Last Updated: January 1, 2022
In this Privacy Policy, terms such as “we”, “us”, “our” or similar
expressions shall mean SAGE Scholars, Inc., operating the http://www.readysetcollege.org website
(the “Service”).
This Privacy Policy describes Our policies and procedures on the collection, use and disclosure
of Your information when You use the Service and tells You about Your privacy rights and how the
law protects You.
We use Your Personal data to provide and improve the Service. By using the Service, You agree to
the collection and use of information in accordance with this Privacy Policy.
We keep our privacy practices under review and may change this Privacy Policy from time to time
by posting changes on the Services or otherwise notifying them to you.
Definitions
- Account
-
Account means a unique account created for You to access our Service or parts of our Service.
- Business
-
For the purpose of the CCPA (California Consumer Privacy Act), refers to the Company as the
legal entity that collects Consumers’ personal information and determines the purposes and means
of the processing of Consumers’ personal information, or on behalf of which such information is
collected and that alone, or jointly with others, determines the purposes and means of the
processing of consumers’ personal information, that does business in the State of California.
- Company
-
(referred to as either “the Company”, “We”, “Us” or
“Our” in this Agreement) refers to SAGE Scholars, Inc., 1650 Arch Street Suite 2502.
For the purpose of the GDPR, the Company is the Data Controller.
- Consumer
-
For the purpose of the CCPA (California Consumer Privacy Act), means a natural person who is a
California resident. A resident, as defined in the law, includes (1) every individual who is in
the USA for other than a temporary or transitory purpose, and (2) every individual who is
domiciled in the USA who is outside the USA for a temporary or transitory purpose.
- Cookies
-
Cookies are small files that are placed on Your computer, mobile device, or any other device by
a website, containing the details of Your browsing history on that website among its many uses.
- Country
-
Country refers to: Pennsylvania, United States
- Data Controller
-
For the purposes of the GDPR (General Data Protection Regulation), refers to the Company as the
legal person which alone or jointly with others determines the purposes and means of the
processing of Personal Data.
- Device
-
Device means any device that can access the Service such as a computer, a cellphone or a
digital tablet.
- Do Not Track (DNT)
-
Do Not Track (DNT) is a concept that has been promoted by US regulatory authorities, in
particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop
and implement a mechanism for allowing internet users to control the tracking
of their online activities across websites.
- Facebook Fan Page
-
Facebook Fan Page is a public profile named SAGE Scholars, Inc. specifically created by the
Company on the Facebook social network, accessible from https://www.facebook.com/SAGEScholarsInc/
- Personal Data
-
Personal Data is any information that relates to an identified or identifiable individual.
For the purposes for GDPR, Personal Data means any information relating to You such as a name,
an identification number, location data, online identifier or to one or more factors specific to
the physical, physiological, genetic, mental, economic, cultural, or social identity.
For the purposes of the CCPA, Personal Data means any information that identifies, relates to,
describes or is capable of being associated with, or could reasonably be linked, directly or
indirectly, with You.
- Sale
-
For the purpose of the CCPA (California Consumer Privacy Act), means selling, renting,
releasing, disclosing, disseminating, making available, transferring, or otherwise communicating
orally, in writing, or by electronic or other means, a Consumer’s personal information to
another business or a third party for monetary or other valuable consideration.
- Service
-
Service refers to the Website.
- Service Provider
-
Service Provider means any natural or legal person who processes the data on behalf of the
Company. It refers to third-party companies or individuals employed by the Company to
facilitate the Service, to provide the Service on behalf of the Company, to perform services
related to the Service or to assist the Company in analyzing how the Service is used. For
the purpose of the GDPR, Service Providers are considered Data Processors.
- Sponsor
-
Sponsor means the adult (typically parent, grandparent, aunt or uncle) who registers for
the Service.
- Student
-
Student means the child family members of Sponsors who are added to the Service as
beneficiaries by Sponsors or Sponsor's designated partner organization.
- Third-party Social Media Service
-
Refers to any website or any social network website through which a User can log in or create
an account to use the Service.
- Usage Data
-
Usage Data refers to data collected automatically, either generated by the use of the Service
or from the Service infrastructure itself (for example, the duration of a page visit).
- Website
-
Website refers to Ready Set College, accessible from http://www.readysetcollege.org
- You
-
You means the individual accessing or using the Service, or the company, or other legal entity
on behalf of which such individual is accessing or using the Service, as applicable.
Under GDPR (General Data Protection Regulation), You can be referred to as the Data Subject
or as the User as you are the individual using the Service.
Collecting and Using Your Personal Data
Types of Data Collected
Personal Data
While using Our Service, We may ask You to provide Us with certain personally identifiable
information that can be used to contact or identify You. Personally identifiable information may
include, but is not limited to:
- Email address
- First name and last name
- Phone Number
- Address, State, Province, ZIP/Postal code, City
- Social Security Number
- Date of Birth
- Usage Data
Usage Data
Usage Data is collected automatically when using the Service.
Usage Data may include information such as Your Device's Internet Protocol address
(e.g. IP address), browser type, browser version, the pages of our Service that You visit,
the time and date of Your visit, the time spent on those pages, unique device identifiers
and other diagnostic data.
When You access the Service by or through a mobile device, We may collect certain information
automatically, including, but not limited to, the type of mobile device You use, Your mobile
device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of
mobile Internet browser You use, unique device identifiers and other diagnostic data.
We may also collect information that Your browser sends whenever You visit our Service or when
You access the Service by or through a mobile device.
Tracking Technologies and Cookies
We use Cookies and similar tracking technologies to track the activity on Our Service and store
certain information. Tracking technologies used are beacons, tags, and scripts to collect and
track information and to improve and analyze Our Service. The technologies We use may include:
-
Cookies or Browser Cookies. A cookie is a small file
placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when
a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some
parts of our Service. Unless you have adjusted Your browser setting so that it will refuse
Cookies, our Service may use Cookies.
-
Web Beacons. Certain sections of our Service and our
emails may contain small electronic files known as web beacons (also referred to as clear gifs,
pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who
have visited those pages or opened an email and for other related website statistics (for
example, recording the popularity of a certain section and verifying system and server
integrity).
Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on Your personal
computer or mobile device when You go offline, while Session Cookies are deleted as soon as You
close Your web browser. Learn more about cookies: What Are Cookies?.
We use both Session and Persistent Cookies for the purposes set out below:
- Necessary / Essential Cookies
-
Type: Session Cookies
Administered by: Us
Purpose: These Cookies are essential to provide You with services available through the Website
and to enable You to use some of its features. They help to authenticate users and prevent
fraudulent use of user accounts. Without these Cookies, the services that You have asked for
cannot be provided, and We only use these Cookies to provide You with those services.
- Cookies Policy / Notice Acceptance Cookies
-
Type: Persistent Cookies
Administered by: Us
Purpose: These Cookies identify if users have accepted the use of cookies on the Website.
- Functionality Cookies
-
Type: Persistent Cookies
Administered by: Us
Purpose: These Cookies allow us to remember choices You make when You use the Website, such as
remembering your login details or language preference. The purpose of these Cookies is to
provide You with a more personal experience and to avoid You having to re-enter your
preferences every time You use the Website.
- Tracking and Performance Cookies
-
Type: Persistent Cookies
Administered by: Third-Parties
Purpose: These Cookies are used to track information about traffic to the Website and how users
use the Website. The information gathered via these Cookies may directly or indirectly identify
you as an individual visitor. This is because the information collected is typically linked to
a pseudonymous identifier associated with the device you use to access the Website. We may also
use these Cookies to test new pages, features or new functionality of the Website to see how our
users react to them.
For more information about the cookies we use and your choices regarding cookies, please visit our
Cookies Policy
or the Cookies section of our Privacy Policy.
Use of Your Personal Data
The Company may use Personal Data for the following purposes:
-
To provide and maintain our Service, including to monitor
the usage of our Service.
-
To manage Your Account: to manage Your registration as
a user of the Service. The Personal Data You provide can give You access to different
functionalities of the Service that are available to You as a registered user.
-
For the performance of a contract: the development,
compliance and undertaking of the purchase contract for the products, items or services You
have purchased or of any other contract with Us through the Service.
-
To contact You: To contact You by email, telephone calls,
SMS, or other equivalent forms of electronic communication, such as a mobile application's push
notifications regarding updates or informative communications related to the functionalities,
products or contracted services, including the security updates, when necessary or reasonable
for their implementation.
-
To provide You with news, special offers and general
information about other goods, services and events which we offer that are similar to those that
you have already purchased or enquired about unless You have opted not to receive such
information.
-
To manage Your requests:To attend and manage Your
requests to Us.
-
For business transfers: We may use Your information to
evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or
other sale or transfer of some or all of Our assets, whether as a growing concern or as part of
bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our
Service users is among the assets transferred.
-
For other purposes: We may use Your information for
other purposes, such as data analysis, identifying usage trends, determining the effectiveness
of our promotional campaigns and to evaluate and improve our Service, products, services,
marketing and your experience.
We may share Your personal information in the following situations:
-
With Service Providers: We may share Your personal
information with Service Providers to monitor and analyze the use of our Service, to contact You.
-
For business transfers: We may share or transfer Your
personal information in connection with, or during negotiations of, any merger, sale of
Company assets, financing, or acquisition of all or a portion of Our business to another
company.
-
With Affiliates: We may share Your information with
Our affiliates, in which case we will require those affiliates to honor this Privacy Policy.
Affiliates include any other subsidiaries, joint venture partners or other companies that We
control or that are under common control with Us.
-
With business partners: We may share Your information
with Our business partners to offer You certain products, services, or promotions.
-
With other users: when You share personal information
or otherwise interact in the public areas, including Facebook, Twitter, Instagram, LinkedIn
or other social websites we may use, with other users, such information may be viewed by all
users and may be publicly distributed outside. If You interact with other users or register
through a Third-Party Social Media Service, Your contacts on the Third-Party Social Media
Service may see Your name, profile, pictures and description of Your activity. Similarly,
other users will be able to view descriptions of Your activity, communicate with You and
view Your profile.
-
With Your consent: We may disclose Your personal
information for any other purpose with Your consent.
Retention of Your Personal Data
The Company will retain Your Personal Data only for as long as is necessary for the purposes set
out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to
comply with our legal obligations (for example, if we are required to retain your data to comply
with applicable laws), resolve disputes, and enforce our legal agreements and policies.
The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally
retained for a shorter period of time, except when this data is used to strengthen the security
or to improve the functionality of Our Service, or We are legally obligated to retain this data
for longer time periods.
Transfer of Your Personal Data
Your information, including Personal Data, is processed at the Company's operating offices and in
any other places where the parties involved in the processing are located. It means that this
information may be transferred to — and maintained on — computers located outside of
Your state, province, country, or other governmental jurisdiction where the data protection laws
may differ than those from Your jurisdiction.
Your consent to this Privacy Policy followed by Your submission of such information represents
Your agreement to that transfer.
The Company will take all steps reasonably necessary to ensure that Your data is treated securely
and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place
to an organization or a country unless there are adequate controls in place including the
security of Your data and other personal information.
Disclosure of Your Personal Data
Business Transactions
If the Company is involved in a
merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice
before Your Personal Data is transferred and becomes subject to a different Privacy Policy.
Law enforcement
Under certain circumstances, the
Company may be required to disclose Your Personal Data if required to do so by law or in
response to valid requests by public authorities (e.g. a court or a government agency).
Other legal requirements
The Company may disclose Your Personal Data in the good faith belief that such action
is necessary to:
- Comply with a legal obligation
- Protect and defend the rights or property of the Company
- Prevent or investigate possible wrongdoing in connection with the Service
- Protect the personal safety of Users of the Service or the public
- Protect against legal liability
Security of Your Personal Data
The security of Your Personal Data is important to Us, but remember that no method of
transmission over the Internet, or method of electronic storage is 100% secure. While We strive
to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its
absolute security.
Detailed Information on the Processing of Your Personal Data
The Service Providers We use may have access to Your Personal Data. These third-party vendors
collect, store, use, process and transfer information about Your activity on Our Service in
accordance with their Privacy Policies.
Analytics
We may use third-party Service providers to monitor and analyze the use of our Service.
- Google Analytics
-
Google Analytics is a web analytics service offered by Google that tracks and reports website
traffic. Google uses the data collected to track and monitor the use of our Service. This data
is shared with other Google services. Google may use the collected data to contextualize and
personalize the ads of its own advertising network.
You can opt-out of having made your activity on the Service available to Google Analytics by
installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics
JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about
visits activity.
For more information on the privacy practices of Google, please visit the Google Privacy &
Terms web page:
https://policies.google.com/privacy
Email Marketing
We may use Your Personal Data to contact You with newsletters, marketing or promotional materials
and other information that may be of interest to You. You may opt-out of receiving any, or all,
of these communications from Us by following the unsubscribe link or instructions provided in any
email We send or by contacting Us.
We may use Email Marketing Service Providers to manage and send emails to You. Their Privacy
Policy can be viewed at:
- Twilio/Sendgrid
-
https://www.twilio.com/legal/privacy
- PostMark
-
https://wildbit.com/privacy-policy
GDPR Privacy
Legal Basis for Processing Personal Data under GDPR
We may process Personal Data under the following conditions:
-
Consent: You have given Your consent for processing
Personal Data for one or more specific purposes.
-
Performance of a contract: Provision of Personal Data
is necessary for the performance of an agreement with You and/or for any pre-contractual
obligations thereof.
-
Legal obligation: Processing Personal Data is necessary
for compliance with a legal obligation to which the Company is subject.
-
Vital interests: Processing Personal Data is necessary
in order to protect Your vital interests or of another natural person.
-
Public interests: Processing Personal Data is related
to a task that is carried out in the public interest or in the exercise of official authority
vested in the Company.
-
Legitimate interests: Processing Personal Data is necessary
for the purposes of the legitimate interests pursued by the Company.
In any case, the Company will gladly help to clarify the specific legal basis that applies to the
processing, and in particular whether the provision of Personal Data is a statutory or contractual
requirement, or a requirement necessary to enter into a contract.
Your Rights under the GDPR
The Company undertakes to respect the confidentiality of Your Personal Data and to guarantee You
can exercise Your rights.
You have the right under this Privacy Policy, and by law if You are within the EU, to:
-
Request access to Your Personal Data. The right to access,
update or delete the information We have on You. Whenever made possible, you can access, update
or request deletion of Your Personal Data directly within Your account settings section. If you
are unable to perform these actions yourself, please contact Us to assist You. This also enables
You to receive a copy of the Personal Data We hold about You.
-
Request correction of the Personal Data that We hold about You.
You have the right to to have any incomplete or inaccurate information We hold about You corrected.
-
Object to processing of Your Personal Data. This right
exists where We are relying on a legitimate interest as the legal basis for Our processing and
there is something about Your particular situation, which makes You want to object to our
processing of Your Personal Data on this ground. You also have the right to object where We are
processing Your Personal Data for direct marketing purposes.
-
Request erasure of Your Personal Data. You have the right
to ask Us to delete or remove Personal Data when there is no good reason for Us to continue
processing it.
-
Request the transfer of Your Personal Data. We will
provide to You, or to a third-party You have chosen, Your Personal Data in a structured,
commonly used, machine-readable format. Please note that this right only applies to automated
information which You initially provided consent for Us to use or where We used the information
to perform a contract with You.
-
Withdraw Your consent. You have the right to withdraw
Your consent on using your Personal Data. If You withdraw Your consent, We may not be able to
provide You with access to certain specific functionalities of the Service.
Exercising of Your GDPR Data Protection Rights
You may exercise Your rights of access, rectification, cancellation, and opposition by contacting
Us. Please note that we may ask You to verify Your identity before responding to such requests.
If You make a request, We will try our best to respond to You as soon as possible.
You have the right to complain to a Data Protection Authority about Our collection and use of
Your Personal Data. For more information, if You are in the European Economic Area (EEA), please
contact Your local data protection authority in the EEA.
Facebook Fan Page
Data Controller for the Facebook Fan Page
The Company is the Data Controller of Your Personal Data collected while using the Service. As
operator of the Facebook Fan Page https://www.facebook.com/SAGEScholarsInc/, the Company and the
operator of the social network Facebook are Joint Controllers.
The Company has entered into agreements with Facebook that define the terms for use of the
Facebook Fan Page, among other things. These terms are mostly based on the Facebook Terms
of Service: https://www.facebook.com/terms.php
Visit the Facebook Privacy Policy https://www.facebook.com/policy.php for more information about
how Facebook manages Personal data or contact Facebook online, or by mail: Facebook, Inc. ATTN,
Privacy Operations, 1601 Willow Road, Menlo Park, CA 94025, United States.
Facebook Insights
We use the Facebook Insights function in connection with the operation of the Facebook Fan Page
and on the basis of the GDPR, in order to obtain anonymized statistical data about Our users.
For this purpose, Facebook places a Cookie on the device of the user visiting Our Facebook Fan
Page. Each Cookie contains a unique identifier code and remains active for a period of two years,
except when it is deleted before the end of this period.
Facebook receives, records, and processes the information stored in the Cookie, especially when
the user visits the Facebook services, services that are provided by other members of the
Facebook Fan Page and services by other companies that use Facebook services.
For more information on the privacy practices of Facebook, please visit Facebook Privacy
Policy here: https://www.facebook.com/full_data_use_policy
CCPA Privacy
This privacy notice section for California residents supplements the information contained in
Our Privacy Policy and it applies solely to all visitors, users, and others who reside in the
State of California.
Categories of Personal Information Collected
We collect information that identifies, relates to, describes, references, is capable of being
associated with, or could reasonably be linked, directly or indirectly, with a particular
Consumer or Device. The following is a list of categories of personal information which we may
collect or may have been collected from California residents within the last twelve (12) months.
Please note that the categories and examples provided in the list below are those defined in the
CCPA. This does not mean that all examples of that category of personal information were in fact
collected by Us, but reflects our good faith belief to the best of our knowledge that some of that
information from the applicable category may be and may have been collected. For example, certain
categories of personal information would only be collected if You provided such personal
information directly to Us.
- Category A: Identifiers
-
Examples: A real name, alias, postal address, unique personal identifier, online identifier,
Internet Protocol address, email address, account name, driver's license number, passport
number, or other similar identifiers.
Collected: Yes.
-
Category B: Personal information categories listed in the California Customer Records statute
(Cal. Civ. Code § 1798.80(e)).
-
Examples: A name, signature, Social Security number, physical characteristics or description,
address, telephone number, passport number, driver's license or state identification card
number, insurance policy number, education, employment, employment history, bank account number,
credit card number, debit card number, or any other financial information, medical information,
or health insurance information. Some personal information included in this category may overlap
with other categories.
Collected: Yes.
-
Category C: Protected classification characteristics under California or federal law.
-
Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship,
religion or creed, marital status, medical condition, physical or mental disability, sex
(including gender, gender identity, gender expression, pregnancy or childbirth and related
medical conditions), sexual orientation, veteran or military status, genetic information
(including familial genetic information).
Collected: Yes.
- Category D: Commercial information.
-
Examples: Records and history of products or services purchased or considered.
Collected: No.
- Category E: Biometric information.
-
Examples: Genetic, physiological, behavioral, and biological characteristics, or activity
patterns used to extract a template or other identifier or identifying information, such
as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or
other physical patterns, and sleep, health, or exercise data.
Collected: No.
- Category F: Internet or other similar network activity.
-
Examples: Interaction with our Service or advertisement.
Collected: Yes.
- Category G: Geolocation data.
-
Approximate physical location.
Collected: No.
- Category H: Sensory data.
-
Audio, electronic, visual, thermal, olfactory, or similar information.
Collected: No.
- Category I: Professional or employment-related information.
-
Current or past job history or performance evaluations.
Collected: Yes.
-
Category J: Non-public education information (per the Family Educational Rights and Privacy
Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
-
Examples: Education records directly related to a student maintained by an educational
institution or party acting on its behalf, such as grades, transcripts, class lists, student
schedules, student identification codes, student financial information, or student
disciplinary records.
Collected: No.
- Category K: Inferences drawn from other personal information.
-
Profile reflecting a person's preferences, characteristics, psychological trends,
predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Collected: No.
Under CCPA, personal information does not include:
- Publicly available information from government records
- Deidentified or aggregated consumer information
-
Information excluded from the CCPA's scope, such as:
-
Health or medical information covered by the Health Insurance Portability and
Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical
Information Act (CMIA) or clinical trial data
-
Personal Information covered by certain sector-specific privacy laws, including the Fair
Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial
Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994
Sources of Personal Information
We obtain the categories of personal information listed above from the following categories
of sources:
-
Directionly from you. For example, from the forms You
complete on our Service, preferences You express or provide through our Service.
-
Indirectly from you. For example, from observing Your
activity on our Service.
-
Automatically from you. For example, through cookies We
or our Service Providers set on Your Device as You navigate through our Service.
-
From Service Providers. For example, third-party vendors
to monitor and analyze the use of our Service, or other third-party vendors that We use to
provide the Service to You.
Use of Personal Information for Business Purposes or Commercial Purposes
We may use or disclose personal information We collect for “business purposes” or
“commercial purposes” (as defined under the CCPA), which may include the following examples:
-
To operate our Service and provide You with our Service.
-
To provide You with support and to respond to Your inquiries, including to investigate and
address Your concerns and monitor and improve our Service.
-
To fulfill or meet the reason You provided the information. For example, if You share Your
contact information to ask a question about our Service, We will use that personal information to respond to Your inquiry.
-
To respond to law enforcement requests and as required by applicable law, court order, or
governmental regulations.
-
As described to You when collecting Your personal information or as otherwise set forth
in the CCPA.
-
For internal administrative and auditing purposes.
-
To detect security incidents and protect against malicious, deceptive, fraudulent or illegal
activity, including, when necessary, to prosecute those responsible for such activities.
Please note that the examples provided above are illustrative and not intended to be exhaustive.
For more details on how we use this information, please refer to the “Use of Your Personal Data”
section.
If We decide to collect additional categories of personal information or use the personal
information We collected for materially different, unrelated, or incompatible purposes We will
update this Privacy Policy.
Disclosure of Personal Information for Business Purposes or Commercial Purposes
We may use or disclose and may have used or disclosed in the last twelve (12) months the
following categories of personal information for business or commercial purposes:
- Category A: Identifiers
-
Category B: Personal information categories listed in the California Customer Records
statute (Cal. Civ. Code § 1798.80(e))
-
Category C: Optionally provided information on Students including age, race, religion or
creed, and sex (including gender, gender identity, gender expression)
-
Category F: Internet or other similar network activity
Please note that the categories listed above are those defined in the CCPA. This does not mean
that all examples of that category of personal information were in fact disclosed, but reflects
our good faith belief to the best of our knowledge that some of that information from the
applicable category may be and may have been disclosed.
When We disclose personal information for a business purpose or a commercial purpose, We enter
a contract that describes the purpose and requires the recipient to both keep that personal
information confidential and not use it for any purpose except performing the contract.
Sale of Personal Information
As defined in the CCPA, “sell” and “sale” mean selling, renting, releasing, disclosing,
disseminating, making available, transferring, or otherwise communicating orally, in writing,
or by electronic or other means, a consumer's personal information by the business to a third
party for valuable consideration. This means that We may have received some kind of benefit in
return for sharing personal information, but not necessarily a monetary benefit.
Please note that the categories listed below are those defined in the CCPA. This does not mean
that all examples of that category of personal information were in fact sold, but reflects our
good faith belief to the best of our knowledge that some of that information from the applicable
category may be and may have been shared for value in return.
We may sell and may have sold in the last twelve (12) months the following categories of
personal information:
- Category A: Identifiers
-
Category B: Personal information categories listed in the California Customer Records statute
(Cal. Civ. Code § 1798.80(e))
-
Category C: Optionally provided information on Students including age, race, religion or creed,
and sex (including gender, gender identity, gender expression)
-
Category F: Internet or other similar network activity
Share of Personal Information
We may share Your personal information identified in the above categories with the following
categories of third parties:
- Service Providers
- Our affiliates
- Our business partners
-
Third party vendors to whom You or Your agents authorize Us to disclose Your personal
information in connection with products or services We provide to You
Release of Personal Information
We do not release the personal information of Consumers We actually know are less than 14 years
of age, unless We receive affirmative authorization (the “right to opt-in”) from either the
Consumer who is between 13 and 14 years of age, or the parent or guardian of a Consumer less
than 13 years of age. By registering for the Program, Consumers are opting in to the release
of personal information. Consumers may opt-out of future releases at any time by requesting the
deletion of their account(s). To exercise the right to opt-out, You (or Your authorized
representative) may submit a request to Us by contacting Us.
If You have reason to believe that a child under the age of 13 has provided Us with personal
information, please contact Us with sufficient detail to enable Us to delete that information.
Member colleges have access to student information beginning at the start of 9th grade in high
school. Student information made available to member colleges may include, but is not limited to:
- Email address
- First name and last name
- Phone number (including mobile)
- Address, State, Province, ZIP/Postal code, City
- Date of birth and year of expected high school graduation
-
Any optional information that has been entered for the student by the account holder, or the
student, such as academic interests, grades, standardized test results, outside clubs and
activities, ethnic or religious information
- Cookies and Usage Data
Unless you specifically opt-in, Sponsor information is not shared with member colleges. Should
you choose to opt-in, information from your account profile that is made available to member
colleges may include, but is not limited to:
- Email address
- First name and last name
- Phone number (including mobile)
- Address, State, Province, ZIP/Postal code, City
- Date of birth
-
Any optional information that has been entered by you in your profile that is intended
specifically to be shared with member colleges and universities
- Cookies and Usage Data
Your Rights under the CCPA
The CCPA provides California residents with specific rights regarding their personal information.
If You are a resident of California, You have the following rights:
-
The right to notice.You have the right to be notified
which categories of Personal Data are being collected and the purposes for which the Personal
Data is being used.
-
The right to request.Under CCPA, You have the right to
request that We disclose information to You about Our collection, use, sale, disclosure for
business purposes and share of personal information. Once We receive and confirm Your request,
We will disclose to You:
- The categories of personal information We collected about You
- The categories of sources for the personal information We collected about You
- Our business or commercial purpose for collecting or selling that personal information
- The categories of third parties with whom We share that personal information
- The specific pieces of personal information We collected about You
-
If we sold Your personal information or disclosed Your personal information for a business
purpose, We will disclose to You:
- The categories of personal information categories sold
- The categories of personal information categories disclosed
-
The right to say no to the sale of Personal Data (opt-out).
You have the right to direct Us to not sell Your personal information. To submit an opt-out
request please contact Us.
-
The right to delete Personal Data. You have the right to
request the deletion of Your Personal Data, subject to certain exceptions. Once We receive and
confirm Your request, We will delete Your personal information from our records, unless an
exception applies. We may deny Your deletion request if retaining the information is necessary
for Us or Our Service Providers to:
-
Complete the transaction for which We collected the personal information, provide a good or
service that You requested, take actions reasonably anticipated within the context of our
ongoing business relationship with You, or otherwise perform our contract with You.
-
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal
activity, or prosecute those responsible for such activities.
-
Debug products to identify and repair errors that impair existing intended functionality.
-
Exercise free speech, ensure the right of another consumer to exercise their free speech
rights, or exercise another right provided for by law.
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Comply with the California Electronic Communications Privacy Act (Cal. Penal Code §
1546 et. seq.).
-
Engage in public or peer-reviewed scientific, historical, or statistical research in the
public interest that adheres to all other applicable ethics and privacy laws, when the
information's deletion may likely render impossible or seriously impair the research's
achievement, if You previously provided informed consent.
-
Enable solely internal uses that are reasonably aligned with consumer expectations based
on Your relationship with Us.
-
Comply with a legal obligation.
-
Make other internal and lawful uses of that information that are compatible with the
context in which You provided it.
-
The right not to be discriminated against
- Denying goods or services to You
-
Charging different prices or rates for goods or services, including the use of discounts
or other benefits or imposing penalties
- Providing a different level or quality of goods or services to You
-
Suggesting that You will receive a different price or rate for goods or services or a
different level or quality of goods or services
Exercising Your CCPA Data Protection Rights
In order to exercise any of Your rights under the CCPA, and if You are a California
resident, You can contact Us:
By email: privacy@sagescholars.com
By phone number: 215-564-9930
By mail: 1650 Arch Street Suite 2502 Philadelphia Pa. 19103
Only You, or a person registered with the California Secretary of State that You authorize to
act on Your behalf, may make a verifiable request related to Your personal information.
Your request to Us must:
-
Provide sufficient information that allows Us to reasonably verify You are the person about
whom We collected personal information or an authorized representative
-
Describe Your request with sufficient detail that allows Us to properly understand, evaluate,
and respond to it
We cannot respond to Your request or provide You with the required information if we cannot:
- Verify Your identity or authority to make the request
- And confirm that the personal information relates to You
We will disclose and deliver the required information free of charge within 45 days of receiving
Your verifiable request. The time period to provide the required information may be extended once
by an additional 45 days when reasonably necessary.
Any disclosures We provide will only cover the 12-month period preceding the verifiable request's
receipt.
For data portability requests, We will select a format to provide Your personal information that
is readily useable and should allow You to transmit the information from one entity to another
entity without hindrance.
Do Not Release My Personal Information
As part of the Tuition Rewards program, we do not release your (the Sponsor) information to member
colleges. We may provide your information to the affiliate(s) you have registered for The Program
through as part of our normal reporting process. You have the right to opt-out of the release of
Your personal information. Once We receive and confirm a verifiable consumer request from You, we
will delete your account, along with the accounts of student beneficiaries that are sponsored only
by you. All earned Tuition Rewards will be forfeited upon account deletion. To exercise Your right
to opt-out, please contact Us.
The Service Providers we partner with (for example, our analytics or advertising partners) may
use technology on the Service that sells personal information as defined by the CCPA law. If you
wish to opt out of the use of Your personal information for interest-based advertising purposes
and these potential sales as defined under CCPA law, you may do so by following the instructions
below.
Please note that any opt out is specific to the browser You use. You may need to opt out on
every browser that You use.
Website
You can opt out of receiving ads that are personalized as served by our Service Providers
by following our instructions presented on the Service:
- The NAI's opt-out platform: http://www.networkadvertising.org/choices/
- The EDAA's opt-out platform http://www.youronlinechoices.com/
- The DAA's opt-out platform: http://optout.aboutads.info/?c=2&lang=EN
The opt out will place a cookie on Your computer that is unique to the browser You use to opt
out. If you change browsers or delete the cookies saved by your browser, You will need to opt
out again.
Mobile Devices
Your mobile device may give You the ability to opt out of the use of information about the apps
You use in order to serve You ads that are targeted to Your interests:
- “Opt out of Interest-Based Ads” or “Opt out of Ads Personalization” on Android devices
- “Limit Ad Tracking” on iOS devices
You can also stop the collection of location information from Your mobile device by changing
the preferences on Your mobile device.
“Do Not Track” Policy as Required by California Online Privacy Protection Act (CalOPPA)
Our Service does not respond to Do Not Track signals.
However, some third-party websites do keep track of Your browsing activities. If You are visiting
such websites, You can set Your preferences in Your web browser to inform websites that You do not
want to be tracked. You can enable or disable DNT by visiting the preferences or settings page
of Your web browser.
Children’s Privacy
The Service may contain content appropriate for children under the age of 13. As a parent, you
should know that through the Service children under the age of 13 may participate in activities
that involve the collection or use of personal information. We use reasonable efforts to ensure
that before we collect any personal information from a child, the child’s parent receives notice
of and consents to our personal information practices.
We also may limit how We collect, use, and store some of the information of Users between 13 and
18 years old. In some cases, this means We will be unable to provide certain functionality of the
Service to these Users. If We need to rely on consent as a legal basis for processing Your
information and Your country requires consent from a parent, We may require Your parent's consent
before We collect and use that information.
We may ask a User to verify its date of birth before collecting any personal information from
them. If the User is under the age of 13, the Service will be either blocked or redirected to
a parental consent process.
Information Collected from Children Under the Age of 13
The Company may collect and store information provided to us by affiliated third-parties, about
Children without parental consent given directly to Us. Please refer to the affiliated
organization's Privacy Policy for details on information shared with Us.
We may collect and store other personal information about children if this information is
submitted by a child with prior parent consent or by the parent or guardian of the child.
The Company may collect and store the following types of personal information about a child when
submitted by a child with prior parental consent or by the parent or guardian of the child:
- First name and last name
- Address, State, Province, ZIP/Postal code, City
- Date of birth
- Gender
- Grade level
- Email address
- Phone number (including mobile)
- Parent's or guardian's name
- Parent's or guardian's email address
- Social Security Number
-
Information about high school academics, standardized testing, financial aid information, and
college preferences
For further details on the information We might collect, You can refer to the “Types of Data
Collected” section of this Privacy Policy. We follow our standard Privacy Policy for the
disclosure of personal information collected from and about children.
Parental Access
A parent who has already given the Company permission to collect and use his child personal
information can, at any time:
- Review, correct or delete the child’s personal information
- Discontinue further collection or use of the child’s personal information
To make such a request, You can write to Us using the contact information provided in
this Privacy Policy.
Your California Privacy Rights (California’s Shine the Light law)
Under California Civil Code Section 1798 (California’s Shine the Light law), California residents
with an established business relationship with us can request information once a year about sharing their
Personal Data with third parties for the third parties’ direct marketing purposes.
If you’d like to request more information under the California Shine the Light law, and if You
are a California resident, You can contact Us using the contact information provided below.
California Privacy Rights for Minor Users (California Business and Professions Code Section 22581)
California Business and Professions Code section 22581 allow California residents under the age
of 18 who are registered users of online sites, services or applications to request and obtain
removal of content or information they have publicly posted.
To request removal of such data, and if You are a California resident, You can contact Us using
the contact information provided below, and include the email address associated with Your account.
Be aware that Your request does not guarantee complete or comprehensive removal of content or
information posted online and that the law may not permit or require removal in certain circumstances.
Links to Other Websites
Our Service may contain links to other websites that are not operated by Us. If You click on a
third-party link, You will be directed to that third party's site. We strongly advise You to
review the Privacy Policy of every site You visit.
We have no control over and assume no responsibility for the content, privacy policies or
practices of any third-party sites or services.
Changes to this Privacy Policy
We may update Our Privacy Policy from time to time. We will notify You of any changes by
posting the new Privacy Policy on this page.
We will let You know via email and/or a prominent notice on Our Service, prior to the change
becoming effective and update the “Last updated” date at the top of this Privacy Policy.
You are advised to review this Privacy Policy periodically for any changes. Changes to this
Privacy Policy are effective when they are posted on this page.
Contact Us
If you have any questions about this Privacy Policy, You can contact us:
By email: privacy@sagescholars.com
By phone number: 215-564-9930
By mail: SAGE Scholars Inc. · 1650 Arch Street · Suite 2502 · Philadelphia Pa. 19103