Effective: March 1, 2015
NON-PERSONAL AND AGGREGATED INFORMATION COLLECTED AUTOMATICALLY
Each time you visit our Site, we log non-personal information that your browser automatically transmits to us. We may also use third-party website analytics tools (such as Google Analytics) that collect information about user interactions with the Site. Such information may include your IP address, operating system and browser type, domain name, the name of the Web page from which you entered our website, which pages you visit on our website, and how much time you spend on each page. We use this information to monitor and improve our website and for internal analysis. In particular, we use IP addresses to analyze trends, administer the Site, and gather information for aggregate use. However, IP addresses are not linked to personal information.
PERSONAL INFORMATION YOU PROVIDE
You can use portions of our Site without divulging any personal information, including your e-mail address. Our Site does not collect personal information about individuals except when such individuals specifically provide such information on a voluntary basis (for example, enrolling in a school and registering for classes; requesting a catalog; requesting additional information by contacting us; posting a message to a message board; requesting help; or accessing, adding to, or changing the information on your account information page on the Site). When you register yourself or children for whom you are the parent or legal guardian for a Graduation Alliance program or participate in a Graduation Alliance program, we may collect information regarding you and your children, as applicable. This personal information may be collected on our Site or collected via telephone or conventional mail. The types of information that you may be asked to provide, depending on what services you would like to receive, may include without limitation: your first and last name and age; billing address; the names and ages of your children; registration and enrollment information about your children, if applicable; and an e-mail address where we can contact you. Once you have registered yourself or your children for a Graduation Alliance program (whether you registered on our Site or through offline communications), there is an online service for all such programs. There will be a personal information page on the Site that contains some or all of your personal information.
Graduation Alliance also collects personal information made available to Graduation Alliance by contracting educational agencies and institutions, such as student names, student identification numbers, e-mail addresses, GPA, grades, courses taken, standardized test scores, and related information.
Graduation Alliance operates in compliance with federal and state school privacy laws, including The Family Educational Rights and Privacy Act of 1974 (20 U.S.C. § 1232g; 34 CFR Part 99) (“FERPA”). 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 personal information of students under the age of 18 without parental consent. By designating Graduation Alliance as a “school official” and/or a designated contractor with a “legitimate educational interest,” educational agencies and institutions are permitted to share personal information with Graduation Alliance without express, parental consent under the exception provided by 34 CFR § 99.31(a)(1). You may find out more information about FERPA at http://www.ed.gov/policy/gen/guid/fpco/ferpa/index.html.
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’s 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.
HOW WE USE INFORMATION WE COLLECT
PERSONAL INFORMATION ABOUT YOUR CHILDREN (if applicable)
Graduation Alliance only receives personal information about your children as set forth in the “Student Records” section above and/or directly from you when you enroll your children into a Graduation Alliance program. If your children are enrolled in a Graduation Alliance program, we will collect, use, and maintain personal information about your children solely (i) to provide Graduation Alliance programs to them and for other authorized educational purposes, and/or (ii) as otherwise authorized by you.
You can review certain personal information that Graduation Alliance has regarding your children by making such a request in writing to email@example.com. Please be aware that some personal information relating to your children’s educational records may not be able to be disclosed by Graduation Alliance due to state and/or federal law. You can request that your children’s personal information not be used by Graduation Alliance and contractors and service providers acting on behalf of Graduation Alliance by making a request in writing to firstname.lastname@example.org. Please be aware that if you make such a request, your children can no longer continue to be enrolled in a Graduation Alliance program or to use most features on our Site. Therefore, a request by you for Graduation Alliance and our contractors and service providers to no longer use your children’s personal information will terminate your children’s participation in the Graduation Alliance program in which they are enrolled.
YOUR PERSONAL INFORMATION
Graduation Alliance may use your personal information to:
We may aggregate your information with the information of other users for our own internal statistical, design, and/or 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. This aggregate information generally will not personally identify you or be correlated to you individually for external purposes.
We also may use the information we obtain about you in other ways for which we provide specific notice at the time of collection.
INFORMATION WE SHARE
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.
MESSAGE BOARDS AND CHATS
We may offer Graduation Alliance message boards and chat rooms to all students on our Site. Please be aware that anyone may read your or your children’s postings on a message board or in a chat room. Furthermore, any information which you or your children submit to be posted to a message board or in a chat room, including your information from your account information page and User ID, will be disclosed and available to all users of that message board or chat room, and is therefore no longer private. We cannot guarantee the security of such information that you or your children disclose or communicate online in public areas such as message boards and chat rooms, and you do so at your own risk. Please be aware that whenever you voluntarily post public information to the Site, that information can be accessed by the public and can in turn be used by those people to send you unsolicited communications. We reserve the right to monitor the content of the message boards and to republish your postings from message boards or chat rooms elsewhere on the Web or otherwise in any format. As a parent of a student enrolled in the Graduation Alliance program, we encourage you to monitor your child’s postings.
If any of our message boards or other interactive features that allow registered users to post content or information on the Site are directed to California residents under the age of 18, or if we have actual knowledge that registered users of such services are California residents under the age of 18, we will permit such registered users to remove, or request and obtain the removal of, content or information such registered users post on our Site to the extent required by California Business and Professions Code § 22581. If you are a California resident under the age of 18 and would like to remove content or information you have posted on our Site, please contact us at email@example.com.
The Site may contain links to other websites, chat rooms, or other resources that we provide for your convenience (“Linked Sites”). Linked Sites are not under the control of Graduation Alliance, and Graduation Alliance is not responsible for the content available on any Linked Site. Such links do not imply Graduation Alliance’s endorsement of material on any Linked Site, and Graduation Alliance expressly disclaims all liability with regard to your access to such Linked Sites. Access to any Linked Site is at your own risk.
OUR COMMITMENT TO DATA SECURITY
We use industry standard practices designed to safeguard the confidentiality of your personal information and personal information about your children . To prevent unauthorized access, maintain data accuracy, and ensure the correct use of such information, we have put in place physical, electronic, and managerial procedures designed to safeguard and secure the personal information we collect. We also use 128-bit Secure Sockets Layer (SSL) protocol to protect information when route between your browser and Graduation Alliance’s server and when in route between Graduation Alliance’s server and another other browser or server.
Personal information residing on Graduation Alliance’s servers is password protected, and access is provided only to those employees of Graduation Alliance who require such access to administer and maintain our Site or to provide requested customer support to users of the Site. Each Graduation Alliance employee who has access to the data residing on our servers has agreed in writing to respect the privacy of all such personal information.
CHANGES IN CORPORATE STRUCTURE
We offer you the following choices about what information we collect from you and how we communicate with you:
Cookies. You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If, however, you choose to decline cookies, you may not be able to fully experience the interactive features of our Site or have some of our services on the Site function properly.
Marketing Emails. If we have sent you a marketing email, you may choose not to receive additional marketing emails from us by following the unsubscribe instructions contained in each email.
Web Analytics. You may opt-out of the aggregation and analysis of data collected about you on the Site by our web analytics vendor by visiting https://tools.google.com/dlpage/gaoptout and downloading and installing the Google Analytics Opt-out Browser Add-on.
MODIFYING, CORRECTING, OR DELETING YOUR INFORMATION
You may update, otherwise modify or delete any personal information you previously provided on the Site by logging onto the Site and accessing either your user profile or an application containing the information you want to change. Please note that if you delete information, it will no longer be available on the Site.
If you are unable to change your personal information as provided above, wish to delete or modify personal information provided to Graduation Alliance by third parties, or wish to delete your account from the Graduation Alliance system, you may email us at firstname.lastname@example.org.
CHILDREN UNDER THE AGE OF 13
The Site is not directed to children under the age of 13 and does not permit registration by, and will not knowingly collect or use personal information from anyone under 13 years of age. We require users to be at least 13 years of age to use the Site. If we learn we have collected or received personal information from a child under the age of 13, we will delete that information. If you believe we might have any information from or about a child under the age of 13, please contact us at email@example.com.
Graduation Alliance, Inc.
310 South Main Street, 12th Floor
Salt Lake City, UT 84101