Effective Date: January 19, 2022
Personal Profile Information. Your Personal Profile Information means the Personal Information (defined below) and Demographic Information (defined below) you provide when registering for the Program, and any updates you or we make to your Personal Profile Information, including information that is provided to us by one of our affiliates.
- Our Commitment to the Protection of Student Information and Privacy
- Determining Appropriate Educational Use
The primary mission of Company is to facilitate connections between registered students and colleges and universities. Any other education-related organizations wishing to connect with registered users of the Program are individually reviewed to determine whether they offer a “redeeming educational value” AND fit in one of the following approved categories defined within the Elementary and Secondary Education Act (ESEA) and other applicable law:
- Financial planning, student loans, and scholarships
- Enrichment opportunities such as travel programs, camps, extra-curricular activities and conferences
- Curriculum materials, books, Internet based educational programs, educational magazines providing low-cost literary products
- Academic assistance, remedial help, and preparation for college-entrance examinations
- Recognition for high levels of performance
- Participation in community service
- Learning about civic responsibilities
- Employment, career options and the militaryCollectively, the purposes set forth above in this section are “Education-related Products and Services.” The Program also utilizes users’ profile and behavior for research purposes to get a better understanding of the educational system.
- Determining Appropriate Educational Use
- Collection of Information
- Information You Provide
The Program, Company, and/or our Service Providers (defined below), may collect information you provide directly to us and/or our Service Providers via the Program. For example, we collect information when you use or register for the Service, subscribe to notifications, post on the Service, participate in activities, or communicate or transact with us through the Program. In addition, when you interact with Third-Party Services (defined below), you may be able to provide information to those third parties. For more information on Service Provider data collection and practices, see Section 4 below. For more information on Third-Party Services’ data collection and practices, see Section 5 below.
- Information Collected Automatically
The Program, Company, our Service Providers, and/or Third Party Services, may also automatically collect certain information about you when you access or use the Service, and/or visit third party services (“Usage Information”). Usage Information may include IP address; device identifier; browser type; operating system; information about your use of the Service; and data regarding network connected hardware (e.g., computer or mobile device). Except to the extent required by applicable law, or to the extent Usage Information is combined by or on behalf of Company with Personal Profile Information, we do not consider Usage Information to be Personal Profile Information. For more information on Service Provider data collection and practices, see Section 4 below. For more information on Third-Party Services’ data collection and practices, see Section 5 below.
The methods that may be used on the Service to collect Usage Information include:
- Log Information
Log information is data about your use of the Service, such as IP address, browser type, Internet service provider, referring/exiting pages, operating system, date/time stamps, and related data, which may be stored in log files or otherwise.
- Information Collected by Cookies and Other Tracking Technologies
Cookies, web beacons (also known as “tracking pixels”), embedded scripts, location-identifying technologies, fingerprinting, device recognition technologies, in-app tracking methods and other tracking technologies now and hereafter developed (“Tracking Technologies”) may be used to collect information about interactions with the Service or emails, including information about your browsing and activity behavior.
A cookie is a small text file that is stored on a user’s device, which may be session ID cookies or tracking cookies. Session cookies make it easier for you to navigate the Service and expire when you close your browser. Tracking cookies remain longer and help in understanding how you use the Service, and enhance your user experience. Cookies may remain on your hard drive for an extended period of time. If you use your browser’s method of blocking or removing cookies, some, but not all types of cookies may be deleted and/or blocked and as a result, some features and functionalities of the Service may not work. The Service may associate some or all of these types of cookies with your devices.
You can exercise control over browser-based cookies. Please see the section regarding Tracking Technologies below for more information.
- Web Beacons (“Tracking Pixels”)
Web beacons are small graphic images, also known as “Internet tags” or “clear gifs,” embedded in web pages and email messages. Web beacons may be used, without limitation, to count the number of visitors to the Service, to monitor how users navigate the Service, and to count content views.
- Embedded Scripts
An embedded script is programming code designed to collect information about your interactions with the Service. It is temporarily downloaded onto your computer from our web server, or from a third party with which we work, and is active only while you are connected to the Service, and deleted or deactivated thereafter.
- Location-identifying Technologies
GPS (global positioning systems) software, geo-filtering and other location-aware technologies locate (sometimes precisely) you for purposes such as verifying your location and delivering or restricting content based on your location.
Collection and analysis of information from your device, such as, without limitation, your operating system, plug-ins, system fonts and other data, are for purposes of identification and/or tracking.
- Device Recognition Technologies
Technologies, including application of statistical probability to data sets, as well as linking a common unique identifier to different device use (e.g., Facebook ID), attempt to recognize or make assumptions about users and devices (e.g., that a user of multiple devices is the same user or household).
- In-app Tracking Methods
There are a variety of Tracking Technologies that may be included in mobile applications, and these are not browser-based like cookies and cannot be controlled by browser settings. Some use device identifier, or other identifiers such as “Ad IDs” to associate app user activity to a particular app and to track user activity across apps.
Some information about your use of the Service and certain other online services may be subject to Tracking Technologies and used by the Company and third parties for purposes such as associating different devices that you use to deliver relevant ads and/or other content to you on the Service and on other online services. Please see the section regarding Tracking Technologies below for more information.
- Log Information
- Information Company Collects from Partners and Other Sources
- Information You Provide
- Use of Information
- Allow you to participate in the features and services we offer
- Facilitate, manage, personalize and improve your experience;
- Process your Registration, analyze your interests and/or fulfill your requests;
- Transact with you, provide services or information you request, respond to your comments, questions and requests, serve you content and/or advertising and send you notices;
- Improve the Service and for any other internal business purposes;
- Tailor our content, resources and offers;
- Fulfill other purposes disclosed at the time you provide Personal Information or otherwise where we have a legally permitted purpose or are required to do so; and
- Prevent and address fraud, breach of policies or terms and threats or harm.
- Sharing of Information
- Education-related Products and Services
We share your information with our affiliates to provide to colleges, universities and others that offer Education-related Products and Services. A value of this is that you may receive information and/or offers from colleges, universities and others that offer Education-related Products and Services. Absent your consent, however, (which may be by means of third party interaction described in the next subsection) we will not share your Personal Profile Information with third parties for their own direct marketing of non- Education-related Products and Services.
- Your Disclosure or Consent
- Corporate Transactions
We may share your Personal Profile Information and other information, including without limitation, your non-Personal Information and Personal Information that is not Personal Profile Information, in connection with or during negotiations of, any proposed or actual merger, purchase, sale, joint venture or any other type of acquisition or business combination of all or any portion of our assets, or transfer of all or a portion of our business to another company (“Corporate Transactions”).
- To our agents, vendors, consultants, and other service providers (collectively “Service Providers”) who may receive, or be given access to your information, including without limitation, Personal Information, Demographic Information, and Usage Information, in connection with their work on our behalf, provided however, we do not authorize our Service Providers to use Personal Profile Information provided by us to the Service Providers to send you direct marketing messages, other than as part of our Program related to Education-related Products and Services, absent your consent. Service Providers may associate their own Tracking Technologies with you to collect information from you. For more information on Tracking Technologies and your choices regarding them, read Section 2 and Section 11.
- We and third parties may convert your Personal Profile Information and your Personal Information to non-Personal Information, including without limitation through hashing it or substituting a unique identifier for the personal information and we and third parties may use and share that data as permitted by applicable law, including to match data attributes from other sources and to send targeted advertisements. For your options regarding targeted advertising, see Section 11.B. For such practices by third parties, consult their privacy policies.
- To comply with the law, law enforcement or other legal process, and in response to a government request.
- To our affiliated entities.
- Education-related Products and Services
- Sweepstakes, Contests, and Promotions
- Co-branded Pages, Third Party Services, Advertising and Analytics
Our Service may engage and work with Service Providers and other third parties to serve advertisements on the Service, and/or on third-party services. Some of these ads may be tailored to your interests based on your browsing of the Service and elsewhere on the Internet over time, sometimes referred to as “interest-based advertising” and “online behavioral advertising” (“Interest-based Advertising”), which may include sending you an ad on a third party service after you have left the Service (i.e., “retargeting”). See Section 11 for information on certain choices offered by third parties regarding Interest-based Advertising.
- Data Security and Monitoring
- International Transfer
The Service is intended for a general audience and not directed to children less than 13 years of age. The Program does not intend to collect personal information as defined by the U.S. Children’s Online Privacy Protection Act (“COPPA”) (Children’s Personal Information) in a manner that is not permitted by COPPA. If you are a parent or guardian and believe we have collected Children’s Personal Information in a manner not permitted by COPPA, please contact us at email@example.com and we will remove such data to the extent required by COPPA. Any California residents under the age of eighteen (18) who have registered to use the Service, and who posted content or information on the Service, can request removal by contacting Company at firstname.lastname@example.org with a message detailing where the content or information is posted and attesting that you posted it. Company will then make reasonable good faith efforts to remove the post from prospective public view or anonymize it so the minor cannot be individually identified to the extent required by applicable law. This removal process cannot ensure complete or comprehensive removal. For instance, third parties may have republished or archived content by search engines and others that Company does not control.
- Accessing and Changing Your Information
We may provide web pages or other mechanisms allowing you to delete, correct or update your Personal Profile Information. California minors should review the Section 9 above titled “Children’s Privacy” to learn more about how to request removal of certain content they have posted on the Service. We will make good faith efforts to make requested changes in Company’s then-active databases as soon as practicable, but it is not always possible to completely change, remove or delete all of your information or postings from our databases and residual and/or cached data may remain archived thereafter. Further, we reserve the right to retain data (a) as required by applicable law; and (b) for so long as reasonably necessary to fulfill the purposes for which the data is retained except to the extent prohibited by applicable law.
- Choices Regarding Your Information
- Tracking Technologies Generally
Regular cookies may generally be disabled or removed by tools available as part of most commercial browsers, and in some instances blocked in the future by selecting certain settings. Browsers offer different functionalities and options so you may need to set them separately. Please be aware that if you disable or remove these technologies, some parts of the Service may not work and that when you revisit the Service, your ability to limit browser-based Tracking Technologies is subject to your browser settings and limitations. App-related Tracking Technologies in connection with non- browser usage (e.g., most functionality of a mobile app) can only be disabled by uninstalling the app. To uninstall an app, follow the instructions from your operating system or handset manufacturer. Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no consensus among industry participants as to what “Do Not Track” means in this context. Like many online services, we currently do not alter our practices when we receive a “Do Not Track” signal from a visitor’s browser. To find out more about “Do Not Track,” you can visit here, but we are not responsible for the completeness or accuracy of this third party information. Some third parties, however, may offer you choices regarding their Tracking Technologies. One way to potentially identify cookies on our Site is to add the free Ghostery plug-in to your browser, which according to Ghostery will display for you traditional, browser-based cookies associated with the websites (but not mobile apps) you visit and privacy and opt-out policies and options of the parties operating those cookies. The Program is not responsible for the completeness or accuracy of this tool or third party choice notices or mechanisms. For specific information on some of the choice options offered by third party analytics and advertising providers, see the next section.
- Analytics and Advertising Tracking Technologies
- Mobile Apps
With respect to our mobile apps (“App(s)”), you can stop all collection of data generated by use of the App by uninstalling the App. Also, you may be able to exercise specific privacy choices, such as enabling or disabling certain location-based or other services, by adjusting the permissions in your mobile device or in the App settings. However, other means of establishing or estimating location in connection with Service use (e.g., IP address, connecting to or proximity to wi-fi, Bluetooth, beacons, or networks, etc.) may persist. See also the prior section regarding the DAA’s mobile Interest-based Advertising choices. To learn more about how you can control location permissions using your mobile device’s operating system settings, please visit the link below that is most applicable to the device you are using:
- Android (6.0 and above): https://support.google.com/googleplay/answer/6270602?hl=en
- Android (earlier versions): https://support.google.com/googleplay/answer/6014972
- iOS: https://www.apple.com/legal/privacy/data/en/location-services/
You can opt-out of receiving certain promotional email communications from us at any time by following the instructions provided in emails to click on the unsubscribe link, or if available, by changing your communication preferences by logging onto your account. Please note that your opt-out is limited to the email address connected to your account and will not affect subsequent subscriptions. If you opt-out of only certain communications, other subscription communications may continue. Even if you opt-out of receiving promotional communications, we may, subject to applicable law, continue to send you non-promotional communications, such as those about your account, transactions, servicing, or our ongoing business relations.
You may turn off the app push notifications through your device settings and/or the app settings, as applicable.
By providing a phone number you consent to be contacted at that number, including promotional phone calls related to us and educational-related companies we think you may find of interest, and administrative texts regarding the Program or Service that do not include advertising messages. For promotional calls, you may opt-out of pre-recorded calls by following the automated prompts and for live promotional calls you may opt- out by telling the operator. Such an opt-out will prospectively end our promotional calls to you, and we will no longer share your number with educational-related companies for their promotional calling, unless you subsequently opt back in. However, you will need to opt-out of any educational-related companies that received your number prior to your opting out with us directly with those third parties. For text messages, you may withdraw consent by replying “STOP” to our texts, but if you thereafter provide a number to receive texts you will have opted back in. We may offer separate text subscription programs for different purposes, in which case you must opt-out of each one separately. If you have provided multiple numbers, you must opt- out of each number separately. These calls and texts may be made using autodialers and/or pre-recorded messages. You are not required to consent as a condition of purchasing any property, goods or services and no purchase is necessary to subscribe. Calls from or to us may be recorded; if you do not consent to call recording, discontinue the call.
- Tracking Technologies Generally
- Your California and Nevada Privacy Rights
- Contact Us