Last Updated: 12/23/2019
1. Types of Personal Information we collect and its Sources
2. How we use your Information
3. How we share your information
4. Your Privacy Rights and Choices (including Access, Deletion and Opt-Out)
5. Use Outside of the United States
6. Our Data Security Procedures
1. TYPES OF PERSONAL INFORMATION WE COLLECT AND ITS SOURCES
A. INFORMATION YOU PROVIDE
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 firstname.lastname@example.org.
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 email@example.com 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.
B. INFORMATION COLLECTED AUTOMATICALLY
C. INFORMATION COLLECTED FROM THIRD PARTIES
We may from time-to-time collect information about you from other entities, such as social networks or other platforms you may have used. We may associate this information with your Cappex profile and other personal information we have collected about you.
2. HOW WE USE YOUR INFORMATION
We use the information we collect to provide you with products and services and to operate, maintain, and enhance the Cappex Sites. For example:
To Provide Our Services. We use the information we collect and receive to provide you with the products, services, or information that you request; to provide you with information about the Cappex Sites or required notices; to deliver marketing communications, promotional materials, or advertisements that may be of interest to you; and to customize your experience when using the Cappex Sites, among other things.
To Improve Our Services. We use the information we collect and receive to improve the Cappex Sites, for example by better tailoring content to user needs and preferences, such as by giving you more relevant scholarships or advertisements; by generating and analyzing statistics about your use of the Cappex Sites; and by developing new products and services.
To Communicate with You. We use the information we collect and receive to communicate with you about the Cappex Sites and relevant services and offers, to respond to you when you contact us, and to let you know about our policies and terms or provide other notices required by law.You may opt-out of receiving these offers at any time through your Cappex account or via the unsubscribe link contained in the email message
We also may use the information in other ways for which we provide specific notice at the time of collection.
3. HOW WE SHARE YOUR INFORMATION
We use and share the information you supply to Cappex in the following ways:
Per your Intentional Interaction with Various Third Parties. We may share all categories of your personal information with colleges, universities, scholarship providers and other parties related to the college admissions and financial aid process when you take certain steps to intentionally interact with these third parties. For example, Cappex will share your information with colleges and universities when you intentionally interact with a particular college or university in various ways, including adding the school to your list, “liking” a school or calculating your chances to get into a school. If you apply for a scholarship that is offered by a third party through the Cappex site in which case, Cappex would share your information with the third-party provider. Cappex may be compensated for inquiries that are generated as a result of this intentional interaction.
Advertisers and other Marketing Partners. In addition to sharing your information as a result of your intentional interaction with third parties, Cappex may from time-to-time share your information with advertisers and other marketing partners who are interested in marketing to your unique demographic in exchange for fees or other consideration. These third parties may share your personal information with other marketers or data aggregators. If you do not want us to sell your information as described in this paragraph, we encourage you to opt out of these sales of your information here. Also, if you are a California resident under 16 years of age, we will not sell your information as described in this paragraph unless you opt-in at the time you create a Cappex account or at the time you choose to allow us to sell your information.
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, Parents and CBOs. You can choose to allow Counselors, Community-based Organizations ("CBOs"), Parents or other trusted advisors (collectively, “Advisors”) to access your Cappex account. If you use this feature, you will either select a registered counselor or CBO or provide the relevant Advisor’s name and e-mail address so that Cappex can invite them to register on the Cappex Site, which will allow the Advisors to view your account and monitor your progress. By inviting these Advisors 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.
De-Identified Information. We may share information that is not reasonably identified with you for any purpose.
Third Party Vendors. Cappex uses third party vendors to perform operational functions related to the Cappex Sites. Some of these vendors 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.
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 RIGHTS AND 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 firstname.lastname@example.org , 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 email@example.com if you have any problems updating your information.
Right to Access Your Information. You have the right to request the following from Cappex with respect to personal information collected about you:
categories and/or specific pieces of personal information collected,
categories of sources from which the personal information is collected,
purpose for which your personal information has been collected or sold,
categories of third parties with whom Cappex shares your information;
categories of your personal information Cappex has sold;
the categories of third parties to whom Cappex has sold your personal information; and
the categories of personal information Cappex has shared for business purposes.
You may submit such a request to Cappex no more than twice in any 12 month period by sending an email containing your requests to UserDataRequest@cappex.com. Prior to fulfilling your request, we will take reasonable steps to verify your identity.
Right to Have Your Information Deleted. You may request that we delete all of your information by sending such a request to UserDataRequest@cappex.comor otherwise request that we close your account. We will take reasonable steps to verify your identity prior to fulfilling your request. Once confirmed, your account will be closed and we will discard your personally identifiable data, but we may retain certain data for internal business purposes as permitted by applicable law.
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 currently support or respond to DNT Signals as it does not track you when you leave a Cappex Site.
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.
Questions? Your privacy is important to Cappex. If you have questions about any of the provisions described above, please contact us at email@example.com.
Alternatively, you may contact us at:
Chief Privacy Officer
200 W Jackson Street, Suite 2700
Chicago, IL 60606