Privacy Policy

DRAFT — not legally reviewed. This is a counselor-drafted starting point. Have a lawyer review it before treating it as your live policy.

Last updated: 5/23/2026

Who we are

Illuma Admissions Counseling is an independent college counseling practice based in the San Francisco Bay Area, California. This Privacy Policy explains how we collect, use, store, and protect information when families work with us.

For questions about this policy, contact us at counselor@illumacounseling.com.

What we collect

When you engage our services, we collect information necessary to provide college counseling. This typically includes:

Identifying information: name, email, phone, high school, graduation year
Academic data: GPA, standardized test scores (SAT / ACT), AP / IB / Honors course history, transcripts you share with us
Activities and awards: descriptions of extracurricular activities, honors, work and volunteer history
Background information: demographics where you choose to share them (first-generation status, international student status, languages spoken at home, family context)
Application materials: college essay drafts, supplemental essays, application lists, school-specific responses
Session notes: observations the counselor records during meetings — anecdotes, preoccupations, Q&A from conversations
Communications: emails, text messages, scheduling information related to your engagement

We do not collect financial account information, social security numbers, or government IDs unless explicitly required for a specific scholarship or aid context, with your prior consent.

How we use this information

Information is used solely to:

Provide direct college counseling services to you
Generate analysis and recommendations about your college list, essay directions, and application strategy
Compare your profile against past student outcomes to inform recommendations
Communicate about scheduling, deadlines, and process

We do not sell your information. We do not use your information for advertising.

Service providers

We use third-party service providers to operate our practice, including for web hosting, database storage, and AI-assisted analysis. All processors we use are US-based. We do not transfer your data outside the United States. These processors are contractually bound not to use your data for any purpose other than providing services to us, and not to train AI models on customer data.

Past student data as peer reference

A central part of our methodology is comparing each current student against past students with similar profiles. We do this so our recommendations are grounded in what has actually worked, not in generic advice.

For this to happen:

At intake we ask each family for explicit consent to use the anonymized case data as a peer reference for future students. This is opt-in.
You may revoke this consent at any time by emailing us. Upon revocation, your data will no longer be used as a peer reference.
Even with consent, peer references are used anonymized — names, specific schools attended, and other identifying details are stripped from any peer-comparison context that informs another student's analysis.

Data retention

We retain student data for:

Duration of active counseling: all data is retained while you are an active client.
Up to 7 years after the engagement ends for our own records, in line with standard business retention norms.
As peer reference data, indefinitely, only if you have consented — until you revoke consent.

You may request earlier deletion at any time (see "Your rights" below).

Your rights

You have the right to:

Access the data we hold about you
Correct any inaccurate information
Delete your data (subject to any business-record retention obligations)
Revoke consent to peer-reference use
Receive a copy of your data in a portable format

To exercise any of these rights, email counselor@illumacounseling.com. We respond within 30 days.

Children's data

We work primarily with high school students, most of whom are minors under California law. We do not knowingly collect data from children under 13 without verifiable parental consent. For students 13 to 17, we expect parents or guardians to be involved in the engagement and aware of what information is shared.

Security

We use industry-standard practices to protect student data:

Encrypted connections (HTTPS) between you, our application, and our database
Encrypted data at rest in our database
Access restricted to the counselors directly engaged with your case
Service-provider authentication keys stored as secrets, not in code

No system is perfectly secure. If we become aware of a security incident affecting your data, we will notify you in accordance with applicable California law.

California residents

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA), including the right to know, the right to delete, the right to correct, the right to opt out of sale or sharing of personal information (we do not sell or share), and the right to non-discrimination for exercising any of these rights.

To exercise these rights, contact counselor@illumacounseling.com.

Updates to this policy

We may update this Privacy Policy from time to time. Material changes will be communicated by email to current clients, and the updated policy will be posted on this page with an updated "Last updated" date.

Contact

Questions about this Privacy Policy, requests to exercise your rights, or concerns about how we handle your data:

Illuma Admissions Counseling Email: counselor@illumacounseling.com

Notes for the legal reviewer (delete before publishing):

Confirm CCPA / CPRA wording is current; California privacy law continues to evolve.
Confirm 7-year retention period is appropriate for an education-services business in California.
Confirm minor-data language is appropriate for the actual age range of clients.
If clients include international students, add explicit GDPR-style language for EU residents.