Last Updated on January 1, 2020.
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Information that We Collect
Personal Information: Depending on the Services you are visiting or using, we may collect various times of information from and about you, including information that can personally identify you. This information includes, but is not limited to: name, age, postal address, email address, telephone number, fax number, short message service or text message address, other wireless device address, instant messaging address, demographic information, education and scholastic information (including but not limited to level of education, desired level of educational program, and areas of interest), current occupation, military status, governmental loan status, information about any transaction you conduct or submit to on or through the Services, and other information that would allow online or offline contact with you as an individual (collectively, “Personal Information”).
Non-Personal Information: We also collect Usage Information (as defined below) and other information from and about you that does not personally identify you or allow us or others to contact you individually online or offline (“Non-Personally Identifiable Information” or “Non-PII”). We may combine Non-PII with other information in a way that allows you to be identified or personally contacted. If this happens, we will treat the combined information as Personal Information.
How We Collect Information: We may collect information from you in the following ways:
• Information Provided by You. We collect information provided by you when you (1) inquire about or obtain our services or products; (2) communicate with us or request information about or from us, whether via email or other means; (3) fill out forms or fields on the Services; (4) register as a user or sign-up for any of our newsletters, materials or services through the Services; (5) enter into online transactions; (6) create profiles; (7) provide college reviews or participate in our online surveys or questionnaires; (8) input information into our interactive programming features or participate in our online forums; (9) participate in any of our marketing initiatives, including contests, scholarship offers, events, or promotions; and (10) post to the Services or provide user-generated content or submissions to us, including without limitation media files, photos, videos, documents or other information, and contributions to a chat room, list serve, blog, or other open forum or community feature that we make available on the Services (“User Contributions”).
• Information from Other Sources. We may collect information about you from other services that we may provide, our affiliates, third-party or public sources (such as from public forums, social networks, and blogs), other users of the Services, and our business partners.
• Automatic Information Collection. We and our service providers use automatic data collection technologies to collect and store Usage Information (as defined below). This information helps us evaluate how our visitors use and navigate the Site on an aggregate basis, including but not limited to the number and frequency of visitors to each Site, and the length of their visits. We may combine this automatically collected log information with other information we collect about you. We do this to improve services we offer you, to improve marketing, analytics, or site functionality. We also may allow third-party advertising companies and ad networks to use automatic data collection technologies to collect Usage Information for purposes of providing interest based ads. See the Automatic Information Collected Technologies and Usage Information and the Third-Party Advertisers and Interest-Based Ads sections for more information.
How We Use the Information that We Collect
We may use your information, including Personal Information, to:
- Provide products and services requested by you;
- Provide customer support, including responding to your requests and questions and troubleshooting and resolving problems or complaints, and for any other purposes that we deem appropriate;
- Verify the information you provide to us;
- Communicate with you;
- Confirm your identity and eligibility to use the Services;
- Establish and manage your account, as applicable;
- Perform research and analysis to develop and improve the Services and other products and services that we may offer;
- Understand and anticipate your use of or interest in, our products, services, and content, and the products, services, and content offered by others;
- Develop and display products, services, and content tailored to your interests on the Services and other online properties;
- Measure the overall effectiveness of our online advertising, content, and programming, and other activities;
- Manage our business and operations;
- We use the information we automatically collect (such as contact information, IP address and basic browser and system details) to help us optimize our sites and the services we offer on the Sites and may offer in the future;
- To provide you with a customized browsing experience;
- Protect the security and integrity of the Services;
- Fulfill any other purposes for which you provide your information and for any other purpose as described to you at the time your information is collected or for which your consent is given.
Our Sharing Practices
We may disclose or share information from or about you, including your Personal Information, as follows:
- With EducationDynamics’ affiliated companies (i.e., companies that control, are controlled by, or are under common control with us) for support of our internal and business operations.
- With our non-affiliated third-party business partners, service providers, and vendors to enable them to assist us in providing you the products or services you request through the Services or to provide us with support for our internal and business operations, such as customer service, data processing, data storage, research, analytics, web hosting, marketing, providing suggestions and strategies to improve our business processes and the services we provide, and delivery of promotional or transactional materials. We may provide your personal information to companies that provide services to help us with our business activities such as offering customer service. These companies are authorized to use your Personal Information only as necessary to provide these services to us.
- With any person who, in our reasonable judgment, is authorized to receive your information, such as your agent, attorney, parent, legal guardian, or co-signor of a loan application.
- We cannot ensure that all of your private communications and other Personal Information will never be disclosed in ways not otherwise described in this Policy. For example, we may be forced to disclose information to the government or third parties under certain circumstances, third parties may unlawfully intercept or access transmissions or private communications, or users may abuse or misuse your personal information that they unlawfully collect from the Site. We will try to protect your privacy, however, we do not promise, and you should not expect, that your Personal Information or private communications will always remain private.
Automatic Information Collection Technologies and Usage Information
We and our service providers automatically collect “Usage Information” from or about you, such as information about your computer or mobile device, IP address, web browser, computer or device platform, related software and settings you are using, browsing actions and patterns, the referring page that linked you to us and the website you visit after using the Services, and other usage activity on the Services. Collection of Usage Information helps us to improve the Services and to deliver a better and more personalized service by enabling us to, among other things: (1) estimate our audience size and usage patterns; (2) store information about your preferences, allowing us to customize the Services according to your individual interests; (3) speed up your searches; and (4) recognize you when you return to the Services.
We and certain third parties, such as but not limited to advertising service providers, may use certain technologies to collect information about your online activities over time and across different services.
The automatic collection technologies we and our service providers may use for this automatic information collection include:
- Cookies (or browser cookies). A cookie is a small data file that is sent to your browser or related software and stored on your computer’s hard drive when you visit a website. Generally, cookies can track what you look at and where you travel on websites and what transactions you make. They can also store Personal Information about you, including your username and password. A “session cookie” expires immediately when you end your browsing session with the particular website. A “persistent cookie” stores information on your hard drive so when you end your browsing session and return to the same website later, the cookie information is still available. The Services may use both types of cookies.
- Flash Cookies. Certain features of the Services may use locally stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from and on the Services.
- Web Beacons. Pages of the Services and any emails we send to you may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened our emails and for other related website analytics (e.g., recording the popularity of certain website content and verifying system and server integrity).
- Local Storage (LSs). We use LSs such as HTML5 to store content information and preferences. Third parties with whom we partner to provide certain features on our site or to display advertising based upon your Web browsing activity use LSs such as HTML5 and Flash to collect and store information. Various browsers may offer their own management tools for removing HTML5 LSs.
We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.
For more information about managing your privacy settings regarding automatic collection of Usage Information, see the Your Choices about How We Use and Disclose Your Information section.
We may post customer testimonials Site, which may contain personally identifiable information like a video along with their first and last name. We do obtain the customer’s consent via email or via other means prior to posting the testimonial to post their name and video along with their testimonial.
The Services and all electronic communications sent in connection with the Services, may contain links, videos, images, or other content provided by third parties. We do not necessarily endorse these websites, products, services, or practices. We do not control, and are not responsible for, the privacy and security practices of these third parties. We recommend that you review the privacy and security policies of these third parties to determine how they handle information they may collect from or about you once you are on the third party site.
The Services may also allow you to engage with social media features, such as the Facebook Like button, Google Plus, and Twitter widgets, when you are logged into those services. These features may collect information about your IP address and which page you are visiting on the Services, and they may set a cookie to make sure the feature functions properly. Your interactions with these features and the information from or about you collected by them are governed by the privacy policies of the companies that provide them.
Your Choices About Use and Disclosure of Your Information
We strive to provide you with choices regarding the Personal Information you provide to us. Below are some mechanisms that provide you with control over your information:
- Promotional Emails or other Electronic Communications. If you do not wish to receive promotional emails or other electronic communications from us, including but not limited to our e-newsletters, contact us at email@example.com to opt-out or follow the unsubscribe process at the bottom of the promotional email or other electronic communication. Note that even if you opt-out, you may still receive transactional or account-related emails from us (e.g., emails related to the completion of your registration, correction of user data, password reset requests, reminder emails that you have requested, and any other similar communications essential to your transactions on or made through the Services).
- Telephone Calls and Texts. If you do not wish to receive promotional telephone calls from us, contact us at firstname.lastname@example.org to opt-out, and we will add your phone number to our internal Do Not Call List. If you do not wish to receive texts, please follow the unsubscribe process in the text by typing “STOP” and sending it to us.
Accessing and Correcting Your Information
The appropriate method(s) for accessing your information, if any, will depend on which of our websites and services you have visited or used. Depending on the website and service, you may have the ability to view or edit some of your information online, by logging into the Services and visiting your account profile page. You may also contact us at email@example.com to request access to, correct, or delete any Personal Information that you have provided to us; however, we may ask you to verify your identity and provide other details to help us to respond to your request. We will respond to your request within a reasonable timeframe.
To request removal of your personal information from our blog or forum, contact us at firstname.lastname@example.org. In some cases, we may not be able to remove your Personal Information, in which case we will let you know if we are unable to do so and why. If you delete or request the deletion of your User Contributions from the Services, copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied, stored, or reposted to another website by other users of the Services.
Any updates you make or request to be made to your Personal Information will be applied in our own records but will not be updated in the records of the educational institutions or other third parties to which we have already shared your information. If you would like to make updates to the information that has been shared with educational institutions and other third parties, you will need to contact them separately.
We strive to use reasonable security measures to protect your information collected through the Services. However, no method of transmission or electronic storage is 100% effective, and we cannot guarantee absolute security. Therefore, your use of the Services is at your own risk and we do not promise or guarantee, and you should not expect, that your information will always and absolutely remain private and secure. We are not responsible for the circumvention of any privacy settings or security measures contained on or concerning the Services. You are also responsible for taking reasonable steps to protect your personal information against unauthorized disclosure or misuse.
In the unlikely event that we believe that the security of your Personal Information in our possession or control may have been compromised, we may seek to notify you of that development. If a notification is appropriate, we would endeavor to do so as promptly as possible under the circumstances, and, if we have your email address, we may notify you by email. You consent to our use of email as a means of such notification. If you prefer for us to use another method to notify you in this situation, please email us at email@example.com with the alternative contact information you wish to be used.
The Services Are Not for Children
The Services are not intended for children under 13 years of age. We do not knowingly collect personal information from children under 13. In the event that we learn that we have collected Personal Information from a child younger than 13 years old, we will endeavor to delete that information and terminate the child’s account (if any). If you believe that a child under the age of 13 has provided us with personal information without verification of parental consent, please contact us at firstname.lastname@example.org.
The site was created by and is controlled, operated and administered by EducationDynamics, LLC, a Delaware company, or its agents from offices within the United States of America utilizing servers located in the United States of America. We make no representation that materials at this Site are appropriate or available for transmission to or from, or use in, locations outside of the jurisdiction(s) stated above and accessing any Site from any jurisdiction where such Site’s contents are illegal is prohibited. You may not use the Site or export the materials in violation of import or export laws and regulations. If you access a Site from a location outside of the United States, you are responsible for compliance with all local laws. If you are located outside of the United States, please note that the personal data you provide to us will be transferred to the United States. Whenever you submit any personal data to us, you consent to this transfer.
Compliance Department, c/o EducationDynamics, LLC, 111 River Street, 10th Floor, Hoboken NJ 07030 or
Contact us by email at email@example.com.
Unigo Return on Education™ (MyROE™) service offered through www.unigo.com. See Unigo Return on Education™ Privacy Notice.
Special Notice to California Residents — Your California Privacy Rights
California’s Shine the Light law provides California residents with the right to receive disclosures about any sharing of their personal information with other companies.
If you are a California resident and you provided your personal information to EducationDynamics, LLC, then, once each calendar year, you may submit a written request for information about the information we shared, if any, with other companies for their use in direct marketing. To submit your written request, please send a written request to:
Compliance Department, c/o EducationDynamics, LLC
111 River Street, 10th Floor, Hoboken NJ 07030
with “Request for California Privacy” in the letter subject line.
You must include sufficient detail for us to locate your file; at a minimum, your name and postal address.
Within 30 days of receiving your request, we will send you a list of the categories of personal information disclosed to third parties for third-party direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties.
We reserve our right not to respond to requests sent more than once in a calendar year, or requests submitted to an address other than the one posted in this notice. Please note that the California Shine the Light law does not cover all information sharing. Our disclosure only includes information covered by the law.
Information We Collect
We have collected the following categories of personal information from consumers within the last twelve (12) months:
|A. Identifiers.||Real name, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, or other similar identifiers.||YES|
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||Name, address, telephone number, or education. Some personal information included in this category may overlap with other categories.||YES|
|C. Protected classification characteristics under California or federal law.||Age, citizenship, religion or creed, marital status, or veteran or military status.||YES|
|D. Commercial information.||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||YES|
|E. Biometric information.||Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.||NO|
|F. Internet or other similar network activity.||Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.||YES|
|G. Geolocation data.||Physical location or movements.||NO|
|H. Sensory data.||Audio, electronic, visual, thermal, olfactory, or similar information.||NO|
|I. Professional or employment-related information.||Current or past job history or performance evaluations.||NO|
|J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).||Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.||YES|
|K. Inferences drawn from other personal information.||Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||NO|
We obtain the categories of personal information listed above from the following categories of sources:
- Directly from consumers. For example, from information that consumers provide to us related to the services we provide.
- Directly and indirectly from schools, our marketing partners, affiliates, and service providers. For example, through information we collect from our partners in the course of providing or receiving services.
- Directly and indirectly from activity on our website(s). For example, from submissions through our website portal or website usage details collected automatically.
Use of Personal Information
We use or disclose the personal information we collect for one or more of the following business purposes:
- To fulfill the purpose for which the information is provided. For example, if you share your personal information to request info on any schools or programs, we will use that personal information to respond to your inquiry.
- To provide you with information, products or services that you request from us.
- To provide you with emails, event registrations, and other notices concerning our products or services, or events or news, that may be of interest to you.
- To improve our website and present its contents to you.
- For testing, research, analysis and product development.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
We will not collect additional categories of personal information or use the personal information we collected for additional purposes without providing you notice or obtaining your consent where required by law.
Sharing Personal Information
We may disclose your personal information for a business purpose. When we disclose personal information for a business purpose, we enter into a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:
Category A: Identifiers.
Category B: California Customer Records personal information categories.
Category C: Protected classification characteristics under California or federal law.
Category D: Commercial Information.
Category F: Internet or other similar network activity.
Category J: Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
Business purposes may include, but are not limited to: (1) auditing such as advertising analytics or auditing legal and regulatory compliance; (2) security such as detecting security breaches, protecting against fraud and malicious activity, or taking action against wrongdoers (e.g. fraudsters and hackers); (3) debugging such as identifying and fixing technical errors; (4) short-term uses including contextual ad customization that does not involve or contribute to profiling; (5) performing services such as account maintenance, customer service, or marketing; (6) internal research to develop or demonstrate technology; or (7) testing or improvement of any service or device “owned, manufactured, manufactured for, or controlled by” the business.
Your Rights and Choices
The CCPA provides California residents with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information. We will disclose the following information to you upon receiving your verifiable consumer request:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting that personal information.
- The categories of third parties with whom we share that personal information.
- The specific pieces of personal information we collected about you.
- Our business or commercial purpose for selling or disclosing that personal information, if applicable.
- If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
- Sales – Identifying the personal information categories that each category of recipient purchased; and
- Disclosures for a business purpose – Identifying the personal information categories that each category of recipient obtained.
Deletion Request Rights
You have the right to request that we delete personal information that we collected from you, subject to certain exceptions. We will delete (and direct our service providers to delete) your personal information from our records upon receiving your verifiable consumer request, unless an exception applies.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a request to us by either:
Calling us at 1-888-266-6010
Data Deletion Requests: https://educationdynamics.com/DataRequest/DeleteData
Data Access Requests: https://educationdynamics.com/DataRequest/RequestData
Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a request related to your personal information. You may also make a request on behalf of your minor child.
We are not required to provide personal information to you more than twice within a 12-month period.
We cannot respond to your request or provide you with personal information if we cannot reasonably verify your identity or authority to make the request or confirm the personal information relates to you. We will not require you to create an account with us in order to make a request. We will only use personal information provided in a request to verify your identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time, we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically. Any disclosures we provide will cover the 12-month period preceding our receipt of the verifiable consumer request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
Changes to Our Privacy Notice
We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you through a notice on our website or obtain consent where required by law.
Postal Address: EducationDynamics, LLC
Attn: Compliance Department
111 River Street, 10th Floor
Hoboken, NJ 07030
Residents of the State of Nevada have the right to opt-out of the sale of certain pieces of their information to third parties who will sell or license their information to others. If you are a Nevada resident and would like to make such a request, please email firstname.lastname@example.org or submit a request at https://educationdynamics.com/DataRequest/DoNotSellData.