Last Updated: 10/1/2019
1. GENERAL STATEMENT
In general, we may share your personal information with a variety of third parties, including colleges, universities, scholarship administrators, marketing partners, advertisers and counselors. However, we only share your personal information with these parties if you have either given your permission or taken an action on a Cappex Site to indicate an interest in a particular college or university (for example, adding the school to your "list," calculating your chances of admission to a particular school, etc.). We also share your personal information with vendors (for example, our web hosting provider) as needed to assist Cappex with business operations, but they are contractually required to keep your information confidential.
We may also use information about how you interact with the Cappex Site and the schools in which you show an interest to generate aggregate data analytics that may be shared with our college and university partners. We take steps to ensure that this data is always anonymous and not identifiable in any way.
- Types of Personal Information we collect
- How we use and share the Personal Information we collect
- Your Privacy Choices
- Use Outside of the United States
- Our Data Security Procedures
- California Online Privacy Protection Act Disclosures
- Nevada Privacy Rights
2. TYPES OF PERSONAL INFORMATION WE COLLECT
Student Account Creation / Registration - When you create an account on a Cappex Site, you are asked to provide certain information, such as name, address, phone number, e-mail address, password, date of birth and other academic and demographic variables relevant to the college selection/admission process. You may update this information at any time after your initial registration. If you are searching for scholarships, you may be asked to provide additional information that will help match you as a candidate for particular scholarships, including financial information, community involvement or disabilities.
Counselor Accounts - Counselors and certain student supporters ("Counselors") have the ability to create accounts on Cappex Sites. If you create a Counselor account, we will collect your business contact information and it may be viewable by students, colleges and universities that use Cappex Sites. You always have the ability to update your counselor information and can have your account removed by contacting us at email@example.com .
Cappex Admissions Advising Users – We may collect personal information from users who subscribe to the Cappex Admissions Advising Service (the “Advising Service”) when such information is shared via online chat and other interactive tools on the Cappex Sites. Personal information collected through the Advising Service may be retained and used by our college advisors and other operational vendors to enable us to provide the Advising Service, but this information will not be added to your Cappex user profile and will not be shared with colleges, universities and sponsors as described in section 3 without your consent.
Collection of Information from Children - Cappex Sites are intended for general audiences and are not directed to children under the age of 13. Cappex follows federal law and Federal Trade Commission guidelines regarding youth privacy and will not knowingly collect any personal information from children under the age of 13. If you are aware that a child under the age of 13 has created an account or provided us with personally identifiable information, please email us at firstname.lastname@example.org to have the account deleted.
Referrals - You may have received an invitation to register for a Cappex Site because we received your information from a third party that believes you would benefit from using a Cappex Site. If you decline the invitation, we do not retain the information we received from that party. Similarly, Cappex registrants can choose to let others know about Cappex through our referral feature by entering in a person's name and email address. If we received your email address through this channel, you may receive an invitation to register for a Cappex Site.
3. HOW WE USE AND SHARE THE INFORMATION WE COLLECT
We use and share the information you supply to Cappex in the following ways:
Colleges, Universities and Sponsors - We use your profile information to match your background to the preferences of colleges and universities and other variables so we can recommend colleges and universities based on "fit." Additionally, colleges and universities who work with Cappex may target certain types of students based on non-personally identifiable criteria such as GPA or general geographic regions. If you meet the school's targeting criteria, or based on other information in your profile, we may ask you whether your profile information may be sent to colleges, universities and/or other sponsors. With your permission, we will release your profile information to such college, university or other sponsor so that they may directly contact you. Cappex will also share your information with colleges and universities when you take certain action or interact with certain functionalities on a Cappex Site indicating an interest in a school. For example, if you add a college to your list, your profile may be shared with that college. Similarly, if you use the What Are My Chances® function to calculate your chances of getting in to a school, your profile may be shared with that school. Colleges and universities may be notified when you begin an application with the applicable school using the Application Service. If you do not complete the Application within the defined application period, the incomplete application data may be provided to the school so that it may close out its records. Cappex may be compensated for information that is shared with colleges, universities and sponsors.
Scholarships - Cappex Sites offer opportunities to apply for scholarships and each may require you to provide additional information about yourself. If you are a match for an external scholarship, Cappex will provide you with information you need to apply for the scholarship and you will then work with that organization to apply. If you participate in a Cappex-sponsored scholarship offer, Cappex will share your personally identifiable information with a third party scholarship administrator who may contact you to verify your profile information, including obtaining copies of any required documentation Cappex or the scholarship administrator requires to award the scholarship and disburse funds to your college or university.
Surveys and Contests - Cappex Sites may invite you to participate in surveys, contests and other promotions relevant to your college search process. If you participate, your personally identifiable information may be shared with third party marketing partners to process entries and send you promotional material. Please consult the official rules of any contest or sweepstakes you enter on a Cappex Site as specific data collection, usage, and information sharing practices may vary by contest and sweepstakes. Survey information will be used to monitor or improve the Cappex Sites, but we will not share individual responses to a survey without your consent.
Inviting Counselors and CBOs - You can choose to allow Counselors, Community-based Organizations ("CBOs") or other trusted advisors to access your Cappex account. If you use this feature, you will either select a registered counselor or CBO or provide your counselor's name and e-mail address so that Cappex can invite them to register on the Cappex Site, both of which will allow the counselor or CBO to view your account and monitor your progress. By inviting these individuals to monitor your progress, you are granting permission to Cappex to share all information in your profile with them. For College Greenlight users who grant such access to CBOs, various CBO employees and agents (e.g., CBO counselors and other CBO administrators) will have the ability to do everything with your account that you could do, including make changes to your profile and take actions that result in Cappex sharing your information with third parties. As part of College Greenlight's mission to serve traditionally underrepresented student populations, we do this so that CBOs can fully assist their students in finding the right college fit and scholarships to fund your education.
Site Customization - Cappex uses your information in order to customize our Cappex Site(s) to your interests and customize the advertisements you see based on your interests and preferences. Cappex uses various methods to recognize you, including cookies and requesting your e-mail address and password before accessing our site.
Aggregate, Non-Personally Identifiable Information - We may use anonymous information about how you use Cappex Sites (e.g., the schools in which you are interested in, schools to which you apply, etc.) to improve the functionality of Cappex Sites and improve Cappex's service offerings, including using this data at an aggregate level to create data analytics offerings to analyze trends. Cappex may share this aggregate level data and other non-personally identifiable information with our business partners and university and college users and may be compensated for the same. Cappex attempts to use industry-standard methods to ensure that the data remains anonymous and that individual students cannot be identified through any of this aggregate data.
Third Party Vendors - Cappex uses third party vendors to perform operational functions related to the Cappex Sites. Some of these vendors (e.g., the Application Service, email vendors or hosting providers) may have access to your personally identifiable information, but only as necessary to provide services to Cappex. Cappex has agreements in place with these vendors requiring them to keep your information confidential and use reasonable data security measures to protect it.
Web Analytics Services - Cappex Sites may use third party analytics services, such as Lucky Orange Web Analytics Service, to help improve usability and the customer experience. These services may record mouse clicks, page views, mouse movements and scrolling activity and are used by Cappex to analyze trends and administer the Cappex Sites. In the case of the Lucky Orange service, you can disable it here; however, doing so may disable features of the Lucky Orange system that the Cappex Sites employ such as 1:1 support chat.
Disclosure to Law Enforcement and Similar Disclosures - Cappex will release your personal information if required by law, for example, if we receive a subpoena or otherwise believe in good faith that the law requires us to release your information.
Sale or Merger - If Cappex sells any part of its business, Cappex may transfer your information to its successor, regardless of your opt-out status.
4. YOUR PRIVACY CHOICES
Modifying Privacy Choices and Opt-outs - You may deactivate your account or opt-out of receiving certain types of communications by clicking here, which will take you to the "Manage your Account" page of the Cappex Site. If you deactivate your account, we will retain your information in our active database, but will not use it to contact you or share with colleges or other third parties. Cappex will communicate with you only according to your listed preferences. In order to opt-out of third party communications, you will need to contact the applicable third party. If you have any questions relating to opting-out, please contact us at email@example.com , and we will do our best to answer your questions.
Updating Your Information - You can update your personal information by clicking here, by clicking on the "Update Profile" link on a Cappex Site, or by following the instructions included in any e-mail message you receive from Cappex. Contact us at firstname.lastname@example.org if you have any problems updating your information.
Closing your Account - You may close your account on a Cappex Site by sending an email to email@example.com and we will remove your personal information from our active database. Once your account is closed, we will discard your personally identifiable data, but we may retain certain data for internal business purposes, such as analysis of non-personally identifiable data or as may be required by applicable law.
5. USE OUTSIDE OF THE UNITED STATES
Cappex Sites are operated in the United States. If you are located outside of the United States, any information you provide to us will be transferred to the United States. By using the Cappex Sites or by providing us with your information, you consent to this transfer.
6. OUR DATA SECURITY PROCEDURES
Cappex has reasonable security measures in place to keep the information you provide to us safe from unauthorized access. However, no method of information transfer over the Internet is 100% secure and we cannot guarantee the security of your information during its transmission or storage in our systems. We will assume that anyone who has the required login/password information for your account is you, so please keep this information confidential. Vendors and contractors who perform operational services for Cappex Sites and have access to your personally identifiable information are required to keep the information confidential.
If you have any questions about security issues, please e-mail us at firstname.lastname@example.org , and we will try to answer your questions.
7. CALIFORNIA ONLINE PRIVACY PROTECTION ACT ("CALOPPA") DISCLOSURES REQUIRED BY 2013 AMENDMENT
Do Not Track ("DNT") Signals - Web browsers offer you an option to send "Do Not Track" signals to web sites you visit. Cappex Sites may use third-party ad servers, retargeting services and web analytics systems, such as Google, to provide advertising on our sites, analyze aggregate web usage statistics and provide us the ability to display advertisements to you when you have left our site. Cappex does not respond to DNT Signals as it does not track you when you leave a Cappex Site. Cappex's third party service providers, who provide ad serving, retargeting services and web analytics services to Cappex, may not respond to DNT signals. If a user comes to a Cappex Site directly with a DNT signal enabled on such user's browser, Cappex does not look for the DNT signal or respond to it.
8. NEVADA PRIVACY RIGHTS
Pursuant to Nevada law, consumers in Nevada have the right to opt-out of the sale of certain covered personal information, as those terms are defined under applicable Nevada law. For purposes of these Nevada rights, Cappex does not currently sell your personal information; however, if you are a Nevada resident and would like to opt-out of any future sale of the covered personal information we have collected about you through the Cappex Sites, please submit your request to email@example.com. Your request must include “Nevada Opt-Out” in the subject line and the email should include your full name, street address, city, state and zip code. Please contact us from the email address you have used to interact with us, or else provide us with that email address in your Nevada Opt-Out request email. We may contact you via the email address you use to contact us as needed regarding this request. We are not responsible for requests that do not come through the designated request mechanism or do not contain sufficient information to allow us to process your request. You may also be required to take reasonable steps as we determine from time to time in order to verify your identity and/or the authenticity of the request. We will respond to your request within sixty (60) days either confirming that your request has been processed or indicating that we need an additional thirty (30) days to complete the request.
Your privacy is important to Cappex. If you have questions about any of the provisions described above, please contact us at firstname.lastname@example.org .
Alternatively, you may contact us at:
Chief Privacy Officer
200 W Jackson Street, Suite 2700
Chicago, IL 60606