PLEASE READ THIS POLICY CAREFULLY. IT IS YOUR CHOICE WHETHER OR NOT TO PROVIDE PERSONAL INFORMATION TO US. IF YOU CHOOSE TO DO SO, YOU ARE GIVING US YOUR EXPRESS CONSENT TO COLLECT, USE, PROCESS, AND DISCLOSE YOUR PERSONAL INFORMATION AS SET FORTH IN THIS POLICY. IF YOU CHOOSE NOT TO PROVIDE YOUR PERSONAL INFORMATION TO US, YOU WILL NOT BE ABLE TO USE OUR SERVICES.
This Policy details our commitment to protecting the privacy of individuals who visit our Websites, who register to use our services, and who provide personal information to us online or offline. We explain what personal information we collect, how we use it, with whom we may share it, and other potentially relevant information. We encourage you to read the summaries below and to click on “Learn More” if you would like more information on a particular topic.
2. Scope of This Policy
This Policy applies to the Websites that link to this Policy.
For the purposes of this Policy, the term “Websites” shall refer collectively to www.collegenet.com as well as the other websites that CollegeNET operates and that link to this Policy, including but not limited to:
In this Policy, personal information means information relating to an identified or identifiable natural person. An identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, and online identifier or to one or more factors specific to the person’s physical, physiological, genetic, mental, economic, cultural, or social identity. Personal information does not include aggregate information or de-identified information, meaning that the information can no longer be attributed to an identifiable natural person without the use of additional information.
Personal information is required for us to be able to provide the services to you. In addition, some of the services we provide require that we disclose your personal information to third parties, such as to companies that help us to provide our services and to client institutions whose forms we host on our Websites. If you are not willing to provide your personal information and have it disclosed to third parties in accordance with this Policy, you will not be able to use our services.
Our Websites may contain links to other websites, and the information practices and the content of such other websites are governed by the privacy statements of such other websites. We encourage you to review the privacy statements of such other websites to understand their information practices.
While we strongly support the protection of privacy on the Internet, we do not have control over, and cannot be responsible for, the actions of our client institutions or other third parties. We encourage you to review each such client institution’s or third party's privacy statement and to otherwise understand its privacy practices, before providing personal information directly to it or in our forms on which it is named.
3. Personal Information We Collect
We collect personal information to operate effectively and provide you with the best experiences with our services. You provide some of this information directly, such as when you create an account, start or submit a form hosted by us, or contact us for support. We get some of the information, such as your IP address, by recording how you interact with our services. We may also get information about you from our client institutions or other third parties.
Information That You Provide To Us
We ask for and may collect personal information about you such as your name, address, phone number, email address, instant messaging ID, and electronic payment information when you register for an account to access or when you use one or more of our services.
We ask for and may collect personal information from you when you start or submit web forms on our Websites, via email, or as you use interactive features of the Websites, including, participation in surveys, discussions, contests, requesting customer support, or otherwise communicating with us. This personal information may include non-text components such as images and videos.
A third party intermediary is used to manage electronic payment processing. This intermediary is not permitted to store, retain, or use your cardholder data for any purpose except for electronic payment processing on our behalf.
By voluntarily providing us with your personal information, you represent that the personal data is accurate and that you are the owner of such personal data or otherwise have the requisite consent to provide it to us.
Information That We Collect From You On Our Websites
As is true with most websites and services delivered over the Internet, we gather certain information and store it in log files when you interact with our Websites and services. This information includes internet protocol (IP) addresses as well as browser type, internet service provider, URLs of referring/exit pages, operating system, date/time stamp, information you search for, locale and language preferences, identification numbers associated with your devices, your mobile carrier, and system configuration information. Occasionally, we connect personal information to information gathered in our log files as necessary to improve our Websites and services. In such case, we would treat the combined information in accordance with this Policy.
Analytics:We collect analytics information when you use our Websites or our mobile applications to help us improve them. We may also share anonymous data about your actions on our Websites and our mobile applications with third party service providers of analytics services. We do not link analytics information to your personal information.
Information Collected From Other Sources
We may also obtain other information, including personal information, from third parties and combine that with information we collect through our Websites. For example, we may receive information from client institutions you have expressed interest in and test scores that you want associated with your application. In addition, we may have access to certain information from a third party social media or authentication service if you log into our services through such a service or otherwise provide us with access to information from the service.
The Websites may include social media features, such as the Facebook Like button, and widgets, such as the Share This button or interactive mini-programs that run on our Websites. These features may collect your IP address, which page you are visiting on the Websites, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on the Websites. Your interactions with these features are governed by the privacy statement of the companies that provide them.
Any access that we may have to such information from a third party social media or authentication service is in accordance with the authorization procedures determined by that service. By authorizing us to connect with a third party service, you authorize us to access and store your name, email address, and other personal information that the third party service makes available to us, and to use and disclose it in accordance with this Policy. You should check your privacy settings on these third party services to understand and change the information sent to us through these services.
4. How We Use Personal Information
We use the personal information we collect for a variety of purposes. The legal basis for our processing of personal information will depend on the specific context in which we collect it. We will retain personal information for as long as it is needed.
We may use the information we collect about you (including personal information, to the extent applicable) for a variety of purposes, including to: (a) provide, operate, maintain, and improve our services and develop new services; (b) enable you to access and use our services; (c) process and complete transactions and send you related information; (d) send transactional messages, including responses to your comments, questions, and requests; provide customer service and support; and send you technical notices, updates, security alerts, and support and administrative messages; (e) monitor and analyze trends, usage, and activities in connection with the Websites and services; (f) investigate and prevent fraudulent transactions, unauthorized access to our services, and other illegal activities; (g) personalize the Websites and services, including by providing features or advertisements that match your interests and preferences; and (h) for other purposes for which we obtain your consent, such as marketing communications. You can revoke your consent to receive marketing communications from us by following the unsubscribe instructions included in our marketing communications. If you revoke such consent, we will create a record of your preference regarding future marketing communications, which will require us to retain your email address. We may also need to share your preference and email address with third parties solely for the purpose of ensuring that you no longer receive marketing communications from such third parties. We will not discriminate against you as a result of your decision to opt-out of marketing communications.
Legal Basis for Processing (GDPR)
If the General Data Protection Regulation (GDPR) is applicable, our legal basis for processing your personal information will depend on the personal information concerned and the specific context in which we collect it. However, we will normally process your personal information only where: (a) we have your consent to do so; (b) we need the personal information to perform a contract with you (e.g. to provide the services you have requested); or (c) the processing is in our or a third party’s legitimate interests (and not overridden by your data protection interests or fundamental rights and freedoms). In some cases, we may also have a legal obligation to process your personal information, or may otherwise use your personal information to protect your vital interests or those of another person.
Where we rely on your consent to process your personal information, you have the right to withdraw or decline your consent at any time. Please note that this does not affect the lawfulness of the processing based on consent before its withdrawal.
If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information). Similarly, if we collect and use your personal information in reliance on our (or a third party’s) legitimate interests which are not already described in this Policy, we will make clear to you at the relevant time what those legitimate interests are.
If you have any questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided further below.
How Long We Retain Your Personal Information
We will retain your personal information for as long is needed to fulfill the purposes set forth in this Policy, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
For personal information that we process on behalf of a client institution, we will retain such personal information in accordance with the terms of our agreement with them, subject to applicable law.
5. Sharing Of Information Collected
We share your personal information as necessary to provide the services you request, including sharing information with third party service providers; when required by law; to protect rights and safety; and with your consent.Learn More about the Sharing Of Information Collected
6. Transfer of Information (GDPR)
Personal information we collect will be processed in the United States and possibly transferred to entities in other jurisdictions. BY PROVIDING YOUR PERSONAL INFORMATION TO US, YOU CONSENT TO ANY TRANSFER AND PROCESSING IN ACCORDANCE WITH THIS POLICY.
WE HEREBY INFORM YOU THAT THERE ARE POTENTIAL RISKS TO YOU ASSOCIATED WITH TRANSFERRING YOUR INFORMATION TO THE UNITED STATES DUE TO THE ABSENCE OF AN ADEQUACY DECISION AND APPROPRIATE SAFEGUARDS. THESE RISKS INCLUDE THE RISK THAT YOU WILL NOT BE ABLE TO EXERCISE YOUR DATA PROTECTION RIGHTS UNDER APPLICABLE LAW TO PROTECT YOURSELF FROM UNLAWFUL USE OR DISCLOSURE OF YOUR INFORMATION.
IF YOU ARE VISITING OUR WEBSITES OR UTILIZING OUR SERVICES FROM THE EUROPEAN UNION OR OTHER REGIONS WITH LAWS GOVERNING DATA COLLECTION AND USE, YOU ARE AGREEING TO THE TRANSFER OF YOUR PERSONAL INFORMATION TO THE UNITED STATES AND POSSIBLY OTHER JURISDICTIONS.
7. Your Privacy Rights
You have certain rights regarding your personal information, as set forth in this Policy and applicable law.
Right to Access and Right to Delete
If you provide us with personal information in connection with your use of our Websites or services, you have the right to access this information and the right to have this information deleted, subject to certain limitations. For some of our services, you have the ability to access, change, and delete the information in your account. Some of our services require you to contact us to request access or deletion.
We will not deny you access to your personal information unless applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal information that we hold about you. Notwithstanding a request to delete information, we may retain information for as long as you maintain an account for our services, as needed to provide you with the services you requested, to comply with our legal obligations, resolve disputes, and enforce our agreements, or because the information is in an Interactive Area.
To make a request to access or delete your personal information maintained by us, please do one of the following things: (1) complete the request form at: www.applyweb.com/privacy/exercise_rights.html; or (2) call the following toll free phone number 833-775-0977. We will respond to your request within ten (10) days. To protect your privacy and security, we will take steps to verify your identity/authority before taking action on your request. We will, when feasible, match the identifying information you provide to the personal information we already have about you. If that is not sufficient to verify your identity/authority, we may request additional information or documentation from you (such as a copy of your photo identification and/or written authorization for an agent to act on your behalf). This additional information will only be used for the purposes of verifying your identity and will be deleted as soon as practical after processing your request, except as required to comply with applicable law. Please note that we cannot change or delete information that you provided in a form that has already been submitted to a client institution. If you want to update or delete information on such a form, you must contact the client institution to which the form was submitted.
If you request access to or deletion of personal information that we store and process on behalf of a client institution, we will direct you to submit your request to the client institution. Upon receipt of a request from one of our client institutions for us to provide or delete your personal information, we will respond to their request within thirty (30) days. We will retain personal information that we store and process on behalf of our client institutions for as long as needed to provide the services to our client institutions. We will retain and use this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
California Privacy Rights
The California Consumer Privacy Act (“CCPA”) and California Privacy Rights Act (“CPRA”) require that we provide notice that California consumers have the following rights:
(1) The right to request that we disclose what personal information we collect, use, disclose, and sell, including the categories of personal information we collect, the categories of sources from which we collect personal information, the business or commercial purpose for collecting or selling personal information, the categories of third parties with whom we share personal information, and, upon receipt of a verifiable request from a California consumer, the specific pieces of personal information we have collected about that California consumer.
(2) The right to request deletion of their personal information collected or maintained by us.
(3) The right, if applicable, to opt out of the sale of personal information by us.
(4) The right to be free from discriminatory treatment by us for the exercise of the privacy rights conferred by the CCPA.
(5) The right to designate an authorized agent to make a request of us on the consumer’s behalf under the CCPA.
(6) The right to request correction of their personal information if it is inaccurate.
(7) The right, if applicable, to limit the use and disclosure of sensitive personal information for reasons other than those necessary to provide the services you request.
The CCPA and CPRA also require that we provide the following information:
The categories of personal information we collected about California consumers in the preceding 12 months are:
- Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.
- Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
- Characteristics of protected classifications under California or federal law.
- Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement.
- Geolocation data.
- Audio, electronic, visual, thermal, olfactory, or similar information.
- Professional or employment related information.
- Education information.
- Inferences drawn from any of the above information.
For each of the above categories of personal information we collected, the categories of sources from which the information was collected are detailed in Section 3 (Personal Information We Collect) of this Policy; the business or commercial purposes for which the information was collected are detailed in Section 4 (How We Use Personal Information) of this Policy; and the categories of third parties with whom we shared the information are detailed in Section 5 (Sharing of Information Collected) of this Policy.
We do not sell personal information, including sensitive personal information. We do not sell personal information of minors under 16 years of age. We have not sold any personal information to third parties for a business or commercial purpose in the preceding 12 months.
We have disclosed personal information to third parties for a business or commercial purpose in the preceding 12 months as detailed in Section 5 (Sharing of Information Collected) of this Policy. The categories of such personal information we disclosed are the same categories of personal information we collected about California consumers that are listed above.
Other California Privacy Rights
California law permits residents of California to request certain details about how their information is shared with third parties for direct marketing purposes. If you are a California resident and would like to make such a request, please contact us at firstname.lastname@example.org.
If you are between the ages of 13 and 17, reside in the state of California, and have registered for a CollegeNET account, you may request and obtain removal of content and information that you posted on our Interactive Areas. To request removal of such content and information, you must send an email to email@example.com that complies with the following: (i) the email must be sent from the email address associated with the CollegeNET account; (ii) the subject line of the email must say "Content Removal Request"; and (iii) the body of the email must include the user name of the CollegeNET account. CollegeNET will send you an email to acknowledge receipt of your content removal request. You must then send a reply email to CollegeNET’s acknowledgement email to confirm your content removal request. We will remove the content and information posted by you within seven (7) business days after receipt of your reply email confirming your content removal request.
We do not guarantee the complete or comprehensive removal of content and information posted by you in the following circumstances: (i) if any applicable law requires us to maintain the content or information; (ii) if the content or information was stored or posted by a third party who also registered for a CollegeNET account, including any content or information that was originally posted by you and then stored, republished, or reposted by such third party (such as a friend or other third party in a post about you); (iii) if we have anonymized the content or information so that you cannot be individually identified; (iv) if you fail to follow the instructions for submitting a request for removal of the content or information; and (v) if you received compensation or other consideration for providing the content or information. Please note that we cannot remove information you entered into a form after you have submitted that form. If you want to update information on such a form, you must contact the client institution to which the form was submitted.
GDPR Privacy Rights
If you are from certain territories (such as the European Union), you may have additional rights available to you under applicable laws, including:
- Rights of access and rectification: You may have the right to request that we provide you with information about whether we store or process any of your personal information and to have any inaccuracies in your personal information corrected.
- Right of erasure: In certain circumstances, you may have a broader right to erasure of personal information that we hold about you – for example, if it is no longer necessary in relation to the purposes for which it was originally collected. Please note, however, that we may need to retain certain information for record keeping purposes, to complete transactions, or to comply with our legal obligations.
- Right to object to processing: You may have the right to request that we stop processing your personal information and/or to stop sending you marketing communications.
- Right to restrict processing: You may have the right to request that we restrict processing of your personal information in certain circumstances (for example, where you believe that the personal information we hold about you is inaccurate or unlawfully held).
- Right to data portability: In certain circumstances, you may have the right to be provided with your personal information in a structured, machine readable and commonly used format and to request that we transfer the personal information to another data controller without hindrance.
- Right to revoke consent: Where our processing of your personal information is based on your consent, you have the right to withdraw your consent at any time. This does not affect the lawfulness of the processing based on consent before its withdrawal.
If you would like to exercise such rights, please complete the request form at www.applyweb.com/privacy/exercise_rights.html. We will consider your request in accordance with applicable laws. To protect your privacy and security, we may take steps to verify your identity before taking action on your request.
You also have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.
8. Children’s Personal Information
We do not knowingly collect any personal information from children under the age of 13. If you are under the age of 13, please do not submit any personal information through our Websites or services. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce this Policy. If you believe a child under the age of 13 has given us personal information, please contact us at firstname.lastname@example.org.
If you are over the age of 13 but under the age of 16 and reside in the European Union, your parent or legal guardian may need to expressly consent to your using our Websites or services. Please direct them to https://www.applyweb.com/public/register?s=consent.
Notice to Parents and Legal Guardians
If you consented to our collection, use, disclosure, or other processing of your child’s personal information, you may review or have deleted the personal information we have about your child, and you can refuse to permit further collection, use, disclosure, or processing of such personal information in accordance with applicable law. If you wish to exercise these rights, please complete the request form at www.applyweb.com/privacy/exercise_rights.html.
9. Other Important Privacy Information
Below you will find additional privacy information you may find important.
The security of your personal information is important to us. We follow generally accepted standards to protect the personal information provided to us, both during transmission and once it is received.
Your account information, if you create an account, is accessible online through the use of a password. To protect the confidentiality of personal information that you provide in connection with a user account, you must keep your password confidential and not disclose it to any other person. We are not responsible for the consequences of any passwords that you disclose or which are lost or stolen, including any unauthorized activity on your account, which shall be your sole responsibility. Please advise us immediately if you believe your password has been misused or otherwise misappropriated.
You may refuse to accept cookies by following the procedures specific to your Web browser. If you do so, your browser may react strangely, and you may not be able to complete, save, or submit a form or use some services on our Websites.
We may assign or transfer this Policy, as well as your account and related information and data, including any personal information, to any person or entity that acquires all or substantially all of our business, stock or assets, or with whom we merge.
We will modify this Policy if our privacy practices materially change in the future. We will notify you of any such modification by posting the modified Policy on our Websites and indicating at the top of the Policy the date it was last updated. We may also notify you of modification or changes by sending you an email or other notification. We encourage you to review the Policy each time you visit one of our Websites, to see if this Policy has been updated since your last visit to make sure you understand how your personal information will be processed.
10. Contact Us
If you have questions regarding this Policy or about our privacy practices, please contact us by email at email@example.com.
Attn: Privacy Officer
805 SW Broadway, Suite 1600
Portland, Oregon 97205