PRIVACY POLICY

Effective March 1, 2015

Graduation Alliance, Inc ("Graduation Alliance," "we," or "us") has established this Privacy Policy to let you know how we collect, use, share, and protect information that we may gather from the technology, software, systems, and websites that support our operations (collectively referred to as the "Site") or that is provided to us by you or third parties. This Privacy Policy does not apply to information that we may collect from you outside of our Site, such as over the phone, by fax, or through conventional mail. This Privacy Policy does not apply to the practices of companies that Graduation Alliance does not own or control or to people that Graduation Alliance does not employ or manage.

NON-PERSONAL AND AGGREGATED INFORMATION COLLECTED AUTOMATICALLY

Each time you visit our Site, we log non-personal information that your browser automatically transmits to us. We may also use third-party website analytics tools (such as Google Analytics) that collect information about user interactions with the Site. Such information may include your IP address, operating system and browser type, domain name, the name of the Web page from which you entered our website, which pages you visit on our website, and how much time you spend on each page. We use this information to monitor and improve our website and for internal analysis. In particular, we use IP addresses to analyze trends, administer the Site, and gather information for aggregate use. However, IP addresses are not linked to personal information.

USE OF COOKIES

Our Site may use "cookies" to help personalize your online experience. A cookie is a text file that is placed on your hard disk by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you. We use cookies to keep track of how you are using our Site and to tailor our content to your interests. Graduation Alliance cookies do not contain any personal information about students enrolled in Graduation Alliance's educational programs. We will not share or sell non-aggregated information contained within cookies to any third party. The cookies we use are erased when you log off the Site or completely close your browser.

PERSONAL INFORMATION YOU PROVIDE

You can use portions of our Site without divulging any personal information, including your e-mail address. Our Site does not collect personal information about individuals except when such individuals specifically provide such information on a voluntary basis (for example, enrolling in a school and registering for classes; requesting a catalog; requesting additional information by contacting us; posting a message to a message board; requesting help; or accessing, adding to, or changing the information on your account information page on the Site). When you register yourself or children for whom you are the parent or legal guardian for a Graduation Alliance program or participate in a Graduation Alliance program, we may collect information regarding you and your children, as applicable. This personal information may be collected on our Site or collected via telephone or conventional mail. The types of information that you may be asked to provide, depending on what services you would like to receive, may include without limitation: your first and last name and age; billing address; the names and ages of your children; registration and enrollment information about your children, if applicable; and an e-mail address where we can contact you. Once you have registered yourself or your children for a Graduation Alliance program (whether you registered on our Site or through offline communications), there is an online service for all such programs. There will be a personal information page on the Site that contains some or all of your personal information.

You may also be assigned a User ID and password and may create, at your discretion, a User ID for your children over 13 years of age any time you are logged on to the Site. The User ID will allow Graduation Alliance to recognize: your or your child's first and last name; registration ID; type of account, such as teacher, administrator, parent, or student; school affiliation or the Graduation Alliance program in which you or your children are enrolled; and the e-mail address you provided. The User ID and the Site will also allow you to track your or your children's attendance, school work, and testing, and to submit relevant portions of same to Graduation Alliance and/or partnering educational agencies and institutions to track your or your children's progress and abide by state and/or federal standards and regulations. Graduation Alliance will not disclose your password to any third party, except as may be required by law or as otherwise described in this Privacy Policy or the Graduation Alliance Terms of Use at http://www.graduationalliance.com/terms-of-use.html

STUDENT RECORDS

Graduation Alliance also collects personal information made available to Graduation Alliance by contracting educational agencies and institutions, such as student names, student identification numbers, e-mail addresses, GPA, grades, courses taken, standardized test scores, and related information.

Graduation Alliance operates in compliance with federal and state school privacy laws, including The Family Educational Rights and Privacy Act of 1974 (20 U.S.C. § 1232g; 34 CFR Part 99) ("FERPA"). FERPA is a federal law that protects the privacy of student educational records, and applies to all schools receiving federal funding. With certain exceptions, this law prohibits schools from releasing personal information of students under the age of 18 without parental consent. By designating Graduation Alliance as a "school official" and/or a designated contractor with a "legitimate educational interest," educational agencies and institutions are permitted to share personal information with Graduation Alliance without express, parental consent under the exception provided by 34 CFR § 99.31(a)(1). You may find out more information about FERPA at http://www.ed.gov/policy/gen/guid/fpco/ferpa/index.html.

The classification as a "school official," or as a contracted company with a "legitimate educational interest" is described by the Family Policy Compliance Office ("FPCO"). The FPCO's FERPA policy and advisory materials on this issue can be found at http://www.ed.gov/policy/gen/guid/fpco/index.html and http://www.ed.gov/policy/gen/guid/fpco/ferpa/lea-officials.html.

HOW WE USE INFORMATION WE COLLECT

PERSONAL INFORMATION ABOUT YOUR CHILDREN (if applicable)

Graduation Alliance only receives personal information about your children as set forth in the "Student Records" section above and/or directly from you when you enroll your children into a Graduation Alliance program. If your children are enrolled in a Graduation Alliance program, we will collect, use, and maintain personal information about your children solely (i) to provide Graduation Alliance programs to them and for other authorized educational purposes, and/or (ii) as otherwise authorized by you.

You can review certain personal information that Graduation Alliance has regarding your children by making such a request in writing to privacy@graduationalliance.com. Please be aware that some personal information relating to your children's educational records may not be able to be disclosed by Graduation Alliance due to state and/or federal law. You can request that your children's personal information not be used by Graduation Alliance and contractors and service providers acting on behalf of Graduation Alliance by making a request in writing to privacy@graduationalliance.com. Please be aware that if you make such a request, your children can no longer continue to be enrolled in a Graduation Alliance program or to use most features on our Site. Therefore, a request by you for Graduation Alliance and our contractors and service providers to no longer use your children's personal information will terminate your children's participation in the Graduation Alliance program in which they are enrolled.

YOUR PERSONAL INFORMATION

Graduation Alliance may use your personal information to:

  • Contact you about your or your children's participation in a Graduation Alliance program and for other customer service purposes;
  • Provide you with resources, products, and services, including but not limited to support services related to your use of the Site, that you request from us;
  • Provide you with information about new products and services available through Graduation Alliance and resources and support services related to your use of the Site, if you choose to receive such information. If you have opted in to receive such information, you can request to opt out of receiving this information in the future by making a request in writing to privacy@graduationalliance.com;
  • Automatically fill out certain forms and surveys upon your instructions to do so, such as:
    • Applications for admission;
    • Financial aid applications;
    • Freshman and transfer planners, which can assist you in selecting courses and otherwise planning to meet admission requirements; and
    • Requests for information or material from colleges or other institutions you specify.
      Unless expressly instructed or authorized by you, these forms and surveys are not disclosed to third parties;
  • Help diagnose problems with and administer our Site;
  • Carry out our obligations and enforce our rights arising from any contracts entered into between you and us; and
  • Comply with applicable legal requirements and industry standards.

We may aggregate your information with the information of other users for our own internal statistical, design, and/or operational purposes, such as to estimate our audience size, measure aggregate traffic patterns, and understand demographic, customer interest, and other trends among our guests and customers. This aggregate information generally will not personally identify you or be correlated to you individually for external purposes.

We also may use the information we obtain about you in other ways for which we provide specific notice at the time of collection.

INFORMATION WE SHARE

We may collect, compile, store, publish, promote, report, sell, or otherwise disclose or use any and all aggregate information, provided that, such information does not personally identify you. When we share such information with other companies, or with contracting schools, it is not traceable to any particular user, and will not be used to contact you.

We do not sell or otherwise disclose personal information except as described in this Privacy Policy. Graduation Alliance will not disclose your personal information or personal information about your children to third parties except:

  • If you authorize Graduation Alliance to do so;
  • To contractors, service providers, and other third parties we use to support our business for the purposes described in this Privacy Policy. Such third parties are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them;
  • To enforce or apply our Terms of Use and other agreements; and/or
  • As required by law and when Graduation Alliance believes the disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, or legal process served on our Site. Graduation Alliance will supply such information, based on the advice of counsel, that Graduation Alliance is legally required to supply.

MESSAGE BOARDS AND CHATS

We may offer Graduation Alliance message boards and chat rooms to all students on our Site. Please be aware that anyone may read your or your children's postings on a message board or in a chat room. Furthermore, any information which you or your children submit to be posted to a message board or in a chat room, including your information from your account information page and User ID, will be disclosed and available to all users of that message board or chat room, and is therefore no longer private. We cannot guarantee the security of such information that you or your children disclose or communicate online in public areas such as message boards and chat rooms, and you do so at your own risk. Please be aware that whenever you voluntarily post public information to the Site, that information can be accessed by the public and can in turn be used by those people to send you unsolicited communications. We reserve the right to monitor the content of the message boards and to republish your postings from message boards or chat rooms elsewhere on the Web or otherwise in any format. As a parent of a student enrolled in the Graduation Alliance program, we encourage you to monitor your child's postings.

If any of our message boards or other interactive features that allow registered users to post content or information on the Site are directed to California residents under the age of 18, or if we have actual knowledge that registered users of such services are California residents under the age of 18, we will permit such registered users to remove, or request and obtain the removal of, content or information such registered users post on our Site to the extent required by California Business and Professions Code § 22581. If you are a California resident under the age of 18 and would like to remove content or information you have posted on our Site, please contact us at privacy@graduationalliance.com.

LINKS

The Site may contain links to other websites, chat rooms, or other resources that we provide for your convenience ("Linked Sites"). Linked Sites are not under the control of Graduation Alliance, and Graduation Alliance is not responsible for the content available on any Linked Site. Such links do not imply Graduation Alliance's endorsement of material on any Linked Site, and Graduation Alliance expressly disclaims all liability with regard to your access to such Linked Sites. Access to any Linked Site is at your own risk.

OUR COMMITMENT TO DATA SECURITY

We use industry standard practices designed to safeguard the confidentiality of your personal information and personal information about your children . To prevent unauthorized access, maintain data accuracy, and ensure the correct use of such information, we have put in place physical, electronic, and managerial procedures designed to safeguard and secure the personal information we collect. We also use 128-bit Secure Sockets Layer (SSL) protocol to protect information when route between your browser and Graduation Alliance's server and when in route between Graduation Alliance's server and another other browser or server.

Personal information residing on Graduation Alliance's servers is password protected, and access is provided only to those employees of Graduation Alliance who require such access to administer and maintain our Site or to provide requested customer support to users of the Site. Each Graduation Alliance employee who has access to the data residing on our servers has agreed in writing to respect the privacy of all such personal information.
 
CHANGES IN CORPORATE STRUCTURE

Notwithstanding any other provision of this Privacy Policy, any information Graduation Alliance receives from you or from third parties is an asset of Graduation Alliance and may be transferred if all or part of Graduation Alliance is sold, merged, consolidated or otherwise transferred to another entity as part of that transaction or process. Should such a sale, merger, or transfer occur, Graduation Alliance will give users reasonable notice and an opportunity to remove personal information from the Site. In any event, Graduation Alliance will take steps to ensure that the transferee will use personal information in a manner consistent with and will otherwise abide by the version of the Graduation Alliance Privacy Policy under which it was collected. FERPA protects your children's educational records in the event of such a transaction.

YOUR CHOICES

We offer you the following choices about what information we collect from you and how we communicate with you:

Cookies. You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If, however, you choose to decline cookies, you may not be able to fully experience the interactive features of our Site or have some of our services on the Site function properly.

Marketing Emails. If we have sent you a marketing email, you may choose not to receive additional marketing emails from us by following the unsubscribe instructions contained in each email.

Web Analytics. You may opt-out of the aggregation and analysis of data collected about you on the Site by our web analytics vendor by visiting https://tools.google.com/dlpage/gaoptout and downloading and installing the Google Analytics Opt-out Browser Add-on.

MODIFYING, CORRECTING, OR DELETING YOUR INFORMATION

You may update, otherwise modify or delete any personal information you previously provided on the Site by logging onto the Site and accessing either your user profile or an application containing the information you want to change. Please note that if you delete information, it will no longer be available on the Site.

If you are unable to change your personal information as provided above, wish to delete or modify personal information provided to Graduation Alliance by third parties, or wish to delete your account from the Graduation Alliance system, you may email us at privacy@graduationalliance.com.

CHILDREN UNDER THE AGE OF 13

The Site is not directed to children under the age of 13 and does not permit registration by, and will not knowingly collect or use personal information from anyone under 13 years of age. We require users to be at least 13 years of age to use the Site. If we learn we have collected or received personal information from a child under the age of 13, we will delete that information. If you believe we might have any information from or about a child under the age of 13, please contact us at privacy@graduationalliance.com.

CHANGES TO THE PRIVACY POLICY

We will occasionally amend this Privacy Policy to reflect company and customer feedback. We reserve the right to change, modify, add, or remove portions of this Privacy Policy at any time. If Graduation Alliance materially changes its use of your or your children's personal information, we will announce such a change on our Site and will also note it in this Privacy Policy, and we will provide you with an opportunity to opt out of such new or different use. The effective date of this Privacy Policy is documented at the beginning of the Privacy Policy. You are responsible for periodically reviewing the Site and this Privacy Policy to check for any updates or changes.

ENFORCEMENT

Graduation Alliance is committed to ensuring the integrity and security of user information. Graduation Alliance reserves the right to pursue all legal remedies available to it in the event that its security measures and/or this Privacy Policy is breached, including but not limited to pursuit of all criminal and civil law enforcement proceedings available as of the occurrence of any breach. Should you believe that your data has been released or used in a way that is contrary to your rights or this Privacy Policy, please contact us at privacy@graduationalliance.com.

CONTACT US

If you have any questions about Graduation Alliance's Privacy Policy, please contact us in writing at privacy@graduationalliance.com or at:

Graduation Alliance, Inc.
10 W Broadway, Suite 700
Salt Lake City, UT 84101