AGREEMENT

By visiting our website and using our services, you agree to be bound by the terms of our Privacy Policy and our Terms of Use.

INTRODUCTION

ConnectEDU, Inc. (the "Company" or "ConnectEDU" or "we") uses industry standard practices to safeguard the confidentiality of your personal information. The Company recognizes and respects the privacy interests of ConnectEDU users and is committed to protecting that privacy and keeping users informed about our privacy policy.

UPDATES AND CHANGES TO THIS POLICY

As ConnectEDU evolves, we may update this privacy policy statement to reflect changes in the manner in which we deal with personal information, whether to comply with then applicable regulations and self-regulatory standards or otherwise. The privacy policy posted here will always be current. We encourage you to review this statement regularly.

WHAT THIS PRIVACY POLICY COVERS

•The information, including the personal identifying information, that we collect
• Reasons we collect your personal identifying information
• Ways in which information, including personal identifying information, may be used and disclosed
• Security measures to prevent misuse of information entrusted to ConnectEDU
• Cookies
• Modifying and deleting your information
• Methods of enforcing this Policy

THE INFORMATION WE COLLECT

ConnectEDU collects information about you, including personally identifying information such as your name, date of birth, address, e-mail address, telephone number, grade level and such additional information as you are required to provide by the college and financial aid applications that you choose to complete. ConnectEDU also collects personal identifying information in the form of your student records, which records are made available to ConnectEDU by contracting high schools and community colleges that designate ConnectEDU as an agent or contractor to help collect and process such information for the purpose of facilitating guidance counseling relating to the college selection process. Student records collected may include student names, student identification numbers, e-mail addresses, GPA, grades, courses taken, standardized test scores, and related information on college application plans and acceptances.

When you log on to ConnectEDU, your browser will automatically transmit to the Company's server the IP address of your computer and type of browser you are using. (An IP address is a number that is automatically assigned to your computer whenever you are surfing the Web). Although your browser transmits the IP address of your computer, ConnectEDU does not associate this IP address with any personally identifiable information. We may collect aggregate and anonymized information about you and your use of our Website whenever you visit us online. For instance, we may collect various forms of "click stream" information such as entry and exit points for our website (i.e. referring URLs or domains), site traffic statistics, page views, impressions, and operating system and browser type. In addition, when users request pages on our website, our servers may automatically log their IP addresses. This aggregate information generally will not personally identify you or be correlated to you individually for external purposes.

In sum, the Company does not collect any personally identifiable information about users other than what users submit and their browsers transmit, and student records obtained from high schools and community colleges. No personal information will be released without your prior approval and only for a designated purpose, subject to the exceptions noted below under "Ways In Which Information May Be Used and Disclosed".

MANAGEMENT AND PROTECTION OF STUDENT INFORMATION

High schools and community colleges provide ConnectEDU with student information. Schools may provide student names, student identification numbers, e-mail addresses, GPA, grades, courses taken, standardized test scores, and related information on college application plans and acceptances.

ConnectEDU handles student information received from educational institutions with the utmost care and operates, on behalf of contracting schools, in compliance with federal and state school privacy laws, including The Family Educational Rights and Privacy Act of 1974 (FERPA) (20 U.S.C. § 1232g; 34 CFR Part 99). FERPA is a federal law that protects the privacy of student educational records, and applies to all schools receiving federal funding. With certain exceptions, this law prohibits schools from releasing personally identifying information of students under the age of 18 without parental consent. By designating ConnectEDU as a "school official" and/or a designated contractor to facilitate guidance counseling in connection with college selection, institutions are permitted to share data with ConnectEDU without express, parental consent under the exception provided by 34 CFR § 99.31 (a)(1).

The classification as a "school official", or as a contracted company with a "legitimate educational interest" is described by the Family Policy Compliance Office (FPCO). The FPCO FERPA policy and advisory materials on this issue can be found at http://www.ed.gov/policy/gen/guid/fpco/index.html and http://www.ed.gov/policy/gen/guid/fpco/ferpa/lea-officials.html.

REASONS WE COLLECT YOUR PERSONAL IDENTIFYING INFORMATION

ConnectEDU collects personal information from you for three reasons. The first reason is to enable the Company to respond to your questions or contact you when necessary in connection with the functioning of ConnectEDU. The second reason is to perform a task, such as filling out a college application, requested by you. Finally, as described earlier, we collect additional information about users to help us better facilitate the use of our service.

Except as may be set forth below, the personally identifiable data you submit to ConnectEDU (or that ConnectEDU obtains from your school) is not made available or distributed to third parties, except with your express consent and at your direction. In particular, unless otherwise specified below, the Company will not give, sell or provide access to your personal information to any company, individual or organization for its use in marketing or commercial solicitation or for any other purpose, except as is necessary for the operation of this site.

WAYS IN WHICH YOUR INFORMATION MAY BE USED AND DISCLOSED

Except as set forth below, the personally identifiable data you submit to ConnectEDU is not made available or distributed to third parties, except with your express consent and at your direction. In particular, the Company will not give, sell or provide access to your personal information to any company, individual or organization for its use in marketing or commercial solicitation or for any other purpose, except as is necessary for the operation of this site.

WAYS IN WHICH PERSONAL IDENTIFYING INFORMATION MAY BE USED

  1. Forms and Surveys. ConnectEDU will use your personal identifying information to automatically fill out the forms and surveys noted below upon your instructions to do so. Unless expressly instructed or authorized by you, these forms and surveys are not disclosed to third parties:
    • Applications for admission
    • Financial aid applications
    • Freshman and transfer planners, which can assist you in selecting courses and otherwise planning to meet admission requirements
    • Requests for information or material from colleges or other institutions you specify
  2. Internal Analysis. We may use your information, including your personally identifying information to help diagnose problems with ConnectEDU's servers and to administer the ConnectEDU website. We may aggregate your information with the information of other users for our own internal statistical, design, operational purposes such as to estimate our audience size; measure aggregate traffic patterns; and understand demographic, customer interest and other trends among our guests and customers.
  3. Use and Disclosure of Aggregated Data. As described earlier, we may collect aggregate and anonymized information about you and your use of our Website whenever you visit us online. This aggregate information generally will not personally identify you or be correlated to you individually for external purposes. We may collect, compile, store, publish, promote, report, sell, or otherwise disclose or use any and all aggregate information, provided that, such information does not personally identify you. When we share such information with other companies, or with contracting Schools, it is not traceable to any particular user, and will not be used to contact you. If we do correlate any aggregate information to you, such information will be treated like any other personal identifying information under this Policy.
  4. Compliance with the Law and Other Special Circumstances. When required by law to comply with any valid legal process such as a search warrant, subpoena, statute, regulation or court order, ConnectEDU will supply such information contained in your ConnectEDU account, based on the advice of counsel, that the Company is legally required to supply. In addition, ConnectEDU may release specific information relevant to special cases, such as a physical threat to you or others or an attempted breach of security on the ConnectEDU site.
  5. Permission-Based Support Services. From time to time, users will be offered resources and support services related to their use of the site. For example, users who select colleges for their college list often elect to receive additional information from and/or have online interaction with those colleges. Whether or not information is received by users from interested parties is permission-based. Users will affirmatively choose to receive such information and have such interactions, at their sole discretion. Users may receive reminders of these opportunities or invitations to participate in certain activities (such as an online chat) in order to maximize their college search and application process but will make individual decisions regarding participation.
  6. Company Sale. Information collected through our website is considered a trade secret of ours. As the owner of such information, we may disclose or transfer such information as an asset of the company in conjunction with the sale to a third party of our company or a portion of our assets. In the event of sale or intended sale of the Company, ConnectEDU will give users reasonable notice and an opportunity to remove personally identifiable data from the service. In any event, any purchaser of ConnectEDU's assets will abide by the terms of this Privacy Policy in the form effective as of any transfer.
  7. Legal Rights to Protect and Defend. We may disclose personal information if required to do so by law or in good faith believe that such action is necessary to protect and/or defend our rights or property.

 

SECURITY MEASURES TO PREVENT MISUSE OF INFORMATION ENTRUSTED TO ConnectEDU

ConnectEDU uses technical, administrative and physical safeguards to maintain the security of your information. ConnectEDU enables the data you input to be encrypted when in route between your browser and the Company's server and when in route between the Company's server and some other browser or server. This practice helps prevent unauthorized third parties from intercepting and gaining access to your private data during transmission over the Internet. ConnectEDU uses 128-bit, Secure Socket Layer encryption supported by all popular Web browsers.

Data residing on the ConnectEDU server is password protected, and access is provided only to those employees of ConnectEDU who require such access to administer and maintain the Company's system or to provide requested customer support to users of ConnectEDU. Each ConnectEDU employee who has access to the data residing on the ConnectEDU server has agreed in writing to respect the privacy of all such personal data.

ISSUANCE OF PASSWORDS; MUTUAL OBLIGATION TO PROTECT PRIVACY

ConnectEDU issues individual passwords to the Company's members. These passwords are the property of ConnectEDU and for security reasons must not be disclosed to any other party. Passwords identify the user as a ConnectEDU member. Members acknowledge that disclosing passwords to others will result in the termination of their rights to use the ConnectEDU service and that the misuse of passwords or misrepresentation of identity by use of another's password may compromise the Company's security, causing irreparable harm to ConnectEDU and allowing the Company to enforce its rights under the Terms of Use. If you lose control of your password, you may lose substantial control of your personally identifiable information and may be subject to legally binding actions taken on your behalf. Therefore if your password has been compromised for any reason, you should immediately contact the Company to deactivate your old password and apply for a new password. ConnectEDU will not disclose a member's password to any third-party, except as may be required by law or as otherwise described in the Terms of Use and in the "WAYS IN WHICH YOUR INFORMATION MAY BE USED AND DISCLOSED" section above. ConnectEDU shall not be responsible for any damages incurred as a result of unauthorized use of your password and hereby expressly DISCLAIMS all responsibility for any such damages.

COOKIES

A cookie is a small file that a website transfers to a user's computer, which may then be stored on its hard drive. ConnectEDU uses cookies to remember you and personalize your web-viewing experience by keeping track of your session when logged on to ConnectEDU. Cookies enable you to maintain continuity as you move from page to page on ConnectEDU and to avoid the nuisance of being asked to provide the same information repeatedly. Cookies also allow us to make sure that only your browser can exchange information regarding your account with our servers. Cookies cannot be used to steal personal information or to gain access to information that you did not directly provide. The cookies we use are set when you log on to ConnectEDU and are erased when you log off ConnectEDU or completely close your browser.

DON'T WANT COOKIES?

Most browsers are initially set to accept cookies. If you don't want cookies, you can set your browser to disable or refuse cookies or to alert you when cookies are being used. You should note, however, that functionality on the ConnectEDU services will be compromised.

MODIFYING, CORRECTING, OR DELETING YOUR INFORMATION

You may update, otherwise modify or delete from the data stored on ConnectEDU any personal information you previously provided. To modify personal information, (i) log on to ConnectEDU, (ii) access either your user profile or an application containing the information you want to change, and (iii) modify that information using standard word-processing techniques. To delete personal information, (i) log on to ConnectEDU, (ii) access your user profile, and (iii) delete the information you want to remove from ConnectEDU using standard word-processing techniques. Please recognize that if you delete information, it will no longer be available on ConnectEDU.

If you are unable to change your profile using the standard ConnectEDU service features, or wish to delete or modify your student records provided to ConnectEDU by your school, or delete your account from the ConnectEDU system, you may:
• Send e-mail to support or
• Call 1-866-553-3366 and speak to the Director of Information Security to request a correction or deletion.

ENFORCEMENT

ConnectEDU is committed to ensuring the integrity and security of user information. ConnectEDU intends to pursue all legal remedies available to it in the event that its security measures and/or this Policy is breached, including but not limited to pursuit of all criminal and civil law enforcement proceedings available as of the occurrence of any breach. Should you believe that your data has been released or used in a way that is contrary to your rights or this Policy you should contact either the helpdesk at support, or call 1-866-553-3366 and ask to speak to the Director of Information Security.

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