Last revised: September 15, 2019
Table of Contents
- 2. INFORMATION WE COLLECT
- 3. HOW WE COLLECT INFORMATION
- 4. HOW WE USE AND SHARE INFORMATION
- 5. SECURITY
- 6. Blogs, Forums, TESTIMONIALS
- 7. OTHER WEBSITES
- 8. COMPLIANCE WITH LAWS AND LAW ENFORCEMENT
- 9. OTHER TRANSFERS
- 10. HOW LONG WE RETAIN YOUR DATA
- 11. CHILDREN’S PRIVACY
- 12. CONTACT US
- 13. ADDITIONAL CALIFORNIA CONSUMER RIGHTS
- 14. ADDITIONAL NEVADA CONSUMER RIGHTS
2. INFORMATION WE COLLECT
a. Personal Information
We collect information that personally identifies, relates to, describes, or is capable of being associated with you (“Personal Information”), including:
- Personal Identifiers (e.g., name, date of birth, email address, mailing address, IP address, login username & password, links to social media profiles)
- Personal Characteristics of Protected Classifications (e.g., gender, ethnicity, citizenship, military affiliation)
- Education Information (e.g., high school name, college name, grade point average, career goals, field of study, grade level, major, essays, transcripts, recommendation letters)
- Commercial Information (e.g., payment method, subscription history, transaction history)
- Internet or Other Electronic Network Activity (e.g., device information such as operating system and browser type, email system data such as inbox and outbox content, affiliate marketing data such as transaction ID and offer ID, device type, other technical information regarding your use of our Site/Services that can be associated with you)
- Professional or Employment-Related Information (e.g., occupation)
- Audio & Visual Data (e.g., photos, videos)
- Geolocation Data
- Inferences drawn from the above categories of Personal Information that relate to your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
The types of Personal Information we collect about you may vary based on how you use the Site and/or Services.
b. Usage Data
We automatically collect information in connection with the actions you take on the Site and in connection with using the Services (“Usage Data”). For example, each time you use the Site, we automatically collect your IP address, location, hardware settings, browser type and settings, time and duration of your connection, and other device information. We use this information to improve the performance and functionality of our Site and Services, and to better understand how individuals interact with our Site and Services. If this information is capable of being associated with you, directly or indirectly, we treat it as Personal Information. If this information is not capable of being individually associated with you, we treat it as Usage Data.
c. Communication Recording
We and/or our Service Providers (as defined below), may record calls and retain the content of chat conversations or other written/electronic communications between you and us and/or our Service Provider. By communicating with us and/or our Service Provider, you consent to such recording and retention of communications.
3. HOW WE COLLECT INFORMATION
a. Voluntary Disclosure
We may ask you to provide us with Personal Information when you register with the Site/Services, purchase a service, complete a scholarship application, claim a scholarship, leave a testimonial, communicate with us (online or offline), and at other times. You are not required to provide us your Personal Information; however, if you choose not to provide the requested information, you may not be able to use some or all of the features of the Site or Services or we may not be able to fulfill your requested interaction.
b. Third-Party Data Sources
We collect Personal Information from third-party data sources such as market research firms, scholarship sponsors or providers, tutoring and essay services, college placement and employment assistance services, social media, and data brokerage companies. This Personal Information may be appended to Personal Information we have already collected from or about you.
We use the following types of cookies:
- Session Cookies: Session cookies keep track of you or your information as you move from page to page within the Site/Services and are typically deleted once you close your browser.
- Persistent Cookies: Persistent cookies reside on your system and allow us to customize your experience if you leave and later return to the Site/Services. For example, persistent cookies may allow us to remember your preferences.
- Strictly Necessary Cookies: Strictly necessary cookies are, as their name suggests, necessary for the operation of the Site and/or Services. These are cookies that facilitate our compliance with laws, allow us to verify your identity before you access restricted areas of the Site/Services, manage our network, or keep track of user input.
- Advertising Cookies: Advertising cookies are used to learn more about you and advertise our or another person’s products/services that might interest you.
d. Information from Advertisements and Affiliate Marketers
If you arrive at the Site via an advertisement (e.g., banner ad) or an affiliate marketer, we may collect information regarding the advertisement or affiliate marketer with which you interacted and your interactions (e.g., item clicked, date, time, offer ID, affiliate ID).
e. Tracking Pixels and Clear GIFs
We employ software technology that enables us to track certain aspects of a user's visit to the Site. This technology helps us better manage content on the Site by informing us what content is effective, how consumers engage with the Site, and how consumers arrive at and/or depart from the Site. The software typically uses two methods to track user activity: (1) "tracking pixels" and (2) "clear gifs." Tracking pixels are pieces of executable code that are embedded in a web page that track usage activity including which pages are viewed, when they are viewed, and how long the pages are viewed. Clear gifs are tiny graphics with unique identifiers which are embedded in web pages and email messages that track whether or not a user has viewed a particular web page or email message. User activity information may be associated with additional information about a user's session, such as IP addresses and the type of browser used, and Personal Information, if provided by the user.
f. Social Media Widgets
The Site may include social media features, such as the Facebook and Twitter widgets. These features may collect information about your IP address and the pages you visit on our Site as well as other Personal Information. A cookie may be set to ensure that a feature properly functions. Your interactions with social media features are governed by the privacy policies of the companies that provide them.
4. HOW WE USE AND SHARE INFORMATION
We use Personal Information for internal purposes, such as to
- Provide you with the Site and Services;
- Process or complete transactions you requested;
- Improve the Site and Services, including customization and personalization;
- Market and remarket our products and services and the products and services of select third parties to you;
- Communicate with you about the Site and Services;
- Develop new products and services and enhance existing products and services; and
- Compile information and analyses to enhance the customer experience and improve our business.
If you provide a testimonial, we may post it publicly on the Site or in other advertising material. By providing a testimonial, you give us permission to use it in any manner and for any purpose, including in marketing and advertising communications.
c. Service Providers
From time to time, we may establish a relationship with other businesses that we believe are trustworthy and that we believe have privacy practices consistent with ours that may include corporate affiliates (“Service Providers”). We contract with Service Providers to provide certain services to us, including:
- Online hosting and maintenance;
- Mobile and online application development, operation, and maintenance;
- Marketing and advertising design, distribution, tracking, and analysis;
- Payment processing;
- Management of access to services;
- Customer service & support;
- Information provision and notifications;
- Data storage and management;
- Analysis of the Site and Services for performance, business, technical, and user experience optimization; and
- Identity and contact information validation.
We only provide our Service Providers with the information necessary for them to perform these services on our behalf. Each Service Provider is expected to use reasonable security measures appropriate to the nature of the information involved to protect your Personal Information from unauthorized access, use, or disclosure. Service Providers are prohibited from using Personal Information other than as specified by us. We share the following types of Personal Information with one or more Service Providers: personal identifiers; personal characteristics of protected classifications; education information; commercial information; internet or other electronic network activity; professional or employment-related information; audio & visual data; geolocation data; and inferences drawn from the above categories of Personal Information that relate to your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
d. Third-Party Transfers
We share and/or sell your Personal Information to third-party companies who may market products or services likely to be of interest to you or who provide services that you request. For example, we may share your Personal Information with scholarship providers who may be able to provide you with a scholarship opportunity or to whom you wish to apply for a scholarship. We may also sell your Personal Information to college & scholarship information providers, education finance providers, advertising and marketing companies, student support organizations, market research firms, providers of products or services, and education providers. We share/sell the following types of Personal Information with one or more third-party companies: personal identifiers; personal characteristics of protected classifications; and education information.
If you would like to opt-out of having your Personal Information shared with third-party companies for their marketing purposes, please let us know by sending us an email at firstname.lastname@example.org with the subject line “Sharing Opt Out” or by mail to the address in the Contact Us section below. Include in your request at least your name, email address, phone number, and a clear statement of your desire to opt-out. We may contact you to verify or obtain additional information to process your request. Please allow up to ten (10) business days to process your opt-out request.
e. Mail & Email Marketing
We may use your Personal Information to market products or services likely to be of interest to you, or to provide you with special offers and opportunities, via mail & email. With respect to commercial email communications from us, you may opt out of these emails via a link in the footer of all commercial email messages. You may also opt out of mail and email marketing communications by emailing us at email@example.com.
6. Blogs, Forums, TESTIMONIALS
Our Site and/or Services may contain features such as blogs, forums, message boards, testimonial opportunities, or other public-facing message systems. If you use one of these features, your comments, including any Personal Information you share, will be viewable to other users and the public. You use such features at your own risk. We are not responsible for the Personal Information you share using such features or any consequences that result therefrom. We reserve the right, but are under no obligation, to remove any comments from such features that we believe, in our sole discretion, constitute defamation, libel, slander, obscenity, pornography, profanity, hate speech, discrimination, or otherwise offend other users or our brand.
7. OTHER WEBSITES
Please be aware that third-party websites and social media platforms accessible through the Site and/or Services have their own privacy and data collection policies and practices. We are not responsible for any actions, content of websites, or privacy policies of such third parties. You should check the applicable privacy policies of those third parties before providing information to them.
8. COMPLIANCE WITH LAWS AND LAW ENFORCEMENT
9. OTHER TRANSFERS
We may share Personal Information and Usage Data with businesses controlling, controlled by, or under common control with us. If we are merged, acquired, or sold, or in the event of a transfer of some or all of our assets, we may disclose or transfer Personal Information and Usage Data in connection with such transaction. You will have the opportunity to opt-out of any such transfer if, in our reasonable judgment, the new entity plans to handle your information in a way that differs materially from this policy.
10. HOW LONG WE RETAIN YOUR DATA
We retain your Personal Information for as long as we have a relationship with you. We also retain your Personal Information for a period of time after our relationship with you has ended where there is an ongoing business need to retain it. This includes retention to comply with our legal, regulatory, tax, and/or accounting obligations. Generally, we retain Personal Information for approximately seven (7) years after our relationship with you has ended, but the term for which we retain your Personal Information may be longer or shorter. We do so in accordance with our data retention policies and applicable law.
11. CHILDREN’S PRIVACY
The Site is not intended for children under the age of 16 and we do not knowingly collect Personal Information from children under the age of 16. If we become aware that we have inadvertently received Personal Information from a child under the age of 16, we will delete such information from our records.
12. CONTACT US
Apply Me, Inc. Attn: Privacy Dept. 427 N. Tatnall St. #91572 Wilmington, Delaware 19801-2230
13. ADDITIONAL CALIFORNIA CONSUMER RIGHTS
If you are a resident of California, you have additional rights to access and control your Personal Information.
a. California “Do Not Track” Disclosure
Do Not Track is a web browser privacy preference that causes the web browser to broadcast a signal to websites requesting that a user’s activity not be tracked. At this time, our Site and Services do not respond to “do not track” signals.
b. California Site Ownership Disclosure
Under California Civil Code Section 1789.3, California residents are entitled to the following information: The provider of the Site is Apply Me, Inc., 427 N. Tatnall St. #91572, Wilmington, Delaware 19801-2230. To file a complaint regarding the Site or to receive further information about the Site, please contact us. You may also contact the Complaint Assistance Unit of the Division of Consumer Services of the Department of Consumer Affairs in writing at 1625 North Market Blvd., Suite N 112, Sacramento, California 95834 or by telephone at (800) 952-5210.
14. ADDITIONAL NEVADA CONSUMER RIGHTS
If you are a resident of Nevada, you have the right to direct us not to sell your Personal Information to third parties. You may exercise these rights by sending an email to firstname.lastname@example.org with the subject line “Nevada Opt Out.” Although Nevada law gives us 60 days to respond to your request, plus an additional 30 days in certain instances, we will strive to respond to your request as soon as reasonably possible. We may request additional information in order to verify your identity or locate your Personal Information.