I. Information We Collect
A. Information You Provide.
If you create a login account on our Site, the personal information that you provide includes your name and email address, and such other information as we may require. Also, if you contact us, we collect additional information such as your location, and any personal information that you provide in your contact request. We also collect your personal data when you call us on our service number. This includes information, such as your name and contact information, your phone number as well as the content of your message.
We also collect other information in the form of the content that you choose to submit during your use of our Site. For example, if you apply for or win a scholarship contest, you may be asked for information, such as high school graduation year, that InsiderPal may share with schools for which you have expressed interest. Other information that you may choose to submit when using the Site or our Site includes your age, citizenship, details of academic and work history, work place, preferences and goals related to the InsiderPal Site, test scores and other personally sensitive information entered into your user account. Likewise, if you post in a user review or opinion survey, or comment on one of our articles our blogs, the information that you post becomes public, and is a part of the information about you that we collect. This information may include your personal comments and positions on topics which could include political information and other information of a sensitive nature that you choose to submit.
B. Information Collected Automatically.
Whether or not you create an account with us, certain information that identifies you may be passively collected and stored on our or our service providers’ server logs, including your Internet Protocol (“IP”) address, browser type, operating system and information regarding what pages you accessed when you visited our Site, and when (e.g., the date and time of your visit to our Site), and the information for which you searched and which you viewed.
We also use “Cookies”, “pixel tags” and other tracking technologies to make our online services more useful to you and to tailor the experience with us to meet your special interests and needs. If you choose to disable Cookies, some aspects of our Site may perform differently, for instance, you will need to re-enter your information each time you return to use the Site.
C. Information Collected from Third Parties.
We may also collect information about you from any social network or other platform (such as from Facebook, Twitter or other third-party social network sites) that you may have connected to or from. This information includes your login and profile information, and the actual social media networks you used. Further, we may associate this personal information obtained from these sources with the other personal information we have collected about you from other sources as described in this Policy. We do not control or supervise how these third-party sources process your personal information, and any request that you have regarding the disclosure of your personal information from them to us should be made directly to those third parties (such as Facebook).
II. How We Use Your Information
For each of the categories of personal information set forth in Section I above, we use your personal information in order to provide you with a meaningful and relevant Site, which includes information about schools. In addition, we may use your personal information for the following purposes:
- to respond to any questions or comments that you submitted to us on our Site or otherwise;
- to carry out any obligations entered into between us, such as providing you with Site that you have requested;
- to notify you of changes to our Site;
- to seek your views or comments on the Site we provide and send you communications by post, e-mail or text message which you have requested or that may be of interest to you, including newsletters, or promotions of our Site or events;
- to measure the adequate performance of our interactions with you;
- to obtain or maintain insurance coverage, manage risks or obtain professional advice and defend our rights and establish, exercise and defend our legal claims;
- to facilitate your use of your web account on the Site; or
- to otherwise provide, create and maintain a trusted online environment and comply with our legal obligations.
In using your personal information, we may share some or all of it with authorized representatives of schools, work-places, and other entities that you may designate whose services relate to the Site. Please refer to Section III of this Policy below for a full description of our information sharing practices.
III. How We Share Your Information
A. Use of the Site.
We may share all categories of your personal information to selected outside companies, either by selling it or otherwise transferring it, to advertisers and other business partners that assist us in providing you with meaningful and relevant Site (each, collectively an “Advertiser”). Our Advertisers may include realtors, loan providers and other complementary service companies, schools, work places, and social media platforms such as Facebook. The sharing of your personal information with these Advertisers is conducted in accordance with the contact preferences that you set when you create your user profile, or when you express an interest in any content displayed on our Site, or when you enter a response to any affirmative authorization that you provide by typing it in a space provided or clicking on an icon designed to show your interest in an item on the web page or in the app.
In addition, any personal information you share publicly through our Site may be indexed through third party search engines, such as Google or Bing. We do not control the practices of third-party search engines, and they may use caches containing your information, including any outdated information. You acknowledge that personal information that you submit when you participate in an opinion survey or user review, a blog or any online message board that we provide through our Site or Site may be available, via the Internet, around the world. We cannot prevent the disclosure to or use (or misuse) of such personal information by others, nor can we ensure it is deleted if you later ask us to delete your personal information as provided for in this Policy.
B. Third Party Processors.
We also share all categories of your personal information with other business partners that perform certain functions for us (“Business Partners”). These Business Partners are themselves responsible to determine the purposes and/or means of the processing your personal information and for the lawfulness of that processing. They include insurance companies, financial institutions, and other professional advisors.
C. Third Party Websites.
D. De-identified information About You.
We also share aggregated or de-identified information (i.e., information that does not personally identify you directly), or statistical information about you, including statistical data and historical use data, with others for a variety of purposes, including for their own uses, for example, for improving their services for you and others.
E. As Required by Law or Business Interest:
IV. Your Options to Opt-Out
You have the right to request that we do not sell your personal information to Advertisers.
IF YOU LIVE IN CALIFORNIA – When you first come to our Site, you will be given the option to click on a “Do Not Sell My Information” button on our landing page. If you click this button, we will not sell your identifiable personal information to Advertisers. We may still sell de-identified information about you, but the Advertisers will not be able to trace this information back to you or use it to market their products and services specifically to you. To opt-out, you may submit your request to firstname.lastname@example.org and putting the words “remove my name” in the subject line of your email, and a request to opt-out in the body of the email.
NO MATTER WHERE YOU LIVE – If you do not initially opt-out or at some point after giving us your personally identifiable information you later decide to limit the sale of your information to our third party Advertisers, or you no longer desire to continue to receive additional information from us about InsiderPal and our Advertisers, you may “opt out” by submitting your request by emailing us at email@example.com and putting the words “remove my name” in the subject line of your email and a request to opt-out in the body of the email. Please note however that an Advertiser may have saved a copy of your account and account-related information from before you opted out. In the case of our email newsletters, you may opt out by clicking on the “unsubscribe” link at the end of each email. If you agree to receive autodialed or pre-recorded calls and/or text messages from an Advertiser and later wish to opt-out, you should follow the direction in such call(s) or text message(s) or contact the school or other
Advertiser directly.Please note, you cannot opt out of our sharing of your personal information with our Processors or Business Partners, or our sharing of de-identified information, or your personal information as required by law or legitimate business interests, as described in Sections III. B., D., and E. above. With respect to information captured and shared through cookies, pixel tags and other tracking technologies, and your ability to limit the sharing of your information through those channels. Also, if you opt out of receiving marketing-related emails from us, we may still send you important administrative messages, from which you cannot opt out.
A special note about your telephone number – By providing your telephone number to us, you agree that this action constitutes an “inquiry” for purposes of telemarketing laws. Regardless of the fact that your telephone and/or mobile number may be listed with the Federal Do-Not-Call Registry or your State Do-Not-Call list, you are providing your express written consent to receive future information (including telemarketing) about products and services from us, and you hereby agree and consent to our contacting you using the information you have provided and will provide to us. This means we may contact you by e-mail, phone and/or mobile number (including use of automated dialing equipment and/or pre-recorded calls), text (SMS) message, social networks or any other means of communication that your wireless or other telecommunications device may be capable of receiving (e.g., video, etc.). You are not required to agree to this consent in order to obtain services through us. This consent may be revoked by you at any time and by any reasonable means, including by emailing us at firstname.lastname@example.org and putting the words “remove my telephone number” in the subject line of your email. Please refer to the InsiderPal User Agreement for additional information regarding telephone consent.
Special rule for users under 16 years of age – So long as we have actual knowledge that you are under the age of 16, we will not sell your personally identifiable information to our Advertisers unless you “opt in” by requesting us to do so. You can opt in to information sharing with Advertisers by requesting that we share your information with schools or related entities for which you have expressed an interest or with parties that you wish to be considered for a scholarship. We may ask you or the person acting on your behalf (e.g., a parent or legal guardian) to verify your identity. Likewise, any public information that you post on the Site, including user reviews or opinion surveys, are considered public and you will be considered to have opted in to the sharing of such public information. You may also request that we share your personally identifiable information with our Advertisers by contacting us at email@example.com, and telling us that you wish to opt in.
V. Cross-Border Information Transfer
VIII. Limitation of liability
IX. Contact Information Us
X. Privacy of Children
Children under the age of 13 are not permitted to use the InsiderPal Site or Site and we do not intentionally collect or maintain personal information from those who are under 13 years old. Protecting the privacy of children is very important to us. Thus, if we obtain actual knowledge that a user is under 13, we will take steps to remove that user’s personal information from our databases. We recommend that children between the ages of 13 and 18 obtain their parent’s permission before submitting information over the Internet. By using the InsiderPal Site or Site, you are representing that you are at least 18 years old, or that you are at least 13 years old and have your parents’ permission to use the website and any Site offered by us.
XI. NOTICE TO CALIFORNIA RESIDENTS – YOUR CALIFORNIA PRIVACY RIGHTS
The following sets forth the categories of information we collect and purposes for which we may use a California Consumers’ personal information collected by us:
Categories of Personal Information We Collect About You:
The categories of personal information we may have collected about you or your use of our Site are:
- Identifiers, such as your name, alias, postal address, phone number, email address, log-in information, or unique personal identifiers (such as device ID, cookies, and IP address);
- Commercial information (such as Site engagement data);
- Protected classification characteristics;
- Internet or other network or device activity (such as browsing or search history or app usage, and advertisement interactions);
- Geo-location information relating to your computer or device when you interact with the Site;
- Professional or employment related information that you supply;
- Education information that you supply;
- Profile data about you and any inferences drawn from the profile data (such as characteristics, behaviors, attitudes);
- Information that identifies or can be reasonably associated with you.
In the past 12 months we have sold the information listed in the above categories to our Advertisers. We do not sell the personal information of California Customers that we know are minors under 16 years of age without affirmative authorization as required under the CCPA. Additionally, during this time period we have also disclosed all or substantially all of this personal information to our Processors and Business Partners for permissible business reasons.
Categories of Sources from Which We Collected Personal Information
The sources from which we may have collected personal information about you or your use of the Site are:
- Directly from you;
- From other sources (such as from third parties and/or business partners);
- Through your use of the Site; and
- Publicly available records.
and as described in more detail in the Information We Collect section above.
Your California Privacy Rights
A California Customer may request information about whether we have sold or disclosed personal information to any third parties for the third parties’ direct marketing purposes or for our business purposes. In general, if we have made such a sale or disclosure of your personal information, upon receipt of a verified request from you, we are required to provide a list of all third parties to whom your personal information was either sold or disclosed for business purposes in the preceding 12 months following your request, as well as a list of the categories of personal information that were sold or disclosed, the sources of it, and what it was used for. You may also request a copy of the personal information that we have collected about you in the last 12 months.
You may have certain additional rights under the CCPA. You may request that we delete certain information we have about you. There may be exemptions from such requests under applicable law. For example, we need certain types of information so that we can provide the Site to you and for compliance with applicable law. You may also have the right to receive information about the financial incentives that we offer to you (if any). You also have the right to not be discriminated against (as provided for in applicable law) for exercising certain of your rights under the CCPA. This means that we will not penalize you for exercising your rights by taking actions such as denying you services; decreasing service quality; or suggesting that we may penalize you for exercising your rights. Except as provided in Section III, above, we do not share your personal information collected by us with third parties for their direct marketing purposes without giving you the opportunity to opt out as more fully described above in Section IV.
If you are a California resident, you may request information about our compliance with California law by emailing us at firstname.lastname@example.org. Any such request must include “California Privacy Rights Request” in the subject line and include your name, street address, city, state and ZIP code. Please note that we are only required to respond to up to two requests per visitor each year, and we are not required to respond to requests made by means other than through this designated email address.
Identity Verification and Additional Information to Needed to Process a Request. We reserve the right to confirm your California residence to process your requests and will need to confirm your identity to process your requests to exercise your information, access or deletion rights. As part of this process, government identification may be required. California Customers can empower an “authorized agent” to submit requests on their behalf. We will require the authorized agent to have a written authorization recognized by law confirming that authority. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it or to verify your or your agent’s identity.
Do Not Track Disclosure. California Business & Professions Code Section 22575(b) provides that California residents are entitled to know how InsiderPal responds to “Do Not Track” browser settings. We currently do not respond to “Do Not Track” signals because a uniform technological standard has not yet been developed.
XII. Nevada Privacy Rights
FOR RESIDENTS OF NEVADA ONLY. In accordance with SB 220, Nevada consumers may opt-out of the sale of their personal information to third parties, as provided by law. If you reside in Nevada and you have provided us with your personal information, you may choose to opt-out of the sale of such personal information by emailing us at email@example.com with “Nevada Privacy Right” in the subject line. We may request additional information from you in order to verify your identity and/or the authenticity of your request. For purposes of this opt-out, a “sale” of your personal information means an exchange of it by us to another party for money and the other party buys it from us for re-sale to a third party.