- Use of Information
- How We Share Information
- Third-Party Service Providers
- Information Security
- Rights to Your Personal Data
- Data Retention
- Links to Third-Party Sites
- Children’s Privacy
- Additional California Privacy Rights
- Changes in the Privacy Policy
- How to Contact Us
Introduction
Welcome to FinAide Application (the “App”) (with all services, together with the App, collectively known as, the “Services”). The Services and related content are owned and operated by FinAide, LLC (“Organization,” “us,” “we,” “our”). We know that you care how information about you is used and shared. We have developed this privacy policy (“Privacy Policy”) to inform users (“User(s),” “you,” or “your”) about how we collect information in the course of conducting our business, including on our Services, how we use the collected information, and a User’s rights with respect to the collected information.
The Services are hosted and operated in the United States. If you use the Services from outside the United States, please be aware that the information you provide to us is transmitted to, processed, and stored in the United States. Data will be collected, processed, maintained, and used subject to this Privacy Policy and applicable privacy laws in the United States. These laws may be different from the privacy laws in your country. However, this does not change our commitments to safeguard your privacy, and we will comply with all applicable laws relating to the cross-border transfer of your Personal Data (as that term is described below).
This Privacy Policy is binding on all those who access, visit, and/or use our Services, whether acting as an individual or on behalf of an entity, including you and all persons, entities, or digital engines of any kind that harvest, crawl, index, scrape, spider, or mine digital content by an automated or manual process or otherwise. Please read this Privacy Policy carefully. If you do not agree to be bound by this Privacy Policy, then do not access or use the Services. By accessing and/or using the Services, you accept and agree to be bound by this Privacy Policy. Your use of our Services and any Personal Data you provide through the Services are subject to this Privacy Policy at all times.
If you have any questions about this Privacy Policy, please contact us [email protected].
1. Information We Collect
When you use the Services, we collect and/or process the following types of data:
a. Personal Data.
“Personal Data” means any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier. We collect Personal Data that you provide to us when you register for an account on our App or contact us via e-mail. This may include your first or last name, email address, academic records, educational awards, financial information, scholarship information, or your Internet Protocol (“IP”) address. Some information may be used in account or password recovery processes. In California, Personal Data (alternatively, “Personal Information”) includes an identification number, location information, and/or an online identifier.
If we combine or associate information from other sources with Personal Data that we collect through the Services, we will treat the combined information as Personal Data in accordance with this Privacy Policy.
b. Non-Personal Data.
“Non-Personal Data” does not identify you, but provides insights regarding your use of the Services. We collect Non-Personal Data that may include information about your use of the Services. We also use Google Analytics and automated chat and e-mail marketing software to provide services and functionality to Users.
Personal Data and Non-Personal Data are collectively referenced as “Data.”
In some jurisdictions, including most jurisdictions within the United States, an IP address may be considered Non-Personal Data. In the European Economic Area and California, however, an IP address is considered Personal Data under applicable data protection laws. If this is the case, we process Non-Personal Data for the same purposes as Personal Data under this Privacy Policy.
2. Use of Information
For Legitimate Interests. We use Non-Personal Data collected by clickstream information collection, web pixels, and cookies to store your preferences, to generate statistical information, to improve our content and the products, services, materials, and other content.
We may identify you from your Personal Data and merge or co-mingle Personal Data and Non-Personal Data, for any lawful business purpose. Except as otherwise stated, we may use information we collect from you for the legitimate business purpose of providing our Services to you, including, but not limited to:
- to respond to your requests and provide user support;
- to evaluate and improve the content of our Services;
- to establish accounts to use the Services;
- to communicate information and promotional materials to you (where you have not expressed a preference otherwise);
- to check on your account status and maintain record of activities in connection with your use of the Services;
- to notify you of any changes to relevant agreements or policies;
- for research analysis;
- to enforce our agreements, terms, conditions, and policies;
- to work with our service providers who perform certain business functions or services on our behalf and who are bound by contractual obligations consistent with this Privacy Policy;
- to prevent or investigate fraud (or for risk management purposes), or to comply with a legal obligation, court order, or in order to exercise our legal claims or to defend against legal claims;
- to conduct aggregate analysis and develop business intelligence that helps us to enhance, operate, protect, make informed decisions and report on the performances of our Services;
- to describe our Services to current and prospective business partners and to other third parties for other lawful purposes; and
- for other purposes identified to you and as requested by you (please note that you have the right to withdraw your consent to such use at any time by contacting us via the contact information below).
In addition, we use third‐party e‐mail providers to deliver communications to you. This is an opt-in e-mail program. If you no longer want to receive these e-mail communications, you may opt-out of receiving e-mail communications through the “unsubscribe” link in our emails.
3. How We Share Information
We may share your Data in the following ways and with the following parties:
- We may store portions of your Data in locations outside of the direct control of the Organization (g., on servers or databases co-located with service providers).
- Corporate affiliates, including corporate parents, subsidiaries, other affiliated entities, and associated entities for the purposes described in this Policy which are required to treat the information in accordance with this Privacy Policy;
- Colleges, universities, or other educational institutions with whom we have partnered;
- Service providers that help us administer and provide the Services (for example, a web hosting company whose services we use to host our platform). These third-party services providers have access to your Personal Data only for the purpose of performing services on our behalf. A list of service providers is provided in Section 4, below;
- Authorized third parties, who are parties directly authorized by you to receive the applicable Data, such as when you authorize a third-party application provider to access your account or a registered college, university, or other educational institution to access your profile. The use of your Data by an authorized third party is subject to the third party’s privacy policy;
- Third parties in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings), in which case we will require the recipient to use such information in accordance with this Privacy Policy;
- As we believe necessary (i) under applicable law; (ii) to enforce applicable terms and conditions; (iii) to protect our rights, privacy, safety or property, and/or that of our affiliates, you, or others; (iv) to detect, prevent, or otherwise address fraud, security or technical issues; (v) to respond to claims that contact information (g., name, e-mail address, etc.) of a third-party has been posted or transmitted without their consent or as a form of harassment; and (vi) to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include authorities outside your country of residence; and
- Pursuant to your express consent.
4. Third-Party Service Providers
We use third-party service providers to help us operate our Services, who may collect, store, and/or process the information detailed herein. We allow access to our database by third parties that provide us with services, but only for the purpose of and to the extent necessary to provide those services.
We use commercially reasonable efforts to engage with third parties that post a privacy policy governing their collection, processing, and use of Non-Personal Data and Personal Data. While we may seek to require such third parties to follow appropriate privacy policies and will not authorize them to use this information except for the express purpose for which it is provided, and you agree that we do not bear any responsibility for any actions or policies of third parties.
We use the following third-party service providers:
Amazon Web Services. We use Amazon Web Services (“AWS”) to host our Services and to store users’ submitted data. You can learn more about AWS’ Data Privacy policy https://aws.amazon.com/compliance/data-privacy-faq/ and its commitment to the privacy of stored information https://aws.amazon.com/privacy/ at its website.
Constant Contact. Constant Contact provides email marketing services that allows us to customize our e-mails and track how users interact with our communications so that we can study what our users are finding relevant and how to optimize our emails to the greatest benefit for our users. Constant Contact’s policies can be reviewed on its website, https://www.constantcontact.com/forward/privacy-center.
5. Information Security
We take reasonable steps online and offline to safeguard the Personal Data that you provide to us, including Secure Sockets Layer (SSL) encrypted connections (HTTPS) to the website(s) on our Services, secure multi-tiered firewalls, and portions of your data may also be encrypted on our storage server for additional security, secure cloud-based environments and uses server authentication and industry-standard firewalls in an effort to prevent interference or access from outside intruders. We also require unique account identifiers, user names, and passwords that must be entered each time users access the App, or use of secure password credentials to an authorized third party portal.
It is common knowledge that transmission of information via the Internet is not wholly secure, and we cannot guarantee the security of your Personal Data, or any other information, transmitted to or through any of our Services. Any transmission of Personal Data, or other information, is at your own risk. By using our Services, you acknowledge and accept these risks. As a result, we cannot guarantee or warrant the security of any information you disclose or transmit to us or that are otherwise provided to us and we cannot be responsible for the theft, destruction, or inadvertent disclosure of information. It is your responsibility to safeguard any passwords, identification numbers, or other special access features associated with your use of the Services. Any transmission of information is at your own risk.
If you have any questions about security on our Services, or if you become aware of any unauthorized use of an account, loss of your account credentials, or suspect a security breach, notify us immediately via [email protected]. If our security system is breached, we will notify you of the breach to the extent required under applicable law.
6. Rights to Your Personal Data
You may change, edit, update, or delete the information that you provided when you set up your account through our Services through your account settings. You may also request the deletion of this information by sending an e-mail to [email protected]. If you access our Services from certain jurisdictions, such as California, you may have additional rights and options with regard to accessing, reviewing, correcting, and updating your Personal Data, as well as how we use and disclose your Personal Data.
Right to Access. We respect your right to access and control your information, and we will respond to requests for information and, where applicable, will correct, amend, or delete your Personal Data. You may choose to access or update your Personal Data as it exists in our records by logging into the account you have created for yourself on the Services or e-mailing us at [email protected]. Before providing data to you, we will ask for proof of identity and sufficient information about your interaction with us so that we can locate any relevant data. We may also charge you a fee for providing you with a copy of your data (except where this is not permissible under applicable law).
Right to Deletion. You may also have the right to deletion of your Personal Data; however, this is not always possible due to legal requirements, and exceptions may apply. It is your responsibility at all times to ensure that you are in compliance with all applicable rules, policies, and regulations at the institutional, administrative, and federal levels regarding retention of research data.
Right to Opt-Out. You have the right to “opt-out” of the sale of your Personal Data by e-mailing us at [email protected]. If you are a User in California age thirteen (13) to fifteen (15), you are opted out by default, and your Personal Data will not be sold unless you affirmatively opt-in. For Users in California ages twelve (12) or younger, the User’s parent or guardian must affirmatively opt-in to sale of consumer’s personal information.
Updating Communications Preferences. We do send e-mails to users with information about our Services that we believe may be of interest. Users may opt out of receiving e-mail messages by contacting us via e-mail at [email protected] or by clicking on the “unsubscribe” link found at the bottom of every e-mail that we send. Please note that if you opt-out of receiving marketing-related e-mails from us, we may still send you important administrative messages that are required to provide you with our Services, as applicable. If you do not opt-out using the link at the bottom of an e-mail, you will continue to receive electronic communications until you choose to click on the link that will be provided in each e-mail you receive from us.
7. Data Retention
Unless otherwise described or requested by you, we will retain your Data for the period necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.
At any time, users may request deletion of their accounts by e-mailing [email protected]. When you delete your account, it cannot be recovered.
Please note that we do retain Non-Personal Data, including aggregated, de-identified data for the purposes described in the section above titled “How We Use Data.”
8. Links to Third-Party Sites
The Services may contain links to other sites that are not operated by us. If you click on a third-party link, you will be directed to that third party’s site. Such links do not constitute an endorsement by us of those other websites, their content or services, or the persons or entities associated with those websites. This Privacy Policy does not apply to third-party websites. We have no control over, and assume no responsibility for, the content, privacy policies, or practices of any third-party sites or services. We encourage you to review the privacy policies and terms of all third-party websites or services that you may visit.
9. Children’s Privacy
We do not sell products or services for purchase by anyone under the age of thirteen (13). In accordance with the Children’s Online Privacy Protection Act (“COPPA”), we will never knowingly request or solicit Personal Data from anyone under the age of thirteen (13) without verifiable parental consent. In the event that we receive actual knowledge that we have collected such Personal Data without the requisite and verifiable parental consent, we will delete that information from our database as quickly as is practical. We reserve the right to request proof of age at any stage so that we can verify that minors are not using the Services.
10. Additional California Privacy Rights
California Civil Code Section 1798.83 permits California residents to request and obtain a list of what Personal Data (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. Requests may be made only once a year and are free of charge. Under Section 1798.83, California residents are entitled to request and obtain such information, by e-mailing a request to [email protected].
11. Changes in the Privacy Policy
We reserve the right to modify and update this Privacy Policy at any time by posting an amended version of the statement on our Services. Please refer to this policy regularly. If at any time we decide to use Personal Data in a manner different from that stated at the time it was collected, we will notify you either on the panel home page of our Services or via e-mail.
12. How to Contact Us
Because protecting your privacy is important to us, you may always submit concerns regarding our Privacy Policy to the information listed below. We will attempt to respond to all reasonable concerns and inquiries expeditiously.
If you have any questions or comments about our Privacy Policy, please contact us at:
By e-mail:
By regular mail:
FinAide, LLC
P.O. Box 50953
Nashville, TN 37205