COLLECTION OF INFORMATION
Information You Provide: To access or utilize the Site or the Services, you may be required to submit personally identifiable information (“PII”) to us. PII is information that identifies you as an individual and may include, but not be limited to, your full name; postal or mailing address; email address; telephone number; mobile number; wireless device address; household members’ names; children’s full names; gender; ethnicity; academic information like grade point average, class rank, and exam scores; birthdates; social security numbers; tax forms and tax information, financial information, and financial documentation; and any information required for tuition assistance; and all other information that identifies you or may be required to create an account (“Account”). PII we collect varies based on the Service being administered.
Information Collected Automatically: We may collect certain PII and non-PII (“Non-PII”) automatically when you use the Site or the Services. “Non-PII” is non-identifiable, anonymized, and/or aggregated information that cannot be used on its own to personally identify you. The information that may be collected automatically may include, but not be limited to, your User ID (defined below), the type of mobile device you use, your Device ID (defined below), the Internet Protocol (“IP”) address of your mobile device or computer, your operating system, the type and version of your Internet browsers, your Internet service provider, Log Data (defined below), real time location information, analytics information, metadata, pages of our Site that you visit, the time spent or actions taken on those pages, any search engine you may have used to locate the Site, and information about the way you use the Site.
User ID: When you register with the Service, we create a unique identification number associated with your email address (“User ID”). If you have an Account and are signed into your Account, your User name will be associated with your User ID. We use and store your User ID to enable you to interact with and use the Site and our Services and understand the use of our Services. We link your User ID with the technical information accessed through your use of the Site and the Services, which enables us to administer resets to your Account or to delete information when you request that we do so or for other administrative purposes.
Device ID’s: We may collect and store a unique device identifiers associated with your particular mobile device (“Device ID”). Device identifiers are small data files or similar data structures stored on or associated with your mobile device, which uniquely identify your mobile device. We use your Device ID to track the number of unique Users using the Site and our Services and to enable you to interact with and use the Site and our Services and to make it possible to authenticate and understand the use of our Services. We link your Device ID with the technical information accessed through your use of the Services, which enables us to administer resets to your Account or to delete information when you request that we do so or for other administrative purposes. Some features of the Service may not function properly if use or availability of Device IDs is impaired or disabled.
Log Data: We may collect information about your interaction with the Site or the Services. When you use the Site and our Services, our servers automatically record information that your browser sends, including through Web analytics tools whenever you visit a website or service connected to the Internet (“Log Data”). This Log Data may include information such as your computer’s or mobile device’s IP address, browser type, your activities within the Site, the webpage you were visiting before you came to the Site, pages of our Site that you visit, the time spent on those pages, search engine(s) and keywords you used to find our Site, your browser add-ons, and your browser's width and height, sections of the Site that you access, information you search for on our Site, access times and dates, and other statistics. We use this information to attempt to provide you with a better experience, to improve the Site, the Services, to analyze and understand how the Site and the Services are used, and for advertising and marketing purposes. We may also use technologies, such as cookies and web beacons (described below) to collect information about the pages you view, the links you click and other actions you take on the Site.
Analytics Information: We use our own and third-party analytics tools to help us measure traffic and usage trends for the Service. These tools collect information sent by your device or our Service, including the web pages you visit, add-ons, and other information that assist us in improving the Service. We collect and use this analytics information with analytics information from other Users so that it cannot reasonably be used to identify any particular individual User.
Metadata: Metadata is data providing information about one or more aspects of the data, including that associated with User Information. For example, metadata can describe how, when and by whom a piece of User Information was collected and how that content is formatted. Users of the Site can add or may have metadata added to their User Information including a hashtag (e.g., to mark keywords when a photo is posted), geotag (e.g., to mark your location to a photo), comments or other data. This metadata makes your User Information more searchable by others and more interactive.
HOW WE USE YOUR INFORMATION
We (or one of our service providers, on our behalf) may use your PII to: process your application or forms for tuition assistance with your school; confirm receipt of your application or form; to gather more information if there are questions regarding your application or form; to send you notification regarding your status; for communications necessary to administer a program or provide a service; analyze the PII you provide to determine your eligibility for tuition assistance with your school and prepare an analysis thereof; identify you when you sign-in to your Account; process and fulfill your transactions; administer your Account, the Site, the Site’s features, the Services; enable us to provide you with the Services and administer your inquiries; send you information we think you may find useful or which you have requested from us; send you marketing and other communications, including, but not limited to, information about our services; enable us to contact you, including in response to any question you make through the Site or Services; analyze the use of the Site and/or Services and the people visiting to improve our Services; protect our rights and property; develop new features and offerings for the Site and/or as part of the Services; or for other purposes that we may disclose to you when we request your information. We use Non-PII to help diagnose problems with our server, administer the Site, and compile aggregate and statistical data to help in Site design and to identify popular features. In addition, we gather certain navigational information about where you go on our Site. Any of the information we collect, including PII and Non-PII, determines which areas of the Site are most frequently visited to provide you with a better experience, allows us to personalize your experience, improve customer service, process transactions, and improve the Site and the Service and content and/or layout of our Site for you and others. We sometimes use your PII in conjunction with your Non-PII. Certain Non-PII would be considered a part of your PII if it were combined with other identifiers (for example, combining your zip code with your street address) in a way that enables you to be identified. We may combine your PII with Non-PII and aggregate it with information collected from other Users to attempt to provide you with a better experience, to improve the Services and to analyze and understand how our Site and Services are used.
If you do not want to receive commercial/promotional email, please let us know by updating your email preferences at firstname.lastname@example.org, by using the unsubscribe option available on commercial email communications.
We may share PII and non-PII we collect on the Site or through the Services with others for a variety of reasons. In addition to PII and non-PII sharing with our subsidiaries, affiliates and third-party providers who need your information in order to provide services to us or on our behalf, we also share such information in connection with the following:
Schools/Business Partners: We will use the PII to prepare an analysis concerning your eligibility for tuition assistance with your school, and we may make certain PII available to third parties that work with us to provide products and services to us or our Users and customers to assist or enable us to provide the Services, that help us with marketing campaigns, or to market products or services to you directly. We may share aggregate information that includes non-PII and Log Data with third parties for industry analysis, including analysis of how our Site and the Services are used, demographic profiling, and to deliver targeted advertising about other products and services. Any aggregate information shared in these contexts will not contain your PII. We engage third party companies and individuals to facilitate our Services (e.g., without limitation, maintenance services, database management, web analytics and improvement of our Services’ features), to provide the Services on our behalf, or to assist us in analyzing how Services are used. These third parties have access to your PII to perform these tasks on our behalf.
TRANSFERS OF INFORMATION FOR LEGAL PURPOSES
There are times when we may be required to disclose certain information to comply with a legal requirement, such as a law, regulation, court order, subpoena, or search warrant, in the course of a legal proceeding, in response to law enforcement or other governmental agency requests, or when we believe that disclosure is necessary to protect our rights. In addition, if there is a change of control in our business (whether by merger, sale, or otherwise) or a sale or transfer of its assets, your information could be sold or transferred as part of that transaction and your PII and other information, including Non-PII, potentially used by the purchaser or other recipient of said information.
You acknowledge that Simple Tuition Solutions, LLC is located in the United States of America ("U.S.") and will process and store your information in the U.S., and that as a result, U.S. governments, courts or law enforcement or regulatory agencies may be able to obtain disclosure of your information through the laws of the U.S. If you reside outside the United States, your PII and Non-PII will be transferred, processed and stored in the U.S. under U.S. privacy standards.
YOUR CALIFORNIA PRIVACY RIGHTS
As described above, from time to time, we make your PII available to third parties. If you do not want us to share your PII with other companies or organizations, you may opt-out of this information sharing by emailing Company at email@example.com or writing to us at Simple Tuition Solutions, LLC, 3909 Hartzdale Dr, Ste 907, Camp Hill, PA 17011. This notice is designed to comply with California's “Shine the Light” law, but the opt-out option is available to all of our Users.
UPDATING YOUR ACCOUNT AND CONTACT INFORMATION
You may update your Account, contact information and PII at any time by emailing us at firstname.lastname@example.org , and identifying the contact information and PII you would like updated. For more information please email us at email@example.com or write to us at Simple Tuition Solutions, LLC, 3909 Hartzdale Dr, Ste 907, Camp Hill, PA 17011.
DATA RETENTION POLICY, MANAGING YOUR INFORMATION
We will retain PII for as long as you use the Site and for a reasonable time thereafter. If you would like us to delete or modify PII that you provided via the Site, please contact us at firstname.lastname@example.org , and identify the PII you would like modified or deleted, and we will respond within a reasonable time. Please note that some or all of the PII may be required in order for the Site and the Services to function properly. You may also delete PII by deleting your Account and terminating your access to the Services; however, we may retain such information for a reasonable period of time after deletion.
CHILDREN UNDER 13
We do not knowingly allow anyone under the age of 13 to provide us with any PII. Children should always get permission from their parents before sending any information about themselves (such as, their names, email addresses, and phone numbers) over the Internet to us or to anyone else. In the event we learn that we have collected PII from a child under the age of 13 without parental consent, we will delete that information as quickly as possible. If you believe we might have any information from or about a child under the age of 13, please contact us at email us at email@example.com.
MOBILE DEVICES/THIRD PARTY FEES
In connection with your use of the Site and the Service, you are responsible for obtaining access to mobile device services and that access may involve third-party fees, including mobile carrier, text messaging, or airtime charges. You are solely responsible for those fees, including any and all fees associated with the use of the Site and the Services, delivery of the messages, emails or other materials to your mobile device. Please consult your mobile service provider's pricing plan prior to purchasing or downloading any application or registering for any such service to determine the charges for sending and receiving text messages from/to your mobile device. You may opt-out of receiving text messages or emails to your mobile device at the time by emailing us at firstname.lastname@example.org or mailing us at Simple Tuition Solutions, LLC, 3909 Hartzdale Dr, Ste 907, Camp Hill, PA 17011, and requesting that you no longer receive such text messages or emails.
LINKS AND THIRD PARTY OFFERS
The Site may, on occasion, contain links to other sites with information gathering practices different from our own. Users and other visitors of the Site should consult privacy policies for all other sites as we have no control over information submitted to or collected by such third parties.
We use industry-standard encryption technologies when transferring and receiving data such as your address. You can check whether your connection is using encryption technologies by using the functions in your browser, such as whether our page is showing has having been delivered by “https.” We have also implemented other technical, physical and administrative security measures that protect against the loss, misuse, or alteration of information that we have collected from you. Please be aware that, although we endeavor to provide reasonable security for information we process and maintain, the security of your data is a shared responsibility and no security system can prevent all potential security breaches. Accordingly, we do not warrant or guarantee the security or integrity of the information we receive or collect. Any transmission of information to us is performed at your own risk.
By using the Site or our Services, you consent to our collection, use and processing of your PII, as well as Non-PII. When you submit an application, forms, documents or information in connection with tuition assistance, register for an Account, engage in the Site, submit User Information or PII to the Site, or communicate with us, you consent to our collection of your PII (as well as Non-PII) in accordance with this Policy. Your information collected through the Site and the Services will be stored and processed within the United States.
If you have questions or suggestions, please contact us at email@example.com.
Effective Date: October 21, 2019