Privacy Notice for California Consumers

Last revised: February 15, 2023

This California Privacy Notice (the “Privacy Notice” or “Notice”) provides limited information to California residents only about how Scholarship Services, Inc. (“we,” “us,” “our”) collects Personal Information (as defined below) on our website(s) (“Site”) and through other internet-based mechanisms (e.g., email and social media), our online applications, and our services generally (collectively, “Services”), and how we use such information. For more details about our privacy practices and any privacy rights you may have, please see our Privacy Policy.

INFORMATION WE COLLECT AS A BUSINESS

We collect information that personally identifies, relates to, describes, or is capable of being associated with you (“Personal Information”), including:

• Identifiers (e.g., name, date of birth, social security number, email address, mailing address, IP address, login username & password, links to social media profiles)
• Personal Information listed in Cal. Civ Code 1798.80(e) (e.g., name, signature, address, telephone number, education level, credit/debit card number, brand, expiration date, and other information under this category to the extent such information is covered by another category)
• Protected classification characteristics under California or federal law ( e.g., gender, ethnicity, citizenship, military affiliation)
• Commercial Information (e.g., payment method, subscription history, transaction history, scholarship history, donation 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)
• Geolocation Information (city-level)
• Audio, electronic, visual, thermal, olfactory, or similar information (e.g., photos, videos)
• Professional or Employment-Related Information (e.g., occupation, job title, employer)
• Education information meaning non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)) (e.g., high school name, college name, grade point average, career goals, field of study, grade level, major, essays, transcripts, recommendation letters)
• Inferences drawn from the above categories of Personal Information that relate to your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

We also collect certain types of Personal Information that may be considered sensitive under relevant laws (“Sensitive Personal Information”) such as:

• Ethnic origin
• Citizenship
• Communications not directed to us such as mail, email, or text message content where we are not the intended recipient. This is considered Sensitive Personal Information for California residents only.
• Account username and password. This is considered Sensitive Personal Information for California residents only.

The types of Personal Information we collect about you may vary based on how you use our Site(s) and/or Services.

INFORMATION WE COLLECT AS A SERVICE PROVIDER

When acting on behalf of our clients as a service provider, we may collect, use, and disclose Personal Information for the purpose of servicing those clients. The specific categories of Personal Information collected and how that Personal Information is used or disclosed is determined by our client and will vary. The Personal Information collected, used, and disclosed on our clients’ behalf is governed by their privacy policies.

HOW WE USE PERSONAL INFORMATION

We use Personal Information for internal purposes, such as to

• Provide you with our Site(s) and Services;
• Process or complete transactions you requested;
• Improve our Site(s) 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 our Site(s) 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.

We use Sensitive Personal Information to assist in scholarship matching and to provide our Services to you as described above. We use and/or disclose it for additional purposes beyond those specified in 11 Cal. Code of Regs. § 7027(m).

PERSONAL INFORMATION SELLING OR SHARING

We may sell your Personal Information to other parties who are not our service providers (“Third Parties”). We do not share Personal Information with Third Parties for cross-context behavioral advertising or targeted advertising purposes. Any time we use the word “share” or its derivatives in this Privacy Policy, we mean sharing for cross-context behavioral advertising or targeted advertising purposes. When you provide Personal Information to us, you agree to be contacted by such Third Parties including without limitation schools or institutions in which you expressed interest. In the past twelve months we have sold and/or shared Personal Information with Third Parties are outlined below:

You have the right to direct us not to sell or share your Personal Information to Third Parties. You may submit a request by calling us at 800 494 4908, emailing us at support@scholarshipowl.com, or using our online submission form. If you submit your request via email, please include at least your name, mailing address, email address, and a description of your request.

HOW LONG WE RETAIN YOUR PERSONAL INFORMATION

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 of individuals who engage with our Site or Services for approximately seven (7) years after their last login or expiration of their ScholarshipOwl subscription (whichever is later). If an individual creates an account with us as the parent or legal guardian of a student, we will retain their Personal Information for approximately the same period of time as we retain the Personal Information of the underlying student or three (3) years, whichever is longer. If you are an individual associated with a Client using our ScholarshipOwl for Business service, we will retain your Personal Information for approximately three (3) years after the last active scholarship posted by the Client under the account expires. The exact period for which we retain your Personal Information may be longer or shorter in accordance with our data retention policies and applicable law.

COLLECTION NOTICE CHANGES

This Privacy Notice is subject to change. We encourage you to review this Privacy Notice frequently for any revisions or amendments. Changes to this Privacy Notice will be posted on our Site and will be effective immediately upon posting. You will be deemed to have been made aware of and have accepted the changes by your continued relationship with us.