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Last updated September 18th, 2013
The information collection, use, and dissemination practices of US College Assistance. This policy applies to US College Assistance’s collection, use, storage and disclosure of information by US College Assistance on its (a) websites, including all its divisions, subsidiaries and related companies (collectively, the “Websites”), (b) on various third party websites, and (c) to US College Assistance’s other information collection, including the purchase of customer lists from third parties. US College Assistance is not responsible for the information collection or privacy practices of third web sites or applications.
1. Collection of Information.
1.1 Survey Information.
US College Assistance collects information from individuals by various methods, including, but not limited to, when an individual voluntarily completes a US College Assistance survey, order form, or a registration page either online or offline, or by means of online or offline surveys, order forms, or registration pages operated by third parties (collectively, a “Survey”). (As used herein, “online” means using the Internet, including the Websites, and related technologies, and “offline” means by methods other than online, including in person, in the postal mail, using telephones and cell phones, and other similar means.) In the Surveys, US College Assistance or a third party (a “Third Party”) may ask an individual to provide various information to US College Assistance, which may include his or her name, email address, street address, zip code, telephone numbers (including cell phone numbers and carriers), birth date, gender, salary range, education and marital status, occupation, social security number, employment information, personal and online interests, and such other information as may be requested from time to time (together, “Survey Information”). US College Assistance may also collect information concerning an individual from another source and uses that information in combination with information provided from this web site. Completing the Surveys is completely voluntary, and individuals are under no obligation to provide Survey Information to US College Assistance or Third Party, but an individual may receive incentives from US College Assistance or a Third Party in exchange for providing Survey Information to US College Assistance.
1.2 Third Party List Information.
US College Assistance collects information from individuals when an individual provides information to a third party and US College Assistance subsequently purchases, licenses, or otherwise acquires the information from the third party (the “Seller”). Such purchased information may include, but is not limited to, an individual’s name, email address, street address, zip code, telephone numbers (including cell phone numbers and carriers), birth date, gender, salary range, education and marital status, occupation, industry of employment, personal and online interests, and such other information as the individual may have provided to the Seller (together, “Third Party List Information”). When acquiring Third Party List Information, US College Assistance seeks assurances from the Seller that the Seller has a right to transfer the Third Party List Information to US College Assistance and that the Seller has a right to provide offers from advertisers to the individuals whose personal information is included on the Seller’s list.
1.3 Other Information.
Other occasions when US College Assistance obtains information from individuals include (1) when an individual is making a claim for a prize or seeking to redeem an incentive offered by US College Assistance or by a third party, (2) when an individual requests assistance through US College Assistance’s customer service department, and (3) when an individual voluntarily subscribes to a US College Assistance service or newsletter (together, “Other Information”).
1.4 Cookies, Web Beacons, and Other Info Collected Using Technology.
US College Assistance currently uses cookie and web beacon technology to associate certain Internet-related information about an individual with information about the individual in our database. Additionally, US College Assistance may use other new and evolving sources of information in the future (together, “Technology Information”).
A cookie is a small amount of data stored on the hard drive of the individual’s computer that allows US College Assistance to identify the individual with his or her corresponding data that resides in US College Assistance’s database. You may read more about cookies at http://cookiecentral.com. Individuals who use the Websites need to accept cookies in order to use all of the features and functionality of the Websites.
(b) Web Beacons.
A web beacon is programming code that can be used to display an image on a web page, but can also be used to transfer an individual’s unique user identification (often in the form of a cookie) to a database and associate the individual with previously acquired information about an individual in a database. This allows US College Assistance to track certain web sites an individual visits online. Web beacons are used to determine products or services an individual may be interested in, and to track online behavioral habits for marketing purposes. For example, US College Assistance might place, with the consent of a third party website, a web beacon on the third party’s website where fishing products are sold. When Joe, an individual listed in US College Assistance’s database, visits the fishing website, US College Assistance receives notice by means of the web beacon that Joe visited the fishing site, and US College Assistance would then update Joe’s profile with the information that Joe is interested in fishing. US College Assistance may thereafter present offers of fishing related products and services to Joe. In addition to using web beacons on web pages, US College Assistance also uses web beacons in email messages sent to individuals listed in US College Assistance’s database.
(c) New Technology.
The use of technology on the Internet, including cookies and web beacons, is rapidly evolving, as is US College Assistance’s use of new and evolving technology. As a result, US College Assistance strongly encourages individuals to revisit this policy for any updates regarding its use of technology.
1.5 Outside Information.
US College Assistance may receive information about individuals from third parties or from other sources of information outside of US College Assistance including information located in public databases (“Outside Information”).
1.6 Individual Information.
As used herein, Individual Information means Survey Information, Third Party List Information, Other Information, Technology Information, and Outside Information, and any other information US College Assistance gathers or receives about individuals.
1.7 No Information Collected from Children.
US College Assistance will never knowingly collect any personal information about children under the age of 13. If US College Assistance obtains actual knowledge that it has collected personal information about a child under the age of 13, that information will be immediately deleted from our database. Because it does not collect such information, US College Assistance has no such information to use or to disclose to third parties. US College Assistance has designed this policy in order to comply with the< Children’s Online Privacy Protection Act (“COPPA”).
1.8 Credit Card Information.
US College Assistance may in certain cases collect credit card numbers and related information, such as the expiration date of the card (“Credit Card Information”) when an individual places an order from US College Assistance. When the Credit Card Information is submitted to , such information is encrypted and is protected with SSL encryption software. US College Assistance will use the Credit Card Information for purposes of processing and completing the purchase transaction, and the Credit Card Information will be disclosed to third parties only as necessary to complete the purchase transaction.
2. Use of Individual Information.
2.1 Discretion to Use Information.
THE COMPANY MAY USE INDIVIDUAL INFORMATION FOR ANY LEGALLY PERMISSIBLE PURPOSE IN COMPANY’S SOLE DISCRETION.
The following paragraphs in Section 2 describe how US College Assistance currently uses Individual Information, but US College Assistance may change or broaden its use at any time. As noted below, US College Assistance may update this policy from time to time. US College Assistance may use Individual Information to provide promotional offers to individuals by means of email advertising, telephone marketing, direct mail marketing, online banner advertising, and package stuffers, among other possible uses.
2.2(a) Content of Email Messages.
In certain commercial email messages sent by US College Assistance, an advertiser’s name will appear in the “From:” line but > hitting the “Reply” button will cause a reply email to be sent to US College Assistance. The “Subject:” line of US College Assistance’s email messages will usually contain a line provided from the advertiser to US College Assistance.
2.2(b) Solicited Email.
US College Assistance only sends email to individuals who have agreed on the Websites to receive email from US College Assistance or to individuals who have agreed on third party websites to receive email from third parties such as US College Assistance. US College Assistance does not send unsolicited email messages. As a result, statutes requiring certain formatting for unsolicited email are not applicable to US College Assistance’s email messages.
2.3 Targeted Advertising.
US College Assistance uses Individual Information to target advertising to an individual. When an individual is using the Internet, US College Assistance uses Technology Information (see also Section 2.5 below) to associate an individual with that person’s Individual Information, and US College Assistance attempts to show advertising for products and services in which the person has expressed an interest in the Surveys, indicated an interest by means of Technology Information, and otherwise. US College Assistance may, at its discretion, target advertising by using email, direct mail, telephones, cell phones, and other means of communication to provide promotional offers.
2.4 Direct Mail and Telemarketing.
US College Assistance uses Individual Information to advertise, directly or indirectly, to individuals using direct mail marketing or telemarketing using telephones and cell phones.
2.5 Location Data
USCollegeAssistance may use information about your location to provide our services or to customize data presented to you. Our network detects your device’s approximate location whenever it is turned on (subject to coverage limitations). We use location information to improve services and delivery of relevancy by location. However, we only locate your general location. Depending on your device, you may also be able to obtain a wide array of services based on the approximate location of your device (for example, driving directions, enhanced 411 Directory Assistance or search results). These data services, known as Location-Based Services are made available by your carrier, usually via applications that may be pre-loaded on your device or that you download from application stores. USCollegeAssistance could be requested to and may disclose your device location to the government or law enforcement if/when USCollegeAssistance is served with lawful process or reasonably believes there is an emergency involving risk of death or serious physical harm. With your consent, USCollegeAssistance may provide location-based services or provide third parties with access to your approximate location to provide services to you. You should review the specific USCollegeAssistance terms and conditions for your use of location-based services. You should also review the privacy policies and other terms of third parties with whom you have authorized sharing your location information, and consider the risks involved. USCollegeAssistance makes all attempts to follow Best Practices Guidelines for Location-Based Services.
2.6 Use of Technology Information.
US College Assistance uses Technology Information (1) to match a person’s Survey Information and Third Party List Information to other categories of Individual Information to make and improve profiles of individuals, (2) to track a person’s online browsing habits on the Internet, (3) to determine which areas of US College Assistance’s web sites are most frequently visited. This information helps US College Assistance to better understand the online habits of individuals so that US College Assistance can target advertising and promotions to them.
2.7 Profiles of Individuals.
US College Assistance uses Individual Information to make a profile of an individual. A profile can be created by combining Survey Information and Third Party List Information with other sources of Individual Information such as information obtained from public databases.
2.8 Storage of Individual Information.
US College Assistance stores the Individual Information in a database on USCollegeAssistance.computers. Our computers have security measures (such as a firewall) in place to protect against the loss, misuse, and alteration of the information under US College Assistance’s control. Not withstanding such measures, US College Assistance cannot guarantee that its security measures will prevent USCollegeAssistance.computers from being illegally accessed, and the Individual Information on them stolen or altered. 3. Dissemination of Individual Information.
3.1 Sale or Transfer to Third Parties.
US College Assistance MAY SELL OR TRANSFER INDIVIDUAL INFORMATION TO THIRD PARTIES FOR ANY PURPOSE IN US College Assistance’S SOLE DISCRETION.
3.2 Order Fulfillment.
US College Assistance will transfer Individual Information to third parties when necessary to provide a product or service that aperson orders from such third party while using US College Assistance web sites or when responding to offers provided by US College Assistance.
3.3 Legal Process.
US College Assistance may disclose Individual Information to respond to subpoenas, court orders, and other legal processes.
3.4 Summary Data.
US College Assistance may sell or transfer non-individualized information, such as summary or aggregated anonymous information about all persons or sub-groups of persons.
4. Privacy Practices of Third Parties.
4.1 Advertiser cookies and web beacons.
Advertising agencies, advertising networks, and other companies (together, “Advertisers”) who place advertisements on the Websites and on the Internet generally may use their own cookies, web beacons, and other technology to collect information about individuals. US College Assistance does not control Advertisers’ use of such technology and US College Assistance has no responsibility for the use of such technology to gather information about individuals.
The Websites and email messages sometimes contain hypertext links to the web sites of third parties. US College Assistance is not responsible for the privacy practices or the content of such other web sites. Linked web sites may contain links to web sites maintained by third parties. Such links are provided for your convenience and reference only. US College Assistance does not operate or control in any respect any information, software, products or services available on such third party web sites. The inclusion of a link to a web site does not imply any endorsement of the services or the site, its contents, or its sponsoring organization.
4.3 Affiliated Companies.
US College Assistance may disclose, transfer, and sell Individual Information to entities affiliated with US College Assistance in US College Assistance’s discretion
5. Unsubscribe Procedures.
(b) Unsubscribe from all of USCollegeAssistance.com’s email lists.
For more information about protecting your privacy, you may wish to visit: www.ftc.gov. If you have questions about this policy, please contact us at info@USCollegeAssistance.com.