College Confidential Privacy Policy

This Privacy Policy (the “Privacy Policy”) outlines how College Confidential, LLC (hereinafter referred to as “College Confidential,” “we,” “us,” “our’) may collect, use, and share Personal Information that is captured while you (“you”, “your”, and “user” refers to you as the customer utilizing the College Confidential website or services) use our website (the “Site”), including all content, information, and functionality available through the Site, and any other College Confidential products and services, (collectively, referred to as the “Services”). At College Confidential, we recognize that privacy is important, and we hope this Privacy Policy will help you make informed decisions about sharing Personal Information with us.

International Users

Any international users of the Services should be aware that by using the Services, your information will be transferred to, stored on, and/or processed on servers located in the United States. You also understand that the United States’ data protection laws may not offer the same protections or rights, including judicial redress, with regards to your Personal Information as the laws of the country in which you are located. By using the Services or by otherwise providing us with your Personal Information, you consent to this transfer, storage, and processing of your Personal Information.

Your Consent to this Privacy Policy

By using our Services, you agree to the terms of this Privacy Policy as they may be amended from time to time. This Privacy Policy applies to all users of the Services. By providing information to College Confidential, you understand and consent to the collection, maintenance, processing, and transfer of such information in and to the United States and other countries and territories, in accordance with United States law. We reserve the right to modify or revise this Privacy Policy. We may notify users if we make material modifications to the Privacy Policy in accordance with applicable law; however, we reserve the right to make other modifications or revisions without prior notice to you. We recommend that users review the most up-to-date version of the Privacy Policy periodically, which will be available at the Site. Your continued use of the Site or the Services indicates your agreement to be bound by subsequent modifications or revisions to the Privacy Policy.

Information Collection

In order for us to provide you with our Services, we need to collect and utilize some Personal Information. “Personal Information” is information that is reasonably capable of being used to identify you, and we have provided specific examples of the Personal Information we may have collected about you below. Personal Information does not include de-identified or aggregated information, which is information in which identifiable information is removed and that cannot reasonably be used to identify an individual.  We collect Personal Information that you provide to us on the Site and through the Services via forms, applications, forum responses, surveys, user account creation, and other fillable fields on the Site.

Categories of Personal Information We Collect

• Identifiers, such as name, postal address, unique personal identifier, internet protocol address, email address, account name, email password and login information, date of birth, or other similar identifiers.
• Demographic information, such as national origin, citizenship, or sex (including gender or gender identity) may be gathered by use of our Services when such content is uploaded or otherwise submitted by users.
• Commercial information, including products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
• Audio, textual, and video content, including photographs and audio recordings of customer service and related telephone calls, may be gathered from use of our Services when such content is uploaded or otherwise submitted by users or submitted to us in emails or other communications or as users participate in recorded online Q&A sessions and other presentations.
• Professional or employment information may be gathered from use of our Services when such content is uploaded or otherwise submitted by users.
• Internet or other similar network activity, including browsing history, search history, links, and information regarding your interaction with an internet website, application, or advertisement. This information may be collected notwithstanding the use of do-not-track browser signals or settings.
• Geolocation data is gathered when users interact with our website as IP addresses are obtained during such interaction, and IP addresses provide information about users’ approximate location.
• Education information, such as personally identifiable information under the Family Education Rights and Privacy Act, including information you choose to add to your profile, such as the name of your high school or college, your education level completed, academic achievements, or whether you are a first-generation college student.

Categories of Sources for Personal Information We Have Collected

• We have received Personal Information from users of the Services through their direct interactions with the Services, including by signing up for and creating an account with the Services and sharing content on the Services. We have also received Personal Information from parent(s) and/or guardian(s) of users.
• We have received Personal Information from our former parent company Strada Education Network and its affiliated companies.
• We have collected Personal Information, such as technical data, usage data, and internet and other similar network activity through automated technologies and users’ interactions with our Services and from service providers.
• We have collected Personal Information from schools or other educational institutions with which you have agreed to the transfer of Personal Information to College Confidential.

Information Collected Automatically

In addition to the Personal Information that we collect from you as described above, we may automatically collect certain information, including Personal Information, from your use of the Site or the Services. This information may include:

• Usage information, such as which features of the Site or the Services you access or use or the frequency of access;
• Device information, such as hardware model, operating system, application version number, browser type, or IP address;
• Mobile device information, such as the unique device identifier assigned to your device, mobile carrier, operating system, and other device attributes;
• Information about software bugs, errors, API calls, page loads, or similar requests; and
• Other information about your Internet activities.

The information described above may be collected through cookies (defined below) or other technologies.

Our Business or Commercial Purposes for Collecting Personal Information and Categories of Third Parties to Whom the Information is Disclosed

• Identifiers are collected to market to individuals, provide users with our Services, to improve the quality, safety, and security of the Services, to customize and improve our Services, to administer your account and process your requests related to the Services, and to respond to direct inquiries. We may share this Personal Information with our service providers that assist us to provide users with the Services, to trusted third parties like Second Street and Upland Software Inc. that assist to facilitate sweepstakes, contests, or other promotions, and to aligned partners such as schools and educational services providers. When users submit content for certain Services, such as the Site, some identifiers may be disclosed publicly.
• Demographic information is collected to market to individuals, provide users with our Services, to improve the quality, safety, and security of the Services, to customize and improve our Services, to administer your account and process your requests related to the Services, and to respond to direct inquiries. We may share this Personal Information with our service providers that assist us to provide users with the Services, and to aligned partners such as schools and educational services providers. When users submit content for certain Services, some demographic information may be disclosed publicly.
• Commercial information is collected to provide users with our Services, to improve the quality, safety, and security of the Services, to customize and improve our Services, to administer your account and process your requests related to the Services, and to respond to direct inquiries. We may share this Personal Information with our service providers that assist us to provide users with the Services, and to aligned partners such as schools and educational services providers.
• Audio, textual, and video content is collected to provide users with our Services, to improve the quality, safety, and security of the Services, to customize and improve our Services, to detect security incidents, and to protect against malicious, deceptive, fraudulent, or illegal activity. We may share this Personal Information with our service providers that assist us to provide users with the Services and to provide fraud protection, and to aligned partners such as schools and educational services providers. When users submit content for certain Services, such as the Site, some audio, textual, and video content may be disclosed publicly.
• Professional or employment information is collected to market to users, to provide users with our Services, to improve the quality, safety, and security of the Services, to customize and improve our Services, to detect security incidents, and to protect against malicious, deceptive, fraudulent, or illegal activity. We may share this Personal Information with our service providers that assist us to provide users with the Services and to provide fraud protection, and to aligned partners such as schools and educational services providers. When users submit content for certain Services, some professional or employment information may be disclosed publicly.
• Internet or other similar network activity is collected to market to individuals, to provide users with our Services, to improve the quality, safety, and security of the Services, to customize and improve our Services, to detect security incidents, and to protect against malicious, deceptive, fraudulent, or illegal activity. We may share this Personal Information with our service providers that assist us to provide users with the Services and to provide fraud protection, and to aligned partners such as schools and educational services providers. We may share Internet activity with advertising service providers to serve relevant advertisements and obtain analytics information concerning our advertising. This may electronic network activity information such as:
• Usage information, such as which features of our online services you access or use or the frequency of access;
• Device information, such as hardware model, operating system, application version number, browser type, or IP address;
• Mobile device information, such as your unique device identifier, mobile carrier, operating system, and other device attributes; and
• Geolocation data is collected to market to individuals, to provide users with our Services, to improve the quality, safety, and security of the Services, to customize and improve our Services, to detect security incidents, and to protect against malicious, deceptive, fraudulent, or illegal activity. We may share this Personal Information with our service providers that assist us to provide users with the Services and to provide fraud protection, and to aligned partners such as schools and educational services providers. We may share geolocation data with advertising service providers to serve relevant advertisements and obtain analytics information concerning our advertising.
• Education information is collected to market to individuals, provide users with our Services, to improve the quality, safety, and security of the Services, to customize and improve our Services, and to administer your account and process your requests related to the Services. We may share this Personal Information with our service providers that assist us to provide users with the Services and to provide fraud protection, and to aligned partners, such as schools and educational services providers. When users submit content for certain Services, some education information may be disclosed publicly.
• Profile information, is collected to market to users, provide users with our Services, to improve the quality, safety, and security of the Services, to customize and improve our Services, to share with partnered educational institutions, and to administer your account and process your requests related to the Services. We may share this Personal Information with our service providers that assist us to provide users with the Services, to provide fraud protection, and to aligned partners, such as schools and educational services providers. When users submit content for certain Services, add schools to their favorites, or My List, some profile information and the users school selections may be disclosed to partnered educational institutions.
• Audio, textual, and video content is collected to market to individuals, provide users with our Services, to improve the quality, safety, and security of the Services, to customize and improve our Services, to detect security incidents, and to protect against malicious, deceptive, fraudulent, or illegal activity. We may share this Personal Information with our service providers that assist us to provide users with the Services and to provide fraud protection, and to aligned partners such as schools and educational services providers. When users submit content for certain Services, such as a scholarship, or participate in a recorded presentation, some audio, textual, and video content may also be disclosed publicly.
• In addition, where consistent with applicable laws and regulations, we may disclose Personal Information in all categories below:
• to prepare, negotiate, or perform a contract with you;
• to respond to subpoenas, court orders, or other legal process otherwise
  required by law or the competent government or judicial authorities;
• to establish or preserve a legal claim or defense;
• as part of corporate restructuring, sale of assets, merger, or divestiture; or
• to prevent fraud or other illegal activities, such as willful attacks on our information technology systems.

We may also use the categories of Personal Information about you described above for the following business or commercial purposes:

• Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.
• Helping to ensure security and integrity to the extent the use of the consumer’s Personal Information is reasonably necessary and proportionate for these purposes.
• Debugging to identify and repair errors that impair existing intended functionality.
• Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing analytic services, providing storage, or providing similar services on behalf of the business.
• Providing advertising and marketing services, except for cross-context behavioral advertising, to the consumer, such as notifying you of company news and promotions.
• Undertaking internal research for technological development and demonstration.
• Undertaking activities to verify or maintain the quality or safety of a service that is owned, developed, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, developed, manufactured for, or controlled by the business.
• For survey or sweepstakes purposes, such as if you participate in a survey or sweepstakes and includes information needed for you to participate (such as contact information), and to fulfill your prize.
• To personalize your experience or to improve our products and services and by allowing us to customize the content and/or layout of our services based on feedback and information we receive from you.
• For our legitimate business purposes that are not otherwise prohibited by law.
• For specific purposes for which we obtain your consent.

Online Tracking

This Site uses cookies and similar tracking technologies such as the Common ID cookie to provide Services. Cookies are important devices for measuring advertising effectiveness and ensuring a robust online advertising industry. The Common ID cookie stores a unique user id in the first party domain and is accessible to our ad partners. This simple ID that can be utilized to improve user matching, especially for delivering ads to iOS and MacOS browsers. Users can opt out of the Common ID tracking cookie by clicking here.

The information that is captured about your use of the Services may be used in a variety of ways, such as to monitor and maintain information about your visits to the Services, to help us identify and address problems, to improve the Services, to analyze web traffic trends, and to help protect the security and integrity of the Services.

You may set your browser not to accept cookies or to notify you when you receive cookies, giving you the opportunity to decide whether to accept cookies. If you do not accept cookies, you may still use the Services, but your experience may be degraded.

Some web browsers may transmit “do-not-track” or similar signals to the websites with which a user communicates. There currently is no industry standard for how websites must respond when they receive such a signal. The Site does not respond to do-not-track signals sent by web browsers.

Some of the content, advertisements, and functionality of the Services may be provided by third parties. We also use third-party service providers, including Sentry.io, to provide us with analytics, error detection, and application functionality services, so we can improve our Services. Although Sentry.io does not use cookie technology, collect Personal Information, or otherwise track users, data is collected during instances of application crashes, errors, software bugs or other adverse events. Sentry.io data is paired with randomly generated unique identifiers (UUIDs) to enable us to diagnose adverse events, like application crashes. Other third parties may collect information about your use of the Online Services through technologies such as cookies and web beacons, and this information may be collected over time and combined with information collected across different websites. Some of these third parties may provide you with ways to choose not to have your information collected or used for targeted advertising. For example, some of these third parties may be members of the Network Advertising Initiative (“NAI”) or the Digital Advertising Alliance (“DAA”), which provide websites where you can opt out of certain types of data collection and use or out of receiving targeted ads from member companies. To opt out, please visit https://www.networkadvertising.org/managing/opt_out.asp or

https://www.aboutads.info. For more information about mobile device opt outs, please visit https://thenai.org/opt-out/mobile-opt-out/.

Another third-party service that we use is Google Analytics, which is a web analysis service provided by Google. Google utilizes the data collected to track and examine the use of the Services and may share this data with other Google services. We have also enabled Google Analytics Advertising features, including remarketing, so Google may use the data collected to contextualize and personalize the ads of its own advertising networks. The Services and third parties, including Google, use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to inform, optimize, and serve ads based on past visits to the Online Services and report how ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to visits to the Online Services. You can learn more about Google’s privacy practices by visiting their website at https://www.google.com/policies/privacy/partners/.

Microsoft Clarity

Microsoft Clarity captures the user interactions on your website such as, how the page is rendering, user interactions such as mouse movements, clicks, and scrolls. You can also read a summary of data collected. You can choose to mask your users' data. For more information, see Microsoft Privacy Statement.

Sentry.io

We also use third-party service providers, including Sentry.io, to provide us with analytics, error detection, and application functionality services, so we can improve our Services. Although Sentry.io does not use cookie technology, collect Personal Information, or otherwise track users; data is collected during instances of crashes, errors, software bugs or other adverse events. Sentry.io data is paired with randomly generated unique identifiers (UUIDs) to enable us to diagnose adverse events, like application crashes.

HotJar

We use third-party service providers, including HotJar, to provide us with site utilization data, including clicks, page visits, device data, browser information and other user activity on our website. Information that Hotjar collects will be used to gain a better understanding of our users’ needs, interactions with our website, to identify issues that our users are running into, and build and maintain user features.

Individuals in the European Economic Area (“EEA”)
Our role as data controller and data processor.
College Confidential generally acts as the data controller of your Personal Information submitted through the Services, including our forum; however, under certain circumstances, the schools and institutions we are contracted with may engage us to provide them with certain processing services related to Personal Information owned or controlled by the school and institution. We are not responsible for any school’s or institution’s use of Personal Information for which it is an owner or controller. As processor for a school or institution, we only act under their instruction with respect to the processing of your Personal Information. To learn more about how a specific school or institution may use Personal Information, you should review its respective Privacy Policy.

Legal basis for our processing of your Personal Information.

As further outlined in this Privacy Policy, we rely on your Personal Information for the legitimate commercial purpose of providing our Services to you or to perform our responsibilities under a contract with you. We also may rely on your consent to collect, use, or disclose your Personal Information. We will only use your Personal Information for the purposes for which we collected it, unless we reasonably believe that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your Personal Information for an unrelated purpose, we will notify you and explain the legal basis that allows us to do so. Please note that we may process your Personal Information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law. If we are relying on your consent to process your Personal Information, you have the right to withdraw your consent by contacting us at admin@collegeconfidential.com.

Data Subject Requests.

Individuals located in the EEA have the right to access Personal Information we hold about you and to ask that your Personal Information be corrected, erased, or transferred. You may also have the right to object to, or request that we restrict, certain processing. More information about how to exercise these rights is included in the “How to Exercise Your Rights” section below.

Questions or Complaints.

If you are situated in the EEA and have any complaints regarding our privacy practices as a data controller, you have the right to make a complaint at any time to your local Supervisory Authority. However, we would appreciate the chance to address your concerns before you approach your Supervisory Authority so please contact us in the first instance. If you are located in the EEA and have a complaint, please contact us at admin@collegeconfidential.com.

Your Privacy Rights. 

In accordance with applicable law, you may have the right to:

• Access and Portability of Your Personal Information, including: (i) confirming whether we are processing your Personal Information; (ii) obtaining access to or a copy of your Personal Information; and (iii) receiving an electronic copy of Personal Information that you have provided to us, or asking us to send that information to another company in a structured, commonly used, and machine-readable format (also known as the “right of data portability”);
• Request Correction of your Personal Information where it is inaccurate or incomplete. In some cases, we may provide self-service tools that enable you to update your Personal Information;
• Request Deletion of your Personal Information;
• Request Restriction of or Object to our processing of your Personal Information where the processing of your Personal Information is based on our legitimate interest or for direct marketing purposes, including (i) the right to opt-out of the sharing of Personal Information, (ii) object to or restrict our use of or your sensitive Personal Information, including the right to opt-out of the sharing of sensitive Personal Information, and (iii) opt out of the processing of your Personal Information for purposes of (a) targeted advertising, and (b) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you, or to our selling or sharing of your Personal Information (although we do not sell or share your Personal Information, including minors under the age of 16 years); and
• Withdraw your Consent to our processing of your Personal Information. Please note that your withdrawal will only take effect for future processing and will not affect the lawfulness of processing before the withdrawal.
• No Discrimination because you have exercised any of your rights.

How to Exercise Your Rights 

If you would like to exercise any of these rights, please send an email to admin@collegeconfidential.com or please visit this page, fill in the form, and submit your request. We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Information, or to exercise any of your other rights. This is a security measure to ensure that Personal Information is not disclosed to a person who has no right to receive it.

Only you, or a person that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child.

The verifiable request must:

• Provide sufficient information, which may include name, address, and date of birth, that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative; and
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond.

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.

Making a verifiable consumer request does not require you to create an account with us.

We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.  We will attempt to match the Personal Information submitted with your request against our records to verify your identity.

You may designate an authorized agent to make a CCPA request on your behalf by writing to us at the contact information provided above. We also require documentation confirming that the individual is authorized to submit the request on your behalf. This may include a signed letter from you or notarization of your request.

Third-Party Sites and Services

Our Services may contain links to other websites and services operated by colleges, universities, and other educational services providers, social networks, and other third parties. In addition, our features, widgets, or portions of the Services may be integrated on other sites and applications. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control third-party websites, applications, or services, and are not responsible for their actions. Other websites and services follow different rules regarding their collection, use, and sharing of your Personal Information. We encourage you to read their privacy policies to learn more.

Notice Regarding Social Media Use

Personal Information that you share on College Confidential-managed pages on social media platforms, such as Facebook, Instagram, and Twitter, and social media advertising services are subject to the privacy policies and terms of use of those platforms. Please refer to those policies before posting any content to those pages or to learn how to opt out from ads or otherwise manage ad preferences. You should NEVER provide Personal Information to College Confidential through social media. We may receive your Personal Information from these social media platforms.

Data Integrity and Retention

We take reasonable steps to ensure that the Personal Information we process is accurate, complete, and current, but we depend on our users to update or correct their Personal Information whenever necessary. We also take reasonable security measures to protect against unauthorized access to, or unauthorized alteration, disclosure, or destruction of, data.

We will only retain your information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for your information, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of your information, the purposes for which we process your information and whether we can achieve those purposes through other means, and the applicable legal requirements, including taking into account the freedoms of speech and expression.

A user’s email address can be updated at any time through their account settings, or by emailing admin@collegeconfidential.com with your username, email address on file, and new email address. We ask individual users to identify themselves and the information requested to be corrected or removed before processing such requests, and we may decline to process requests that require extraordinary technical effort, jeopardize the privacy of others, or would be extremely impractical.

User accounts are personal to the registered user. In the event of the death of a user, the user’s account will be deactivated if a verifiable request is received; however, existing content will not be removed from the forums unless required by law. College Confidential cannot provide any Personal Information regarding the user or the account (including username and password) to any family member, next of kin, or legal representative without an order from a court of competent jurisdiction compelling College Confidential to do so.

Data Relating to Children Under 13

Our Services are not intended for, directed at, and we do not knowingly collect Personal Information from, anyone under the age of 13 (or such other age as may be restricted under local law). If we are made aware that we have received such information, or any information in violation of our Privacy Policy, we will use reasonable efforts to locate and remove that information from our records.

If you wish to have your child’s information removed, please contact College Confidential by email at admin@collegeconfidential.com. We will need to verify the identity of anyone requesting information about a child to ensure that the person is in fact the child’s parent or legal guardian. However, please understand that, even after removal, your child's content may remain viewable in cached and archived pages or by others if a user has copied or stored such content.

Subprocessors

Some of the content, advertisements, and functionality on our website may be provided by third-party subprocessors. When we share your information with third party subprocessors, such as our vendors and service providers, we remain responsible for it. We work hard to maintain your trust and when bringing on new vendors and subprocessors, we make certain those third parties can be trusted with any Personal Information they may have access to.

CPRA Notice at Collection

Ascent is providing you with this Notice at Collection (“Notice”) and Privacy Policy as required under CCPA and CPRA to provide you with timely notice, at or before the point of collection, about the categories of Personal Information to be collected from you, the purposes for which the Personal Information will be used, and retention periods.

Changes to this Privacy Policy

Please note that this Privacy Policy may change from time to time. We reserve the right, at our discretion, to change, modify, add, or remove portions from this Privacy Policy at any time. However, if at any time in the future we plan to use your Personal Information in a way that materially differs from this Privacy Policy, we will post such changes here or email you. We recommend that users of our Services review the most up-to-date version of the Terms of Service, Forum Rules, and Privacy Policy periodically at www.collegeconfidential.com. If you have any additional questions or concerns about the Privacy Policy, please contact us at: admin@collegeconfidential.com.

Last Updated: June 28th, 2023