SCHOLAR'S APP – PRIVACY POLICY
Last updated: July 6, 2018
If you have questions regarding this User Agreement or the Website, please contact us by e-mail at moc.ppasralohcs@olleh.
Introduction
This Privacy Policy pertains to the Scholar’s App website, located at the following URL: https://www.scholarsapp.com/(referred to herein as the “Scholar's App Website” or the “Website”). The “Scholar's App Website,” as used in this Agreement, collectively includes all of the webpages, services, content and software comprising or made available through the Website and the individual webpages, including, without limitation, the Scholar’s App application, school-specific forms (called “Supplements”), inquiry forms and all other forms, documents and materials available on or via the website.
Our Privacy Pledge
Scholar’s App is committed to protecting your privacy. We use and disclose information collected on or through the Scholar’s App Website only as described in this Privacy Policy and we utilize industry-standard security practices and procedures to protect your personally identifiable information, as further described below.
Purpose of This Privacy Policy
The purpose of this Privacy Policy is to explain our policies regarding: (a) our collection of information on the Scholar’s App Website, (b) our use and disclosure of the information collected, (c) our use of cookies on the Scholar’s App Website and (d) our security measures for the protection of information. This Privacy Policy applies to all information we collect on or through the Scholar’s App Website.
Relation to Terms of Service
This Privacy Policy forms a part of and is incorporated into the Terms of Service governing your use of the Scholar’s App Website. If you have any questions, concerns or comments about the Terms of Service and/or this Privacy Policy, please contact us through any of the several means described below.
Children Under the Age of 13
THE SCHOLAR'S APP WEBSITE IS PROVIDED SOLELY FOR USE BY REGISTERED USERS AGE 13 OR OLDER.We do not knowingly solicit or collect personally identifiable information from children under the age of 13. All users are required to enter their date of birth at the time of registration. Children under the age of 13 are not permitted to use the Scholar’s App Website themselves and will not be permitted to register or submit a Scholars App application. Parents or legal guardians of children under the age of 13 may register to use the Scholar’s App Website and submit the Scholar’s App application on behalf of a child under the age of 13. For simplicity, “you” or “your” as used in this Privacy Policy includes both the registrant and/or the applicant, as applicable, even if not the same person. By registering for an account on the Scholar’s App Website and by accessing or using the Scholar’s App Website, the registrant affirms and verifies that he or she is age 13 or older. This policy will be strictly enforced. If you believe that a child under the age of 13 has provided any personally identifiable information to us through the Scholar’s App Website, contact us immediately. Any personal information provided by a child under the age of 13 will be permanently and immediately destroyed.
Your Consent and Age Verification
As further explained in the Terms of Service, when you access or use the Scholar’s App Website and when you register for an account on the Scholar’s App Website, you agree to the Terms of Service, including this Privacy Policy, as revised from time to time. You also agree to any revisions to this Privacy Policy when you continue to access or use the Scholar’s App Website after receiving notice of such revisions via the means of notification described below. In addition, by registering for an account on the Scholar’s App Website and by accessing or using the Scholar’s App Website, you verify that you are age 13 or older and give your consent to the collection, use and disclosure of information in the manner disclosed in this Privacy Policy, as revised from time to time. If you do not agree with our policies or practices or you do not consent to the collection, use and/or disclosure of information as disclosed herein, you should not access or use the Scholar’s App Website or, if you are already a registered user, you should discontinue your use of the Scholar’s App Website.
Our Policies Regarding the Collection of Information
The information we collect can be broadly categorized as general information and personally identifiable information.
General information. General information does not specifically identify you and may include, for example, information automatically provided to us by your browser or computer, such as your IP address, Internet service provider, the type of browser you are using, your operating system, the website you visited prior to and after this website, the webpages you visited on this website, your location information, and the date and time of your visit. We automatically collect some general information from you indirectly each time you visit the Scholar’s App Website and the webpages within the site. This type of general information helps us determine, for example, your computer environment, the type of browser and version you are using and the pages you visit on the Scholar’s App Website.
Personally identifiable information is specific to you and identifies you individually. Personally identifiable information includes information such as your name, date of birth, social security number, mailing address and email address. As used in this Privacy Policy, personally identifiable information also includes demographic, academic and other related information about you and your background, as well as any personally identifying information provided about your child, parents, guardians and/or siblings, as applicable.
Scholar’s App necessarily requires applicants to provide personally identifiable information and other information to enable the applicant’s selected schools to identify the applicant and process the applicant’s inquiry form and/or application for admission. All personally identifiable information collected by us is voluntarily provided by you directly when you register for a Scholar’s App account and user id and each time you complete a Scholar’s App application, inquiry form, Supplement or other form on the Scholar’s App Website. Some of the personally identifiable information requested is mandatory and must be provided by the registrant or applicant in order to complete the registration, inquiry or application process. All other information is optional and should not impede the application process if omitted by the applicant.
We may also collect personally identifiable information when you contact us via phone or email for technical support or other requests. By voluntarily providing personally identifying information, you are consenting to our use of such information as described in this Privacy Policy.
Our Policies Regarding Use and Disclosure of Information
Use of General and Personally Identifiable Information. The general information that we collect automatically from users of the Scholar’s App Website (such as IP address, browser type, etc.) is stored primarily in our log files. With the exception of IP address, which may be stored with personally identifiable information in our database to help authenticate your acceptance of our Terms of Service, general information is not used to identify individual users of the Scholar’s App Website. We use general information to analyze website usage loads and trends, to administer the website and to improve the website and our service. We may also use and disclose general information in the aggregate without disclosure of personally identifiable information.
We use your personally identifiable information to prepare your Scholar’s App application. We store this information in our database until it is submitted to scholarship committees for scholarships that you qualify for. We retain a copy of your application, other forms and all general and personally identifiable information in our database for your future use, for the use of scholarship committees and/or other forms, and for our records. All personally identifiable information remains subject to this Privacy Policy, as revised from time to time, and is protected according to our security policies and practices described below. We do not promise to retain your personally identifiable information or general information for any minimum period of time and we may delete all or some of your information at any time, with or without notice, without liability, in the event that you violate our Terms of Service or for any other reason in our sole and absolute discretion. We may use your email address and/or other contact information to communicate with your from time to time about your Scholar’s App application or the scholarships to which your application has been sent, to provide you with technical or other information about the Scholar’s App Website or to respond to your inquiries and requests for customer service. These communications are not promotional in nature. We may also use aggregated (i.e., non-identifying) general and/or personally identifiable information for statistical and other purposes and we may share such aggregate information with our member scholarship committees and partners.
Disclosure of Personally Identifiable Information to Third Parties. We do not sell, lease, license, share or otherwise disclose your personally identifiable information to third parties, except as described in this Privacy Policy.
In providing this service to you, we necessarily must share your Scholar’s App application and related information, including your personally identifiable information, with the scholarships for which you qualify. By submitting a Scholar’s App application via the Scholar’s App Website, you are consenting to such use and disclosure of your application and related information to those scholarship committees, including your personally identifiable information. Note that we cannot and do not control the use and/or disclosure of your personally identifiable information by the scholarship committees to whom your Scholar’s App application is submitted and we are not responsible for any use or misuse by those scholarship committees or any third party. Once your Scholar’s App application is submitted to a particular scholarship committee, the information on the application submitted to the scholarship committee cannot be changed through the Scholar’s App Website. You must contact the scholarship committee directly to change or correct a submitted application.
We may disclose personally identifiable information to our independent contractors, service providers and/or vendors who assist us in performing internal business functions and/or provide other services necessary to the operation of our business and/or the Scholar’s App Website.
We may also disclose personally identifiable information and/or general information to third parties when we reasonably believe that disclosing such information is necessary to: (a) identify or contact a user of the Scholar’s App Website; (b) to prevent abuse, fraud, or unlawful use of the Scholar’s App Website or Scholar’s App application; (c) to protect our rights, safety, or property and/or the rights, safety, or property of others; (d) to initiate or defend a legal action relating to the Scholar’s App Website; or (d) to respond to or comply with a subpoena, other legal or administrative process or law, rule or regulation.
Qualified colleges, universities, nonprofit scholarship services, and educational organizations pay a license fee to use this information to recruit students and manage enrollment in connection with educational or scholarship programs.
- The student agrees to share their profile information with colleges, universities, and scholarship programs. This information will be used for recruitment, scholarship opportunities, and college planning outreach.
- These organizations must sign a license agreement, which outlines the specific terms for which the student information can be used before it must be destroyed.
- Under no circumstances are these organizations allowed to give the student information to other organizations.
- Scholar’s App consistently monitors the use of student information by licensed organizations for compliance.
- Users can opt out of at any time
Finally, we may disclose personally identifiable information in the event of a merger, acquisition, or sale of our business or assets, or in the event of an insolvency, bankruptcy, or receivership, if such information is transferred to one or more third parties as part of our business or assets.
Your Access to Personally Identifiable Information
You may correct or update your personally identifiable information at any time by accessing your Scholar’s App application on the Scholar’s App Website. However, the information on any applications submitted to a school prior to such corrections or updates will not be changed. To make changes to an application already submitted, you must contact the school directly. To avoid fraud, abuse and mistakes, we do not allow you to deactivate your application or close your account online. To deactivate your Scholar’s App application and/or close your account, you must send a signed, written request to our office address set forth below with your name, user id, the reason for your request and a telephone number by which we can reach you. We will attempt to respond to each such request within a reasonable time after receipt. We will retain archived copies of your account, Scholar’s App application and personally identifiable information for our records, subject to this Privacy Policy.
Our Use of Cookies
A cookie is a small amount of data that is sent to your browser from our server and stored on your computer’s hard drive. We use cookies for managing your online sessions while you are using the Scholar’s App Website, to save you from having to repeatedly enter your user ID and password, and to secure your communications with the Scholar’s App Website, when necessary. We do not store personally identifiable information in cookies.
You may choose to accept or reject cookies. By modifying your browser preferences, you have the choice to accept all cookies, to be notified when a cookie is set, or to reject all cookies. If you choose to reject cookies from the Scholar’s App Website, you may not be able to use those parts of the website that require cookies.
Our Security Practices and Procedures
We follow generally accepted industry standards to protect the personally identifiable information you submit to us, both during transmission and once we receive it. When you enter sensitive information on our webpages, we encrypt that information using secure socket layer technology (SSL). We use the same type of encrypted transmissions when providing your application information to your selected schools and when you provide your payment information to the school’s chosen payment processor. We also restrict physical and electronic assess to our servers through the use of perimeter security and industry-standard firewalls. However, be aware that any emails you send to or receive from us are inherently not secure. Contact us by telephone if your question or comment involves sensitive personally identifiable information.
In addition to encrypted transmissions and physical and electronic security, we require you to select a unique user ID and password when you register to use the Scholar’s App Website. You must enter your user ID and password each time you log in to the Scholar’s App Website to access your account. It is your responsibility to maintain the secrecy of your password and to change your password periodically. We recommend that you do not divulge your password to anyone in order to avoid unauthorized access to your account. Each time you are finished working in your account, you should logout of your account, close your browser window and clear the computer cache to avoid unauthorized access to your account. You should contact us immediately if you believe your password or account has been compromised.
No method of transmission over the Internet or data security scheme is 100% secure, however. Therefore, while we strive to use commercially reasonable means to protect your personally identifiable information, we cannot guarantee its absolute security. If you have any questions about our security practices, you may contact us by any of the means described below.
Links to Other Websites
This website may contain links to other websites that are not owned or controlled by or affiliated with Scholar’s App. We are not responsible for the privacy practices of such other sites. We encourage you to be aware when you leave our site and to read the privacy policies of each website that collects personally identifiable information. This privacy policy applies only to information collected by the Scholar’s App Website.
Notice of Modifications to This Privacy Policy
Scholar’s App reserves the right to modify this Privacy Policy from time-to-time as necessary to reflect changing circumstances, including, for example, changes in our information collection and/or usage practices. Scholar’s App will notify you of any modifications to this Privacy Policy by electronically posting the revised Privacy Policy on the Scholar’s App Website. We encourage you to review this Privacy Policy frequently in order to be aware of any changes in the way we collect, use and/or disclose your information. The revised Privacy Policy will be effective as of the Effective Date displayed at the top and bottom of this document. Your continued use of the Scholar’s App Website after the Effective Date of the revised Privacy Policy will constitute your acceptance of the revised Privacy Policy. In addition, Scholar’s App may, but is not obligated to, notify you via e-mail and/or by other means of such modifications.
Information we collect
Information you provide to us
We collect the personal information you provide to us when you Counselors. The categories of information we may collect include:
- Personal Identifiers, including name, email address, postal address, and telephone number
- Professional, including non-public education records and professional information
We collect the personal information you provide to us when you Parents. The categories of information we may collect include:
- Personal Identifiers, including name, email address, postal address, and telephone number
- Commercial and Financial Information, including signature and other financial information
- Professional, including professional information
We collect the personal information you provide to us when you Recommenders. The categories of information we may collect include:
- Personal Identifiers, including name, email address, postal address, and telephone number
- Professional, including professional information
We collect the personal information you provide to us when you Reviewers. The categories of information we may collect include:
- Personal Identifiers, including name, email address, postal address, and telephone number
We collect the personal information you provide to us when you Scholarship Providers. The categories of information we may collect include:
- Personal Identifiers, including name, email address, postal address, and telephone number
- Commercial and Financial Information, including purchases, credit card or debit card number, bank or other financial account number, account name, and signature
- Physical and Audio Data, including visual information
- Professional, including professional information
We collect the personal information you provide to us when you Students/Applicants. The categories of information we may collect include:
- Personal Identifiers, including name, email address, postal address, telephone number, driver's license number, passport number, and military ID number
- Commercial and Financial Information, including signature
- Physical and Audio Data, including physical characteristics or descriptions, audio information, and visual information
- Characteristics of Protected Classifications, including age, sex or gender, race or color, national origin, citizenship or immigration status, gender identity or expression, religion, marital status, medical condition, disability, and military or veteran status
- Other Sensitive Data, including union membership, data revealing racial or ethnic origin, data revealing religious or philosophical beliefs, data concerning sex life or sexual orientation, and data from a known child (under 13 years old)
- Medical, including medical information
- Professional, including professional information
- Inferences, including inferences created from other personal information collected
We collect the personal information you provide to us when you Website Visitors. The categories of information we may collect include:
- Personal Identifiers, including name, email address, and telephone number
We collect the personal information you provide to us when you Business Prospects. The categories of information we may collect include:
- Personal Identifiers, including name, email address, postal address, and telephone number
To the extent we process deidentified personal information, we will make no attempt to reidentify such data.
Information collected automatically
We automatically collect internet or other electronic information about you when you visit our website, such as IP address, browsing history and interactions with our website. This data may be collected using browser cookies and other tracking technologies.
Opt-Out Preference Signals. Your browser settings may allow you to automatically transmit an opt-out preference signal, such as the Global Privacy Control (GPC) signal, to online services you visit. When we detect such signal, we place a U.S. Privacy String setting in your browser so that any third party who respects that signal will not track your activity on our website. Your request to opt-out of sale/sharing will be linked to your browser identifier only and not linked to any account information because the connection between your browser and the account is not known to us. GPC is supported by certain internet browsers or as a browser extension. Find out how to enable GPC..
Information from other sources
We may collect personal information about you from third-party sources, including Other consumers (e.g., referrals).
Other consumers (e.g., referrals)
- Personal Identifiers, including Name and Email address
How long we keep your data
We do not retain data for any longer than is necessary for the purposes described in this Policy.
We generally retain data according to the guidelines below.| Type of Data | Retention Period |
|---|---|
| Cookies and online data we collect while you use our website, including Name, Email address, Telephone number, Age, Sex or gender, Race or color, Medical condition, Disability, Professional information | We delete or anonymize data concerning your use of our website within 15 years of collecting it. |
| Data we collect when you contact us for customer support and other inquiries, including Name, Email address, Postal address, Telephone number, Driver's license number, Passport number, Military ID number, Online Identifiers, Internet Activity, Purchases, Credit card or debit card number, Bank or other financial account number, Account name, Signature, Physical characteristics or descriptions, Visual information, Age, Sex or gender, Race or color, National origin, Citizenship or immigration status, Gender identity or expression, Religion, Marital status, Medical condition, Disability, Military or veteran status, Precise geolocation, Union membership, Data revealing racial or ethnic origin, Data revealing religious or philosophical beliefs, Data concerning sex life or sexual orientation, Medical information, Non-public education records, Professional information | We keep customer feedback and correspondence with our customer service for up to 5 years to help us respond to any questions or complaints. We may keep data beyond this period in anonymized form. |
| Data we collect when you sign up for promotional and marketing communications, including Name, Email address | Where you have signed up to received promotional and marketing communications from us, we will retain any data collected until you opt out or request its deletion. We may keep data beyond this period in anonymized form. We will further retain a record of any opt-outs in order to prevent sending you future communications. |
| Data we collect when you review our products, answer surveys, or send feedback, including Name, Email address | We retain review, survey, and feedback data for up to 15 years following your last contact with us. We may keep data beyond this period in anonymized form to help improve our products and services. |
| Data we collect in connection with privacy requests, including Name, Email address | We retain records related to privacy requests as long as necessary to comply with our legal obligations, and for a minimum of 24 months. |
| Data we collect for security purposes, including Name, Email address | We retain security-related data as long as necessary to comply with our legal obligations and to maintain and improve our information security measures. |
Purposes of Processing
We process personal information for the following purposes:
- Analyzing Data
- Conducting Surveys
- Improving our Products & Services
- Meeting Compliance & Legal Requirements
- Operating Our Website or Mobile Apps
- Providing Customer Support
- Providing Cybersecurity
- Sending Promotional Communications
- Storing and Managing Data
How we disclose information
Information Disclosed for Business or Commercial Purposes in the Last 12 Months, and Categories of Parties Disclosed To
We may disclose the following personal information about you when you Counselors:
| Personal Information Category | Categories of Service Providers | Categories of Third Parties |
|---|---|---|
| Personal Identifiers | Business Operations Tool, Collaboration & Productivity Tools, Customer Support Tools, Governance, Risk & Compliance Software, IT Infrastructure Services, Sales & Marketing Tools, and Web Hosting Services | Cloud Computing & Storage Providers |
| Online Identifiers | Business Operations Tool, Governance, Risk & Compliance Software, IT Infrastructure Services, Sales & Marketing Tools, and Web Hosting Services | None |
| Internet Activity | Business Operations Tool, IT Infrastructure Services, and Sales & Marketing Tools | None |
| Professional | Business Operations Tool and IT Infrastructure Services | Cloud Computing & Storage Providers |
We may disclose the following personal information about you when you Parents:
| Personal Information Category | Categories of Service Providers | Categories of Third Parties |
|---|---|---|
| Personal Identifiers | Business Operations Tool, Collaboration & Productivity Tools, Customer Support Tools, Governance, Risk & Compliance Software, IT Infrastructure Services, Sales & Marketing Tools, and Web Hosting Services | Cloud Computing & Storage Providers |
| Online Identifiers | Business Operations Tool, Governance, Risk & Compliance Software, IT Infrastructure Services, Sales & Marketing Tools, and Web Hosting Services | None |
| Internet Activity | Business Operations Tool, IT Infrastructure Services, and Sales & Marketing Tools | None |
| Commercial and Financial Information | IT Infrastructure Services | None |
| Professional | Business Operations Tool and IT Infrastructure Services | Cloud Computing & Storage Providers |
We may disclose the following personal information about you when you Recommenders:
| Personal Information Category | Categories of Service Providers | Categories of Third Parties |
|---|---|---|
| Personal Identifiers | Business Operations Tool, Collaboration & Productivity Tools, Customer Support Tools, Governance, Risk & Compliance Software, IT Infrastructure Services, Sales & Marketing Tools, and Web Hosting Services | Cloud Computing & Storage Providers |
| Online Identifiers | Business Operations Tool, Governance, Risk & Compliance Software, IT Infrastructure Services, Sales & Marketing Tools, and Web Hosting Services | None |
| Internet Activity | Business Operations Tool, IT Infrastructure Services, and Sales & Marketing Tools | None |
We may disclose the following personal information about you when you Reviewers:
| Personal Information Category | Categories of Service Providers | Categories of Third Parties |
|---|---|---|
| Personal Identifiers | Business Operations Tool, Collaboration & Productivity Tools, Customer Support Tools, Governance, Risk & Compliance Software, IT Infrastructure Services, Sales & Marketing Tools, and Web Hosting Services | Cloud Computing & Storage Providers |
| Online Identifiers | Business Operations Tool, Governance, Risk & Compliance Software, IT Infrastructure Services, Sales & Marketing Tools, and Web Hosting Services | None |
| Internet Activity | Business Operations Tool, IT Infrastructure Services, and Sales & Marketing Tools | None |
We may disclose the following personal information about you when you Scholarship Providers:
| Personal Information Category | Categories of Service Providers | Categories of Third Parties |
|---|---|---|
| Personal Identifiers | Business Operations Tool, Collaboration & Productivity Tools, Customer Support Tools, Governance, Risk & Compliance Software, IT Infrastructure Services, Payment Processors, Sales & Marketing Tools, and Web Hosting Services | None |
| Online Identifiers | Business Operations Tool, Governance, Risk & Compliance Software, IT Infrastructure Services, Sales & Marketing Tools, and Web Hosting Services | None |
| Internet Activity | Business Operations Tool and IT Infrastructure Services | None |
| Commercial and Financial Information | IT Infrastructure Services and Payment Processors | None |
| Professional | Business Operations Tool | None |
We may disclose the following personal information about you when you Students/Applicants:
| Personal Information Category | Categories of Service Providers | Categories of Third Parties |
|---|---|---|
| Personal Identifiers | Business Operations Tool, Collaboration & Productivity Tools, Customer Support Tools, Governance, Risk & Compliance Software, IT Infrastructure Services, Sales & Marketing Tools, and Web Hosting Services | Cloud Computing & Storage Providers |
| Online Identifiers | Business Operations Tool, Governance, Risk & Compliance Software, IT Infrastructure Services, Sales & Marketing Tools, and Web Hosting Services | None |
| Internet Activity | Business Operations Tool, IT Infrastructure Services, and Sales & Marketing Tools | None |
| Commercial and Financial Information | IT Infrastructure Services | None |
| Geolocation Information | IT Infrastructure Services | None |
| Physical and Audio Data | Business Operations Tool, Collaboration & Productivity Tools, and IT Infrastructure Services | None |
| Characteristics of Protected Classifications | Business Operations Tool, Collaboration & Productivity Tools, and IT Infrastructure Services | Cloud Computing & Storage Providers |
| Other Sensitive Data | Business Operations Tool, Collaboration & Productivity Tools, and IT Infrastructure Services | None |
| Medical | Business Operations Tool and IT Infrastructure Services | Cloud Computing & Storage Providers |
| Professional | Business Operations Tool and IT Infrastructure Services | Cloud Computing & Storage Providers |
| Inferences | IT Infrastructure Services | None |
We may disclose the following personal information about you when you Website Visitors:
| Personal Information Category | Categories of Service Providers | Categories of Third Parties |
|---|---|---|
| Personal Identifiers | Customer Support Tools, Governance, Risk & Compliance Software, IT Infrastructure Services, and Web Hosting Services | None |
| Online Identifiers | Business Operations Tool, Data Analytics Providers, IT Infrastructure Services, and Web Hosting Services | None |
We may disclose the following personal information about you when you Business Prospects:
| Personal Information Category | Categories of Service Providers | Categories of Third Parties |
|---|---|---|
| Personal Identifiers | Business Operations Tool, Collaboration & Productivity Tools, Customer Support Tools, Governance, Risk & Compliance Software, IT Infrastructure Services, and Web Hosting Services | None |
California Privacy Notice (CCPA)
This section provides additional information for California residents under the California Consumer Privacy Act (CCPA). The terms used in this section have the same meaning as in the CCPA. This section does not apply to information that is not considered "personal information," such as anonymous, deidentified, or aggregated information, nor does it apply to publicly available information as defined in the CCPA.
To the extent we process deidentified personal information, we will make no attempt to reidentify such data.
Collection and Disclosure of Personal Information
The personal information we collect is described above in Information we collect. The personal information we disclose for business or commercial purposes is described above in How we disclose information. The length of time for which we retain personal information is described above in How long we keep your data. Our purposes for processing data are described above in Purposes of processing.
Information “Sharing” and “Selling”
We do not receive monetary or other valuable consideration in exchange for your data and therefore do not "sell" your data as defined in CCPA.
We do not “share” personal data with third parties, as that term is defined in the CCPA.
We do not knowingly sell or share (for cross-context behavioral advertising) the personal information of consumers under 16 years of age.
CCPA Rights
Your CCPA rights are described below. Make a Privacy Request by clicking here or the link at the top of this page or by emailing us at moc.ppasralohcs@ycavirp.
Right to Know and Access
You have the right to request to know and access the following about the personal information we have collected about you in the past 12 months:
- the categories and specific pieces of personal information we have collected about you
- the categories of sources from which we collect personal information about you
- the business or commercial purposes for which we collect, sell, or share personal information
- the categories of third parties with whom we disclose the information
- the categories of personal information about you that we have sold, shared, or disclosed for a business purpose, and the categories of third parties to whom we have sold, shared, or disclosed that information for a business purpose
The information we would provide to you in response to a Request to Know Categories is contained in this Privacy Notice. To receive a copy of the specific personal information we have about you, submit a Request to Know or Access via the link above. If you make a Request to Know more than twice in a 12-month period, or we determine the request is manifestly unfounded or excessive, we may require you to pay a small fee for this service.
Right to Delete
You have the right to request that we delete any personal information about you that you have provided to us. Subject to certain limitations, we will delete from our records your requested personal information and direct our service providers to do the same.
Right to Non-Discrimination
If you exercise your CCPA consumer rights:
- We will not deny goods or services to you
- We will not charge you different prices or rates for goods or services, including through the use of discounts or other benefits or penalties
- We will not provide a different level or quality of goods or services to you
- We will not suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services
- We will not retaliate against you, as an employee, applicant for employment, or independent contractor
We may still offer you certain financial incentives permitted by the CCPA such as discounts, rewards, premium features, or loyalty accounts that can result in different prices, rates, or quality levels.
Right to Opt-Out
We do not sell or share any personal information to third parties.
Right to Correct
You have the right to correct inaccuracies in your personal data, taking into account the nature of the data and our purposes for processing it.
Request Verification
Before we can respond to a Request to Know or Request to Delete, we will need to verify that you are the consumer who is the subject of the CCPA request. Verification is important for preventing fraudulent requests and identity theft. Requests to Opt-Out do not require verification.
Typically, identity verification will require you to confirm certain information about yourself based on information we have already collected. For example, we will ask you to verify that you have access to the email address we have on file for you. If we cannot verify your identity based on our records, we cannot fulfill your CCPA request. If you submit a request not through our webform, we will ask you to provide the same information requested in the webform.
For a request that seeks specific personal information, we ask that you sign a declaration stating that you are the consumer whose personal information is the subject of the request, as required by the CCPA.
In some cases, we may have no reasonable method by which we can verify a consumer's identity. For example:
- If a consumer submits a request but we have not collected any personal information about that consumer, we cannot verify the request.
- If the only data we have collected about a consumer is gathered through website cookies (i.e. the consumer visited our website but had no other interaction with us), we are unable to reasonably associate a requester with any data collected; therefore, we cannot verify the request.
Authorized Agent
A California resident's authorized agent may submit a rights request under the CCPA by emailing us at moc.ppasralohcs@ycavirp. Requests submitted by an authorized agent will still require verification of the consumer who is the subject of the request in accordance with the process described above. We will also ask for proof that the consumer who is the subject of the request authorized an agent to submit a privacy request on their behalf by either verifying their own identity with us directly or directly confirming with us that they provided the authorized agent permission to submit the request. An authorized agent that has power of attorney pursuant to California Probate Code section 4121 to 4130 may also submit proof of statutory power of attorney, which does not require separate consumer verification.
If you have trouble accessing this notice, please contact us at moc.ppasralohcs@ycavirp.
Contact Us
If you have any privacy-related questions or have trouble accessing this notice, please email moc.ppasralohcs@ycavirp.
Virginia Privacy Notice (VCDPA)
This section provides additional information for Virginia residents under the Virginia Consumer Data Protection Act (VCDPA). The terms used in this section have the same meaning as in the VCDPA. This section does not apply to information that is not considered "personal data," such as deidentified or publicly available information as defined in the VCDPA.
Collection and Disclosure of Personal Information
The personal data we collect is described above in Information we collect. The personal data we disclose to third parties and the categories of third parties to whom we disclose personal data is described above in How we disclose information. The length of time for which we retain personal information is described above in How long we keep your data. Our purposes for processing data are described above in Purposes of processing.
Data “Selling” and Targeted Advertising
We do not receive monetary consideration in exchange for your data and therefore do not "sell" your data as defined in VCDPA.
We do not process personal data for purposes of targeted advertising as defined in the VCDPA.
Profiling
The VCDPA gives consumers the right to opt out of automated profiling that produces legal or similarly significant effects, such as approval for a loan, employment, or insurance.
We do not profile consumers in furtherance of decisions that produce legal or similarly significant effects.
VCDPA Rights
Your VCDPA rights are described below. Make a Privacy Request by clicking here or the link at the top of this page.
Right to Access
You have the right to confirm whether we are processing personal data about you and to access such data. Where processing is carried out by automated means, you have a right to receive a copy of your personal data in a portable and readily usable format that allows you to transmit your data to another controller.
If you make an Access Request more than twice in a 12-month period, or we determine the request is manifestly unfounded or excessive, we may require you to pay a small fee for this service.
Right to Delete
You have the right to request that we delete any personal data provided by or obtained about you. Subject to certain limitations, we will permanently delete any such personal data from our records and direct our processors to do the same.
Right to Non-Discrimination
If you exercise your VCDPA consumer rights:
- We will not deny goods or services to you
- We will not charge you different prices or rates for goods or services
- We will not provide a different level or quality of goods or services to you
However, we may offer a different price, rate, level, quality, or selection of products or services if your personal data is required in order to provide those products or services and you have exercised your right to opt out, or the offer is related to a voluntary loyalty or rewards program.
Right to Opt-Out
Sale of Personal Data:
We do not sell your personal data, as defined by the VCDPA.
Targeted Advertising:
We do not process your personal data for the purpose of targeted advertising.
Profiling:
We do not profile consumers in furtherance of decisions that produce legal or similarly significant effects.
Right to Correct
You have the right to correct inaccuracies in your personal data, taking into account the nature of the data and our purposes for processing it.
Authenticating Your Request
Once we receive your request, we will verify the information you provided by matching the information that we have collected. If we cannot authenticate your request, we may ask for additional information from you. If you are unable to provide additional information, or we are unable to authenticate the request using commercially reasonable efforts, we may deny your request.
Right to Appeal
If we decline to take action in response to any of your privacy requests, you have the right to appeal that decision within a reasonable amount of time, but no later than 90 days from the date of our decision. To submit a request for appeal, click here and select "Appeal a Decision" in the request type drop-down.
If you believe your rights have been violated and you are not able to resolve the issue directly with us, you may file a complaint with the Virginia Attorney General’s Office.
Colorado Privacy Notice (CPA)
This section provides additional information for Colorado residents under the Colorado Privacy Act (CPA). The terms used in this section have the same meaning as in the CPA. This section does not apply to information that is not considered "personal data," such as deidentified or publicly available information as defined in the CPA.
Collection and Disclosure of Personal Information
The personal data we collect is described above in Information we collect. The personal data we disclose to third parties and the categories of third parties to whom we disclose personal data is described above in How we disclose information. The length of time for which we retain personal information is described above in How long we keep your data. Our purposes for processing data are described above in Purposes of processing.
Data “Selling” and Targeted Advertising
We do not receive monetary or other valuable consideration in exchange for your data and therefore do not "sell" your data as defined in CPA.
We do not process personal data for purposes of targeted advertising as defined in the CPA.
Profiling
The CPA gives consumers the right to opt out of automated profiling that produces legal or similarly significant effects, such as approval for a loan, employment, or insurance.
We do not profile consumers in furtherance of decisions that produce legal or similarly significant effects.
CPA Rights
Your CPA rights are described below. Make a Privacy Request by clicking here or the link at the top of this page.
Right to Access
You have the right to confirm whether we are processing personal data about you and to access such data. You have a right to receive a copy of your personal data in a portable and readily usable format that allows you to transmit your data to another controller.
If you make a Request to Know more than twice in a 12-month period, or we determine the request is manifestly unfounded or excessive, we may require you to pay a small fee for this service.
Right to Delete
You have the right to request that we delete any personal data we have obtained about you. We will permanently delete any such personal data from our records and direct our processors to do the same. However, we may retain your personal data if it is necessary for certain purposes, including the following:
- To comply with legal obligations
- To comply with an official investigation or cooperate with law-enforcement agencies
- To establish or defend legal claims
- To complete an obligation to you that you have requested
- To respond to security incidents, fraud, harassment, and other similar activity
- To identify and repair technical errors
- To conduct internal research to develop, improve, and repair our products and services
- For internal operations that are reasonably aligned with your expectations
Any personal data retained for these purposes will not be processed for other purposes.
Right to Non-Discrimination
If you exercise your CPA consumer rights:
- We will not deny goods or services to you
- We will not charge you different prices or rates for goods or services
- We will not provide a different level or quality of goods or services to you
However, we may offer a different price, rate, level, quality, or selection of products or services if the exercise of your CPA rights affects the feasibility or the value of those products or services, or the offer is related to a voluntary loyalty or rewards program.
Right to Opt-Out
We do not sell your personal data, process it for targeted advertising, or engage in profiling in this way.
Authorized Agents. You may authorize an agent to submit a Request to Opt-Out on your behalf, including through a technology such as a web link, browser setting, or global device setting. We will comply with such requests if we are able to authenticate your identity and the agent’s authority to act on your behalf.
Right to Correct
You have the right to correct inaccuracies in your personal data, taking into account the nature of the data and our purposes for processing it.
Authenticating Your Request
Once we receive your request, we will verify the information you provided by matching the information that we have collected. If we cannot authenticate your request, we may ask for additional information from you. If you are unable to provide additional information, or we are unable to authenticate the request using commercially reasonable efforts, we may deny your request.
Right to Appeal
If we decline to take action in response to any of your privacy requests, you have the right to appeal that decision within a reasonable amount of time, but no later than 90 days from the date of our decision. To submit a request for appeal, click here and select "Appeal a Decision" in the request type drop-down.
If you believe your rights have been violated and you are not able to resolve the issue directly with us, you may file a complaint with the Colorado Attorney General’s Office.
Connecticut Privacy Notice (CTDPA)
This section provides additional information for Connecticut residents under the Connecticut Data Privacy Act (CTDPA). The terms used in this section have the same meaning as in the CTDPA. This section does not apply to information that is not considered "personal data," such as deidentified or publicly available information as defined in the CTDPA.
If you have any questions or wish to contact us regarding this privacy notice, please send an email to moc.ppasralohcs@ycavirp.
Collection and Disclosure of Personal Information
The personal data we collect is described above in Information we collect. The personal data we disclose to third parties and the categories of third parties to whom we disclose personal data is described above in How we disclose information. The length of time for which we retain personal information is described above in How long we keep your data..
Data “Selling” and Targeted Advertising
We do not receive monetary or other valuable consideration in exchange for your data and therefore do not "sell" your data as defined in CTDPA.
We do not process personal data for purposes of targeted advertising as defined in the CTDPA.
Profiling
The CTDPA gives consumers the right to opt out of automated profiling that produces legal or similarly significant effects, such as approval for a loan, employment, or insurance.
We do not profile consumers in furtherance of decisions that produce legal or similarly significant effects.
CTDPA Rights
Your CTDPA rights are described below. Make a Privacy Request by clicking here or the link at the top of this page.
Right to Access
You have the right to confirm whether we are processing personal data about you and to access such data. Where processing is carried out by automated means, you have a right to receive a copy of your personal data in a portable and readily usable format that allows you to transmit your data to another controller.
If you make a Request to Know more than twice in a 12-month period, we may require you to pay a small fee for this service.
Right to Delete
You have the right to request that we delete any personal data provided by or obtained about you. We will permanently delete any such personal data from our records and direct our processors to do the same. However, we may retain your personal data if it is necessary for certain purposes, including the following:
- To comply with legal obligations
- To comply with an official investigation or cooperate with law-enforcement agencies
- To establish or defend legal claims
- To complete an obligation to you that you have requested
- To respond to security incidents, fraud, harassment, and other similar activity
- To identify and repair technical errors
- To conduct internal research to develop, improve, and repair our products and services
- For internal operations that are reasonably aligned with your expectations
Any personal data retained for these purposes will not be processed for other purposes.
Right to Non-Discrimination
If you exercise your CTDPA consumer rights:
- We will not deny goods or services to you
- We will not charge you different prices or rates for goods or services
- We will not provide a different level or quality of goods or services to you
However, we may offer a different price, rate, level, quality, or selection of products or services if your personal data is required in order to provide those products or services and you have exercised your right to opt out, or the offer is related to a voluntary loyalty or rewards program.
Right to Opt-Out
We do not sell your personal data, process it for targeted advertising, or engage in profiling in this way.
Authorized Agents. You may authorize an agent to submit a Request to Opt-Out on your behalf, including through a technology such as a web link, browser setting, or global device setting. We will comply with such requests if we are able to authenticate your identity and the agent’s authority to act on your behalf.
Right to Correct
You have the right to correct inaccuracies in your personal data, taking into account the nature of the data and our purposes for processing it.
Authenticating Your Request
Once we receive your request, we will verify the information you provided by matching the information that we have collected. If we cannot authenticate your request, we may ask for additional information from you. If you are unable to provide additional information, or we are unable to authenticate the request using commercially reasonable efforts, we may deny your request. Authentication is not required for a Request to Opt-Out, but we may deny the request if we have a good faith, reasonable, and documented belief that the request is fraudulent.
Right to Appeal
If we decline to take action in response to any of your privacy requests, you have the right to appeal that decision within a reasonable amount of time, but no later than 90 days from the date of our decision. To submit a request for appeal, click here and select "Appeal a Decision" in the request type drop-down.
If you believe your rights have been violated and you are not able to resolve the issue directly with us, you may file a complaint with the Connecticut Attorney General’s Office.