CollegeInColorado Privacy Statement
Last Updated: December 18, 2015
XAP Corporation including its subsidiary Bridges Transitions Inc. (collectively, "XAP" - the company that operates CollegeInColorado.org) and the Colorado Department of Education, College In Colorado Division, (referred to hereafter as "CIC" - the sponsor of CollegeInColorado.org) have adopted the following Privacy Statement for the information collected at this website. When you use CollegeInColorado.org, both XAP and CIC have access to your information and may use your information to operate and maintain CollegeInColorado.org and in accordance with the terms of this Privacy Statement.
As CollegeInColorado.org evolves, we may update this Privacy 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 Statement posted here will always be current. We encourage you to review this Statement regularly. Please see additional information regarding amending this Statement in the Section entitled "Amending this Privacy Statement" below.
IMPORTANT NOTICE: Please see the information in the Section entitled "With whom personally identifying information and automatically collected information may be shared" for an understanding regarding the parties who may access your information.
WHAT THIS PRIVACY STATEMENT COVERS:
- Your agreement to this Privacy Statement
- Types of information collected
- Creating an account when you are under the age of 18
- Reasons we collect personally identifying information
- Ways in which personally identifying information and automatically-collected information may be used
- With whom personally identifying information and automatically-collected information may be shared
- Security measures to protect information; Disclaimer
- Modifying your information
- Retention and Storage
- Amending this Privacy Statement
YOUR AGREEMENT TO THIS PRIVACY STATEMENT
When you use CollegeInColorado.org, you signify and affirm that you have read, understand, and agree to the terms of this Statement; that you are competent and capable of understanding, agreeing to, and complying with this Statement; and that this Statement forms a legally-binding agreement between you, XAP, and CIC. You agree that this Statement is supported by reasonable and valuable consideration (which includes your use of CollegeInColorado.org), and you acknowledge your receipt of and the sufficiency of such consideration. If you do not agree with all of the provisions of this Statement, you may not use CollegeInColorado.org.
TYPES OF INFORMATION COLLECTED
This Statement covers information you expressly enter into CollegeInColorado.org and information that we automatically collect as you use CollegeInColorado.org.
THE PERSONALLY IDENTIFYING INFORMATION WE COLLECT
To use certain features of CollegeInColorado.org, we will require you to provide us with information that personally-identifies you ("Personally Identifying Information" or "PII"). If you choose not to provide us your Personally Identifying Information, you will not be able to use certain features of CollegeInColorado.org. When you do provide us your PII, you are authorizing us to use that PII in accordance with this Statement and to store your PII on our servers in the United States. The categories of PII that CollegeInColorado.org may collect from you include your name, date of birth, address, email address, phone number, grade level, Social Security number, username and password, demographic data (such as your gender, ethnicity, and zip code), parent’s or guardian’s names, parent’s or guardian’s address and phone number and other contact information, financial information (such as credit card information), user preferences, and such additional information as you choose to actively enter into CollegeInColorado.org and include in your portfolio or are required to provide by the college and/or financial aid applications that you choose to complete or other actions you choose to take through CollegeInColorado.org. Further, some Colorado schools provide students’ transcript information to us, including at least the following student PII contained on the applicable student’s transcript: Name, address, date of birth, gender, ethnicity, graduation year, email address, grade point average (GPA), Student number (from your school district), and State Student ID. If a Colorado school provides us this transcript information about you, we will automatically include that information in your account on CollegeInColorado.org.
You may apply to educational institutions located both within and outside the State of Colorado via CollegeInColorado.org. To do so, you may be required to or have the opportunity to provide financial information (such as credit card information) to pay the application processing fee to the applicable institution. If you do provide your financial information, we provide data encryption during the payment process. We only use and retain your financial information to complete payments you initiate. We do not retain your financial information after the transaction is complete. We use a third-party intermediary to manage payment processing. Our third-party processor follows Payment Card Industry ("PCI") standards and is PCI-Compliant. Our third-party payment processor is not authorized to use your financial information in any way other than to process payments you initiate and is required to keep the information confidential. We only share your financial information with our third-party payment processor, your credit card provider, and financial institutions to process payments.
When you use CollegeInColorado.org, we automatically track, collect, and store the following types of information (referred to as "Automatically-Collected Information"): 1) Date and time you access CollegeInColorado.org; 2) pages visited and features used, and the order of use; 3) type of computer or other operating device accessing CollegeInColorado.org and type of browser used to access CollegeInColorado.org; 4) referring source (meaning the website you visit prior to visiting CollegeInColorado.org); and 5) other similar information about the interaction between your browser and CollegeInColorado.org and activities in which you engage while using CollegeInColorado.org. Unless otherwise stated in this Statement, Automatically-Collected Information may be combined with your PII.
When you visit CollegeInColorado.org, we collect your Internet Protocol ("IP") address to track and aggregate Automatically-Collected Information. We also collect IP addresses of users when they log onto their account portfolios on CollegeInColorado.org in order to confirm the applicable user’s identity.
CREATING AN ACCOUNT WHEN YOU ARE UNDER THE AGE OF 18
Between Age 13 and 17
If you are between the ages of 13 and 17, by using CollegeInColorado.org, you represent and warrant that you possess legal parental or guardian consent to use CollegeInColorado.org and provide PII and Automatically-Collected Information through CollegeInColorado.org.
Under Age 13
If you are under the age of 13 and you indicate to us that you are under age 13 when you enter your birthdate into CollegeInColorado.org, you can only create an anonymous account that does not require you to enter your name or other Personally Identifying Information. When there are open fields required in order to create such an anonymous account, you may not use any of these open fields to enter Personally Identifying Information, and your account portfolio will not include your Personally Identifying Information. Further, you will be restricted from using any areas of CollegeInColorado.org that require you to enter Personally Identifying Information. You will only be able to use CollegeInColorado.org features or modules that do not require you to enter Personally Identifying Information.
REASONS WE COLLECT PERSONALLY IDENTIFYING INFORMATION
CollegeInColorado.org collects PII from you primarily for three reasons. The first reason is to perform a task on CollegeInColorado.org requested by you, such as filling out a financial aid application. The second reason is to enable you to submit, in a convenient and efficient manner, information that is likely to be needed when you complete college admission, financial aid, and other applications and forms made available through CollegeInColorado.org or undertake a scholarship search on CollegeInColorado.org. The third reason is to enable XAP to respond to your questions or contact you when necessary in connection with the functioning of CollegeInColorado.org or to provide required notices. When the effective functioning of a CollegeInColorado.org module does not require PII, none is collected, and any such module can be accessed without providing any PII.
WAYS IN WHICH PERSONALLY IDENTIFYING INFORMATION AND AUTOMATICALLY-COLLECTED INFORMATION MAY BE USED
Upon your instructions to do so, CollegeInColorado.org module will use your PII to complete the following forms and surveys, to obtain information for you, and to effect transactions on your behalf:
- Complete applications for admission
- Complete financial aid applications
- Complete financial aid calculators
- Complete a scholarship search
- Complete Your Plan of Study, which can assist you in selecting courses and otherwise planning to meet admission requirements
- Communicate your requests for information or material to colleges or other institutions you have specified
Your PII and Automatically-Collected Information may also be used for the following purposes:
- We may use your PII and Automatically-Collected Information to help diagnose problems with the CollegeInColorado.org server and to administer CollegeInColorado.org.
- We may use your PII and Automatically-Collected Information to customize and tailor your experience using CollegeInColorado.org, displaying content on CollegeInColorado.org that we think you might be interested in and according to your preferences (but we do not track your activity across multiple websites for the purpose of serving targeted advertising to you).
Summary data consisting of a compilation of de-identified and aggregate data representing CollegeInColorado.org users may be collected by XAP and/or CIC and provided to various entities including colleges and other educational institutions represented on CollegeInColorado.org. NO PII IS MADE AVAILABLE AS PART OF THESE SUMMARY REPORTS. Some examples of summary data are the number of monthly visitors to CollegeInColorado.org, the number of admission applications submitted over CollegeInColorado.org, and the CollegeInColorado.org functions utilized by students in specified age or grade ranges.
WITH WHOM PERSONALLY IDENTIFYING INFORMATION AND AUTOMATICALLY-COLLECTED INFORMATION MAY BE SHARED
Except as set forth below, PII you enter on CollegeInColorado.org is not made available or distributed to third parties, except with your express consent or at your express direction. In particular, neither XAP nor CIC will give, sell, rent, trade, transfer, otherwise provide or provide access to your PII to any company, individual, or organization for its use in marketing or commercial solicitation or for any other purpose, except with your express consent and at your direction, unless it is pursuant to one of the exceptions listed below or necessary for operation of CollegeInColorado.org.
We may share your PII as follows:
a. School Administration and Staff. Your account is meant to help you set goals and plan for the future. If you connect your account to a school or other site using CollegeInColorado.org as part of a career and education planning program, then professional staff at that school or site designated by the administration of the school or site to have access to the CollegeInColorado.org Professional Center will have access to view (i) your CollegeInColorado.org portfolio, including your PII that is part of your portfolio, (ii) email communications to and from you through CollegeInColorado.org, (iii) and all other PII and other content that you add to CollegeInColorado.org as part of your portfolio. This access is granted to these professional users so that they may assist you in a guidance capacity with your career and education planning. You have the option of not connecting your account to a school or site, though you will not be able to make full use of CollegeInColorado.org.
b. Parents and Guardians. You may request that your parent or legal guardian be given permission to view your portfolio (including all PII and other content that you add to CollegeInColorado.org as you use CollegeInColorado.org ). And if you do make this request, your parent or legal guardian will be granted access to your portfolio and may view all of your PII associated with your portfolio.
c. CIC. As the sponsor of CollegeInColorado.org, CIC may also have access to the PII associated with your CollegeInColorado.org account in order to help you set goals and plan for the future and to otherwise operate CollegeInColorado.org.
d. Bridges Transitions Inc. XAP Corporation and Bridges Transitions Inc. reserve the right to share PII with one another (regardless of which entity first collected the information) in connection with the maintenance and operation of CollegeinColorado.org and for use in accordance with this Statement.
e. As Directed by You. Any time you request that we perform a task that involves a transfer of PII, the PII related to the performance of that task will be made available to a recipient you designate. For example:
- If you submit an application for admission to a college or other educational institution, the PII required to complete that application and any other PII you entered onto the application will be provided on your behalf to the admissions office of the institution to which you are applying.
- If you request that a college or other educational institution send you material, your contact information will be provided to that institution so the institution can send you material and contact you.
Note: If you begin an application for admission to a college or other educational institution, your name and other PII entered on that application may be provided to the admissions office of that institution, even though you have not yet submitted a completed application to that institution. The institution may then contact you regarding your potential attendance.
f. Replacement Vendor. In the event that CIC decides to internally operate or hires a new party (other than XAP) to operate a site similar to CollegeInColorado.org or that otherwise replaces CollegeInColorado.org, you acknowledge and agree that CIC will have access to and may obtain a copy of all PII contained in XAP’s databases, and you acknowledge and agree that this includes PII that you provided from the date you first opened your account on CollegeInColorado.org. All such PII will be used by CIC in connection with such replacement site and may be given to a new third-party hired by CIC to operate such replacement site. Unless you expressly consent otherwise, all such PII will continue to be treated in accordance with the terms of this Statement. You also acknowledge and agree that in the event that CIC decides to internally operate or hires a new party (other than XAP) to operate a site similar to CollegeInColorado.org or that otherwise replaces CollegeInColorado.org, XAP will retain your PII in its databases as well. CollegeInColorado.org allows you to use PII that you entered through your CollegeInColorado.org account on other similar XAP-operated systems. Therefore, you will still be able to use your account for other XAP systems, and XAP will retain your PII to allow you to do so. Unless you expressly consent otherwise, XAP will continue to treat your PII in accordance with the provisions of this Statement.
g. Required by Law. When required by law to comply with any valid legal process such as a statute, regulation, search warrant, subpoena, or court order, XAP and/or CIC may supply PII contained in your CollegeInColorado.org account as XAP and/or CIC reasonably determines, based on the advice of counsel, it is legally required to supply. XAP and/or CIC may also disclose PII in emergency situations, to protect your safety or the safety of others, to defend against legal claims, to enforce XAP’s and/or CIC’s contractual or other rights, or to take actions regarding illegal activities or suspected fraud.
h. Merger, Acquisition, or Sale of XAP. XAP may transfer your PII and Automatically-Collected Information to another entity if XAP is involved in a merger, acquisition, reorganization, restructuring, or other sale or transfer of all or any portion of its assets or business. In this event, we will, if allowed, use reasonable efforts to notify you when your information is transferred to a third party (this notification may be made via email to you or by posting a prominent notice on CollegeInColorado.org and other similar XAP-operated systems). Unless you consent otherwise, XAP will contractually require any successor to treat your PII in accordance with the promises made in this Statement, even after the transfer. But any information you provide after the transfer will likely be subject to a new privacy statement, and you should review that statement.
i. Third-Party Payment Processor. We use a third-party intermediary to manage payment processing when you submit payment to apply to an educational institution through CollegeinColorado.org. This intermediary is not permitted to store, retain, or use your financial information or other PII, except for the sole purpose of processing payments you initiate. For more information regarding third parties who will have access to your financial information, see the subsection above entitled "The Personally Identifying Information We Collect."
j. Third-Party Service Providers. We may share Automatically-Collected Information with our third-party service providers who assist us by performing services related to our operation of CollegeInColorado.org (such as hosting, data storage, and security). Such third-party service providers are not authorized to use your information in any way other than as described here and are required to keep the information confidential.
k. Third-Party Analytics Services. We may use third-party analytics services to assist us in better understanding our CollegeInColorado.org users. For example, we use these services to track and analyze certain Automatically-Collected Information, such as feature usage. We only ever provide these service providers with (or allow these service provides to collect on our behalf) Automatically-Collected Information. We use the information collected from these service provides to make CollegeInColorado.org better and easier to use. The information we receive from these third parties may be re-associated with your PII after we receive it back from these third parties. These third parties are not authorized to use the information in any other way and are required to keep it the information confidential.
SECURITY MEASURES TO PROTECT INFORMATION; DISCLAIMER
XAP and CIC use industry standard physical, electronic, and procedural security measures to protect against the loss, misuse, and unauthorized access, disclosure, alteration, and destruction of PII and Automatically-Collected Information we collect and store. For example, CollegeInColorado.org causes the PII you input to be encrypted when in route between your browser and the CollegeInColorado.org server and when in route between the CollegeInColorado.org server and some other browser or server. This practice helps prevent unauthorized third parties from intercepting and gaining access to your PII during transmission over the Internet. CollegeInColorado.org uses 128-bit, Secure Socket Layer encryption supported by both Netscape’s and Microsoft’s browsers.
PII residing on the CollegeInColorado.org server is password protected, and account access is provided only to the account holder who created the password, anyone to whom that account holder entrusted the password, designated school administrators and staff, and those employees of XAP and CIC who require such access to administer and maintain the CollegeInColorado.org system or to provide requested customer support to users of CollegeInColorado.org. Each XAP employee who has access to the PII residing on the CollegeInColorado.org server has agreed in writing to respect the privacy of all such PII. XAP trains employees to protect customer information and only authorize access for employees who XAP believes have a business need for that information. XAP holds employees accountable to a Code of Conduct and Ethics to protect user information.
The safety and security of your PII also depends on you. You should not send us sensitive PII via email, as this is not secure. You are also responsible for keeping your account username and password confidential. Please notify us if you become aware that your PII is lost, stolen, or used without permission; we may disable access to your account in order to prevent an unauthorized third party from accessing your account.
While we take industry-standard security measures to protect the privacy of your PII, we cannot guarantee that your PII will never be compromised. No Internet or wireless network transmission is ever 100% secure, and no security system can prevent all security breaches. We do not and cannot guarantee that there will be no unintended disclosures of your PII or that unauthorized third parties will not defeat our security measures or use nonpublic information for improper purposes.
We use third-party services provided by Google Analytics to track and analyze your CollegeinColorado.org activity. In order to gather this Automatically-Collected Information, we use a Google Analytics cookie on CollegeinColorado.org. If you don’t want your Automatically-Collected Information used by Google Analytics, Google recommends installing the Google Analytics Opt-out Browser Ad-on, located here:
We also have third-party widgets on CollegeinColorado.org, such as widgets provided by YouTube, PollDaddy and Screencast. When you use these third-party widgets by using features of our site, the widgets may place cookies associated with these widgets on your computer or other operating device
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MODIFYING YOUR INFORMATION
You may update on CollegeInColorado.org any PII you previously provided. To modify PII: (i) Sign in to CollegeInColorado.org, (ii) access either your portfolio or an application containing the information you want to change, (iii) modify that information using standard word-processing techniques, and (iv) save the change. If you want to remove PII that is in a required field (and not replace it with other data), you will need to contact XAP at 1-800-GOTO-XAP and request that your account be inactivated.
Please recognize that if you delete information, it will no longer be available on CollegeInColorado.org so that, for example, if a college to which you previously submitted an application were to attempt to retrieve that application from CollegeInColorado.org after you made the deletion, the deleted information would no longer be accessible. Similarly, when accessed over CollegeInColorado.org, PII that has been updated or otherwise modified will appear in its then-current form, rather than in the form in which it may have been submitted at some earlier time. Please note that if you modify or delete any PII, we may retain the earlier-submitted PII, as described in the section below entitled "Retention and Storage."
RETENTION AND STORAGE
We only retain financial information to complete your payment if you apply to an educational institution through CollegeinColorado.org. We retain all other PII and Automatically-Collected Information in our databases to fulfill the purpose for which the information was collected. Because CollegeInColorado.org is intended to help you set goals and plan for your future education and career path, the PII you put into CollegeInColorado.org will be retained until you ask us to remove your information. Note that even after you ask that we remove your information from our databases, it may be impossible to remove some information, such as information tracked in our web server log files and information that may reside in backup files. We may also retain Automatically-Collected Information even after you request that we remove your information from our databases, for use in the aggregate and to analyze and improve CollegeInColorado.org. Further, even after you request that we remove your information from our databases, we may retain PII and Automatically-Collected Information to comply with applicable laws, rules, regulations, or guidelines; to prevent fraudulent activity; to protect ourselves against liability; to resolve disputes; and to enforce our contractual or other rights. Notwithstanding the foregoing, XAP will not retain PII for longer than is allowed under applicable law.
AMENDING THIS PRIVACY STATEMENT
XAP may amend this Privacy Statement from time to time. We will post any new Statement here, and you should review this Statement regularly to make sure you are aware of its terms. You can determine if this Statement has been revised since your last visit to CollegeInColorado.org by referring to the "last updated" date at the top of this Statement. If XAP makes any substantial changes to this Privacy Statement, XAP may also notify you (i) by posting a message on the CollegeInColorado.org homepage for at least thirty (30) days; or (ii) by providing direct notice to you via your contact information or by requiring that you agree to the revised Statement to next time you log into your account on CollegeInColorado.org. Once posted to CollegeinColorado.org, the new Privacy Statement will apply to all data previously submitted and subsequently submitted to CollegeInColorado.org, unless such use is prohibited by law.
If any part of this Statement is determined to be invalid, illegal, or unenforceable under applicable law, then the invalid, illegal, or unenforceable provision will be deemed to be superseded by a valid, legal, and enforceable provision that most closely matches the intent of the original provision, and the remainder of this Statement will continue in full force and effect.
If you have any questions about this Privacy Statement and the privacy practices on this site, you may contact us at firstname.lastname@example.org.