Effective Date: March 16, 2020
This policy describes: (i) The types of information we collect when you use our service; (ii) How we use, share, and protect that information; (iii) How long we retain that information; and (iv) Your rights and options regarding the information we collect.
- Information We Collect. We collect two different classes of information from you.
- The first is Personally Identifiable Information (PII) which pertains to you as an individual. We will collect PII from you only if you choose to complete the form in order to receive information about continuing your education. As of this date, we collect the following information when you complete a form on our site:
- Your full name and date of birth;
- Street and email address,
- Phone number; and
- Specific data pertaining to educational background and goals.
In addition, when you visit our website, we will record your computer IP address or mobile device number and may tie it to the data submitted with the form. Under ordinary circumstances, an IP address or mobile device number recorded in isolation is not PII under the standard definition of the term. However, it may become PII when it is combined with other information, as in this case.
- The second class of information we collect is called General Information, which consists of information that is anonymous in nature and does not identify you as an individual. General Information of this nature is collected through a small piece of computer code called a “cookie,” and includes your computer IP address, unique mobile device identifier, browser type, ISP or carrier name, the URL of the last webpage you visited before visiting our website, and actions you undertake on our site whenever you visit. This information gives us insights on how our users use our site and our services.
- How We Use Information. If you meet the initial qualifications as determined by your answers to the questions presented on the form, we will share your PII with participating schools and educational service providers so they may provide you with information regarding the programs they offer.
If you express an interest in any of the offers presented to you after you complete form, we may use your PII to connect you with the third party that sponsors the offer(s) in which you expressed an interest. We may also use your PII for the following purposes:
- To send you email messages with information that we believe may be of interest to you, including offers for third party products and services;
- For internal business purposes, such as market research, site analysis, etc.; and
- To comply with applicable legal requirements, protect our legal rights, and to enforce our Terms of Service
We use the information we collect through cookies to improve our site’s features, to customize your visits, to determine which of our site’s pages you access, to narrow or limit the advertising materials provided to you based on your prior online activities. Note that we may also choose to anonymize certain elements of the PII you provide to us so that it can no longer be attributed to you. We will use PII that we render anonymous in the same manner as we use General Information.
- How We Share Information. We share PII and General Information as follows:
- Participating Schools and Educational Service Providers: We share your PII with participating schools and educational service providers. It is important to note that these parties are not affiliated with us and may use your information in accordance with their own privacy policies, which we encourage you to review.
- Employees and Contractors: We share your PII with those employees and contractors that must have access to it in order to perform their functions.
- Service Providers: As of the effective date of this policy, any PII we share with service providers is encrypted and inaccessible. We share General Information with nonaffiliated third parties that perform services or functions on our behalf, including cloud storage and web hosting providers, email service providers, and software maintenance service providers. We must necessarily share information with such third parties as may be required to perform their functions, but only to the extent necessary for them to do so.
- Legal Requests: If requested or required by law enforcement authorities, courts, or regulators, we may disclose any information we have collected from you. We also may disclose your information to exercise or protect our legal rights or to defend against legal claims.
- Other: In some cases, we may choose to buy or sell assets. In these business transfers, customer information is typically one of the business assets that are transferred. Moreover, if all or substantially all of our business assets were acquired, or in the unlikely event that we go out of business or enter into bankruptcy, customer information (including your PII), would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any assets may continue to be used as set forth in this policy.
- How We Protect Information. We take the security of your information seriously and use appropriate technical and organizational measures to protect PII against unauthorized or unlawful processing and against accidental loss, destruction or damage. Our website and the server(s) upon which our data is stored is hosted using 256-bit Secure Socket Layering (SSL) to encrypt all elements of PII. This website also uses a generally accepted standard of technological security for the purpose of protecting all information provided by visitors from misuse, loss, or corruption. We also limit access to PII to those employees and contractors who reasonably need access to it to deliver our service.
- How Long We Keep Information. We reserve the right to retain your information for as long as we deem necessary to fulfill a business purpose or comply with a legal request, and may anonymize certain of the information you provide to us so that it can no longer be attributed to you if we would like to retain it for longer periods of time.
- Your Rights and Control. You may limit how we use your PII as follows: (i) You may elect not to have a unique cookie identification number assigned to your computer to avoid aggregation and analysis of data collected on our Site by configuring your browser; and (ii) You may stop receiving commercial emails from us by clicking the “unsubscribe” link at the bottom of the email (this will not prevent or interfere with us sending you non-marketing transactional communications). Residents of certain states, such as California, have additional rights as described below.
- For California Residents. If you are a California resident, you have the following rights regarding the PII we collect from and about you under the California Consumer Protection Act (CCPA):
- Right to Ask: The right to ask us: (1) whether we are collecting, selling, or disclosing your PII; and (2) to identify the categories of PII we collected from and about you;
- Right to Access: The right to access the PII we collected from you;
- Right to Deletion: The right to have your PII deleted without undue delay in certain circumstances;
- Right to Restriction: The right to restrict the sharing or sale of your PII for business purposes in certain circumstances.
- Right to Opt-Out: You have the right to opt-out of the sale of your PII; and
- Right to Non-Discriminatory Treatment: You have the right not to be discriminated against for exercising any of the rights listed above.
If you wish to exercise any of these rights, please contact our Privacy Officer via email at . We will honor the requests you make related to your rights as the law allows, which means, in some cases, there may be legal or other legitimate reasons that we may not be able to address the specific request you make. You do not have to pay any fees to exercise your rights. We will respond to your request within 45 days. We will verify your request using the information associated with your account or other information that is held by us, including your email address.
You may also designate an authorized agent to exercise your CCPA rights on your behalf. In order to allow an authorized agent to make a request on your behalf, please email us at to provide your written request and consent to an authorized agent. When your authorized agent makes a request related to your personal information, we will require the agent to provide the above written permission. We may also require that you verify your own identity directly with us at the time such a request is made.
In addition, under the California Online Privacy Protection Act, California residents may request information regarding the types of PII we share with third parties for direct marketing purposes, and the identities of the third parties with whom we have shared such information during the immediately preceding calendar year. You may request further information about our compliance with this law by contacting our privacy officer at firstname.lastname@example.org. Please note that we are only required to respond to one request per customer each year concerning this law, and we are not required to respond to requests made by means other than through the means described above.
- Tracking Technology and Do-Not-Track Requests. We do not currently employ any technology that enables us to track your online activities over time and across third-party Web sites. Because we do not employ tracking technology, we offer no response to Do-Not-Track requests transmitted by Web browsers.
- Children under 18. Our service is not intended for users under the age of 18, and we do not knowingly collect any information from children under 18. If we are informed that you have provided us with the information of anyone under the age of 18 in a manner that violates any statute or regulation concerning the same, we will attempt to delete it as soon as possible.