· The information we collect and why we collect it;
· How we use that information;
· How we share information; and
· The choices we offer.
1. Personally Identifiable Information That We Collect
You may be required to submit certain personally identifiable information when you register on the Service. The personally identifiable information which you may provide to us could include your name, contact information (including without limitation address, phone number, and email address), gender, birth date, year of graduation, school and/or school district, grade point average, course enrollment information, test scores, schools and scholarships to which you have applied and the result of such application, income information, job title, and other personal information.
We will not combine or aggregate personally identifiable information with non-personal or statistical or technical information in order to create personally identifiable information.
2. Geolocation Information
When you access or use the Service, ConnecPath may access, collect, monitor and/or remotely store “location data,” which may include GPS coordinates (including but not limited to latitude and/or longitude), IP addresses, and/or similar information regarding the actual location of your device. Location data may convey to us information about how you browse or use the Service. Location data does not collect or share any personally identifiable information about you. Location data may be used in conjunction with personally identifiable information. Some features of the Service, particularly any location-based services, may not function properly if use or availability of location data is impaired or disabled.
3. Non-Personal Or Aggregate Information That We Collect
When you access our Service, we may automatically collect non-personally identifiable information from you, such as IP host address, web pages viewed, browser type, operating system, referring service, search information, device type, page views, usage and browsing habits on the Service and similar data. We may also aggregate demographic information collected from our users (such as the number of users in a particular geographical location) in a manner which does not identify any one individual. We may also aggregate information collected offline in connection with the Service, obtain non-personally identifiable information from third party sources and develop aggregate information by anonymizing previously collected personally identifiable information.
It is possible at times when collecting non-personally identifiable information through automatic means that we may unintentionally collect or receive personally identifiable information that is mixed in with the non-personally identifiable information. While we will make reasonable efforts to prevent such incidental data collection, the possibility still exists. If you believe that we have inadvertently collected your personal information, please notify us at email@example.com.
4. Information Usage
We will only use your personally identifiable information as described below, unless you have specifically consented to another type of use, either at the time the personally identifiable information is collected from you or through some other form of consent from you or notification to you:
· We may share your personally identifiable information collected in connection with providing the Service.
· We may use your personally identifiable information to respond to your inquires or requests.
· We may share your personally identifiable information with certain third parties (collectively, the “Third Party Vendors”) to facilitate or improve your use of the Service. By way of example, but not limitation, we may share your information with our payment processors, for the purpose of processing your payments, or with our email platform, for the purpose of sending you emails. We urge you to read the privacy practices of all of our Third Party Vendors before submitting any personally identifiable information through the Service.
· We may share your personally identifiable information for training and/or internal marketing purposes or to deliver better service.
· We may disclose personally identifiable information as required by law or legal process.
· We may disclose personally identifiable information to investigate suspected fraud, harassment or other violations of any law, rule or regulation, or the terms or policies for our services or our sponsors.
· We may transfer your personally identifiable information in connection with the sale or merger or change of control of ConnecPath or the division responsible for the services with which your personally identifiable information is associated.
· We may share your personally identifiable information with an affiliate of ConnecPath who is in the same corporate family as us as long as their privacy practices are substantially similar to ours.
Non- personally identifiable or aggregate information may be used by us for any purposes permitted by law and may be shared with any number of parties, provided that such information shall not specifically identify you.
5. California Student Data Privacy Agreement
We proudly comply with the California Student Data Privacy Agreement (the "CSDPA"). You can read the entire text of the CSDPA at https://secure2.cpsd.us/cspa/agreements/CSDPA_Final_V1_Overview_022717.pdf.
The CSDPA shall be referred to collectively as the “Pledges.”
Notwithstanding the foregoing, you acknowledge and agree that:
· We may use your personally identifiable information for internal marketing purposes; provided, however, we will not share your personally identifiable information with third parties for marketing purposes.
· We may send or present you with targeted advertisements for the purpose of helping you discover educational-related content. These advertisements may be targeted based on certain information that you provide (e.g., zip code), but not based on any behavioral data.
· We may share non-personally identifiable information with vendors or other third parties.
6. De-Identification of Personally Identifiable Information
In accordance with the CSDPA, and in an effort to avoid unnecessarily retaining personally identifiable information, we will de-identify users’ personally identifiable information whenever we determine, in our reasonable discretion, that such user(s) are no longer using the Service. You may request that we de-identify your personally identifiable information by emailing us at firstname.lastname@example.org. Upon confirmation of your request, we will make all reasonable efforts to comply with your request within a reasonable amount of time.
7.Cookies and Similar Technologies
If you delete your cookies, change browsers or use a different cookie, our cookie (or an opt-out cookie) may no longer work and you will have to reinput (or opt-out) again.
8. Automatically Collected Information
When you access the Service or open one of our HTML emails, we may automatically record certain information from your system by using cookies and other types of tracking technologies. This "automatically collected" information may include Internet Protocol address ("IP Address"), a unique user ID, device type, device identifiers, browser types and language, referring and exit pages, platform type, version of software installed, system type, the content and pages that you access on the Service, the number of clicks, the amount of time spent on pages, the dates and times that you visit the Service, and other similar information. Depending on the law of your country of residence, your IP address may legally be considered personally identifiable information.
9. Analytics and Conversion Tracking
We may collect information about your computer, including your IP address, operating system and browser type, for system administration and in order to create reports. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual.
Like many services, Google Analytics uses first-party cookies to track visitor interactions as in our case, where they are used to collect information about how visitors use our site. We then use the information to compile reports and to help us improve our site.
Cookies contain information that is transferred to your computer’s hard drive. These cookies are used to store information, such as the time that the current visit occurred, whether the visitor has been to the site before and what site referred the visitor to the web page.
Google Analytics collects information anonymously. It reports website trends without identifying individual visitors. You can opt out of Google Analytics without affecting how you visit our site – for more information on opting out of being tracked by Google Analytics across all websites you use, visit https://tools.google.com/dlpage/gaoptout.
We also use Google conversion tracking and/or similar services to help us understand your and other users’ use of the Service.
Please see https://support.google.com/adwords/answer/1722022?hl=en for more information about conversion tracking provided by Google.
The security of your personally identifiable information is very important to us. When we collect your personally identifiable information online, we use reasonable efforts to protect it from unauthorized access by developing and providing the Service with reliable providers such as Amazon and Google. However, due to the inherent open nature of the Internet, we cannot guarantee that your personally identifiable information will be completely free from unauthorized access by third parties such as hackers and your use of our Service demonstrates your assumption of this risk. We have put in place reasonable physical, electronic, and managerial procedures to safeguard the information we collect. Only those employees who need access to your information in order to perform their duties are authorized to have access to your personally identifiable information. For more information on protecting your privacy, please visit www.ftc.gov/privacy.
11. Your Disclosures In Blogs And Other Social Media
You should be aware that personally identifiable information which you voluntarily include and transmit online on the Service or in a publicly accessible blog, chat room, social media platform or otherwise online, or that you share in an open forum such as an in-person panel or survey, may be viewed and used by others without any restrictions. We are unable to control such uses of your personally identifiable information, and by using the Service or any other online services you assume the risk that the personally identifiable information provided by you may be viewed and used by third parties for any number of purposes.
12. California Online Privacy Protection Act
According to CalOPPA, we agree to the following:
· Users can visit our site anonymously.
You change your personal information:
· By emailing us.
13. Protection for Children and Students
We generally do not collect personally identifiable information from children under the age of 13. If at any time in the future we plan to collect personally identifiable information from children under 13, such collection and use, to the extent applicable, shall, when required, be done in compliance with the Children’s Online Privacy Protection Act (“COPPA”) and appropriate consent from the child’s parent or guardian will be sought where required by COPPA. When we become aware that personally identifiable information from a child under 13 has been collected without such child’s parent or guardian’s consent, we will use all reasonable efforts to delete such information from our database.
Any collection of student educational records by us will comply with the Family Educational Rights and Privacy Act of 1974 (“FERPA”) and California Assembly Bill No. 1584. More information on FERPA can be found here: https://www2.ed.gov/policy/gen/guid/fpco/ferpa/index.html. More information on California Assembly Bill No. 1584 can be found here: https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=201320140AB1584.
14. Other Services
As a convenience to you, we may provide links to third-party Services from within our Service. We are not responsible for the privacy practices or content of these third-party sites. When you link away from our Service, you do so at your own risk.
16. Opt-Out Process
17. Communications with ConnecPath
Any phone calls and/or text messages delivered to your phone or device may cause you to incur extra data, text messaging, or other charges from your wireless carrier. MESSAGE AND DATA RATES MAY APPLY. You are solely responsible for any carrier charges incurred as a result of phone and/or text communications from ConnecPath.
18. No Rights of Third Parties
21. Governing Law
For questions or concerns relating to privacy, we can be contacted at email@example.com.