UPDATED AS OF: September 15, 2019
At The College Funding Coach® (“we”, “us”, or “our”) we recognize that our relationships with you are based on integrity and trust. We are committed to maintaining your confidence and trust as it relates to the privacy of your information. Please read below and learn how we collect, protect, share and use your information as part of our technology platforms, including, without limitation, our websites, live workshops, webinars, interactive features, applications, and social network pages (“Platforms”).
1. INFORMATION WE COLLECT ON OUR PLATFORMS
Information You Provide To Us
Information We Collect Automatically
Usage Information. Whenever you visit or interact with the Platforms, we, as well as any third-party advertisers and/or service providers, may use a variety of technologies that automatically or passively collect information about how the Platforms are accessed and used (“Usage Information”). Usage Information may include browser type, device type, operating system, application version, the page served, the time, the preceding page views, and your use of features or applications on the Platforms. This information helps us keep our Platforms fresh and interesting to our visitors and allows us to tailor content to a visitor’s interests.
Device Identifier. We automatically collect your IP address or other unique identifier (“Device Identifier”) for the Device (computer, mobile phone, tablet or other device) you use to access the Platforms. A Device Identifier is a number that is assigned to your Device when you access a website or its servers, and our computers identify your Device by its Device Identifier. We may use a Device Identifier to, among other things, administer the Platforms, help diagnose problems with our servers, analyze trends, track users’ web page movements, help identify you and your interests, and gather broad demographic information for aggregate use.
Cookies; Pixel Tags. The technologies used on the Platforms to collect Usage Information, including Device Identifiers, include but are not limited to: cookies (data files placed on a Device when it is used to visit the Platforms), mobile analytics software and pixel tags (transparent graphic image, sometimes called a web beacon or tracking beacon, placed on a web page or in an email, which indicates that a page or email has been viewed). Cookies may also be used to associate you with social networking sites like Facebook and Twitter and, if you so choose, enable interaction between your activities on the Platforms and your activities on such social networking sites. We, or our vendors, may place cookies or similar files on your Device for security purposes, to facilitate site navigation, to perform analytics, and personalize your experience while visiting our Platforms (such as allowing us to select which ads or offers are most likely to appeal to you, based on your interests, preferences, location, or demographic information). A pixel tag may tell your browser to get content from another server.
2. HOW WE USE THE INFORMATION WE COLLECT
We use the information we collect about and from you for a variety of business purposes such as to respond to your questions and requests for services; provide you with access to certain areas and features of the Platforms; verify your identity; communicate with you about your account and activities on the Platforms and, in our discretion, changes to any of our policies; tailor content, advertisements, and offers we serve you; improve the Platforms; comply with license obligations; and for purposes disclosed at the time you provide your Personal Information or otherwise with your consent. We may also collect your location-based information for the purpose of providing you with certain services.
3. SHARING OF INFORMATION
Third Parties Providing Services. We may share your Personal Information with third parties that perform functions on our behalf (or on behalf of our partners) such as:
• Affiliated advisors who are part of The College Funding Coach® network.
• Nonaffiliated companies in order to perform standard business functions on our behalf including service providers that host or operate our Platforms, analyze data, process transactions, fulfill orders, or provide customer service; advertisers; sponsors or surveys or provide marketing or promotional assistance.
• Other financial institutions with whom we may jointly market products, if permitted in your state.
Business Transfers. We may share your Personal Information with other entities and our affiliates primarily for business and operational purposes. In the event that we are involved in a bankruptcy, merger, acquisition, reorganization or sale of assets, your information may be sold or transferred as part of that transaction.
4. INFORMATION WE RECEIVE FROM THIRD PARTIES
We may receive information about you through your interactions with our affiliated companies. In addition, if you are on another website and you opt-in to receive information from us, that website will submit to us your email address and other information about you so that we may contact you as requested. You may also choose to participate in a third party application or feature (such as one of our Facebook or Twitter applications or a similar application or feature on a third party website) through which you allow us to collect (or the third party to share) information about you, including Usage Information and Personal Information such as lists of your friends, “likes”, comments you have shared, groups and location. Services like Facebook Connect give you the option to post information about your activities on our Platform to your profile page to share with others within your network. In addition, we may receive information about you if other users of a third party website give us access to their profiles and you are one of their “connections” or information about you is otherwise accessible through your “connections’” web page, profile page, or similar page on a social networking or other third party website or interactive service. We may supplement the information we collect about you through the Platforms with such information from third parties in order to enhance our ability to serve you, to tailor our content to you.
5. YOUR PRIVACY RIGHTS, CHOICE AND ACCESS
You control the Personal Information that you provide to us on the Platforms, but some Personal Information is required by us in order for you to obtain services from us or for you to use the Platforms. If you choose not to provide us with your Personal Information on the Platforms, you may not be able to take advantage of some of the services we offer or use some functionality on the Platforms. Except as provided above in section 3, we will not share Personal Information collected on the Platforms with third parties without your consent. You may also direct us to stop sending you promotional emails by following the removal instructions in a communication you receive from us. Your opt-out request will be processed within 10 business days of the date on which we receive it.
If you wish to modify, verify, correct, or delete any of your Personal Information collected through the Platforms, you may edit your registered user information or contact us via phone, mail or e-mail. In accordance with our routine record keeping, we may delete certain records that contain Personal Information you have submitted through the Platforms. We are under no obligation to store such Personal Information indefinitely and disclaim any liability arising out of, or related to, the destruction of such Personal Information. It may not always be possible to completely remove or delete all of your information from our databases without some residual data because of backups and other reasons. We will retain your information (including geo-location data) for as long as needed to provide you services. If you wish to cancel your online account or request that we no longer use your information to provide you services through the platform, contact us. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. We do not control certain privacy settings and preferences maintained by our social media partners like Facebook and Twitter. If you wish to make changes to those settings and preferences, you may do so by visiting the settings page of the appropriate social media site.
6. ADVERTISING; HOW TO OPT-OUT
The Platforms are not directed to children under 13. We do not knowingly collect, use or disclose personally identifiable information from anyone under 13 years of age. If we determine upon collection that a user is under this age, we will not use or maintain his/her Personal Information without the parent/guardian’s consent. If we become aware that we have unknowingly collected personally identifiable information from a child under the age of 13, we will make reasonable efforts to delete such information from our records.
8. SECURITY OF YOUR INFORMATION
We take information security seriously and use industry-leading physical, electronic and procedural safeguards to help protect your Personal Information. We restrict access to your personal information to personnel with a business need-to-know. We also require that any employee or business partners with whom we share your personal information protect it and use it exclusively for the purpose for which it was intended.
However, no electronic data transmission or storage of information can be guaranteed to be 100% secure. Please note that we cannot ensure or warrant the security of any information you transmit to us, and you use the Platforms and provide us with your information at your own risk.
9. OTHER SITES
The Platforms may contain links to other sites that we do not own or operate. This includes links from advertisers, sponsors and/or partners that may use our logo(s) as part of a co-branding or co-marketing agreement. We do not control, recommend or endorse and are not responsible for these sites or their content, products, services or privacy policies or practices. These other sites may send their own cookies to your Device, they may independently collect data or solicit Personal Information and may or may not have their own published privacy policies. You should also independently assess the authenticity of any site which appears or claims that it is one of our Platforms (including those linked to through an email or social networking page).
11. CONTACT US