This Master Privacy Policy (“Privacy Policy”) explains the collection, use, and disclosure of “personal information” by Student Data Privacy Services (“SDPS”), a Texas Limited Liability Company. Unless otherwise noted on a particular site or service, this Privacy Policy applies to your use of all websites that SDPS operates (collectively, the “Websites”), as well as the products, information, and services provided through the Websites, (together with the Websites, the “Services”).
In addition, supplemental Privacy Policy terms (“Supplemental Privacy Policy Terms”) may apply to a particular Service.
This Privacy Policy also explains our commitment to you with respect to our use and disclosure of non-personal browsing and site usage data that SDPS collects as the provider of the Services. That commitment is contained in a “Data Usage Policy,” below.
As used in this policy, “personal information” means information that would allow a party to identify you such as, for example, your name, address or location, telephone number, or email address.
By accessing the Websites or using any of the Services, you are accepting and agreeing to the practices described in this Privacy Policy.
Our Principles
SDPS is committed to handling responsibly the information and data we collect about you through our Services, whether personal information or non-personal browsing and site usage data. We have designed our Privacy Policy and our Data Usage Policy consistent with the following principles (the “Principles”):
- Privacy policies and data collection and use policies should be human readable, comprehensive, and easy to locate;
- Only the minimum amount of information reasonably necessary to provide you with services should be collected and maintained, and only for so long as reasonably needed or required;
- Information you provide through our Services, or that we gather as a result of your use of our Services, should not be provided voluntarily (without your permission) to anyone else unless required; and
- If SDPS is required to provide a third party with your personal information (whether by subpoena or otherwise), then provided we have collected and retained an email address for you, SDPS will use reasonable means to notify you promptly of that event, unless prohibited by law or SDPS is otherwise advised not to notify you on the advice of legal counsel.
Personal Information SDPS Collects
We may collect personal information through our Website or Services, including without limitation:
- when you provide us with your personal information such as by sending an email to us, submitting a form, posting a comment, or signing up to receive updates;
- when you subscribe to one of our email discussion lists; or
- when you purchase merchandise or Services.
What SDPS Does with Personal Information
We use the personal information you provide to us when you send us emails or sign up to receive updates from SDPS or any of our Websites in order to respond to your request – for example, to reply to your email or to send you communications about SDPS news and campaigns.
When you subscribe to updates from us or submit a form on the web site, your email address is sent to and stored in a database that can only be accessed by SDPS staff and contractors.
When you purchase merchandise or Services, your personal information will be used for the purpose of sending you the items you purchased or providing the purchased Services.
Disclosures of Personal Information
In general, it is not SDPS practice to disclose personal information to third parties. We may share your personal information in two instances:
- First, SDPS may share personal information with our contractors and service providers in order to maintain, enhance, or add to the functionality of the Services.
- Second, we may disclose your personal information to third parties in a good faith belief that such disclosure is reasonably necessary to (a) take action regarding suspected illegal activities; (b) enforce or apply our Master Terms of Use and/or Privacy Policy; (c) comply with legal process, such as a search warrant, subpoena, statute, or court order; or (d) protect our rights, reputation, and property, or that of our users, affiliates, or the public. If SDPS is required to provide a third party with your personal information (whether by subpoena or otherwise) then provided we have collected and retained an email address for you, SDPS will use reasonable means to notify you promptly of that event, unless prohibited by law or SDPS is otherwise advised not to notify you on the advice of legal counsel.
Security of Personal Information Collected via the Services
SDPS has implemented reasonable measures to protect against unauthorized access to and unlawful interception or processing of personal information that SDPS stores and controls. However, no website can fully eliminate security risks. Third parties may circumvent our security measures to unlawfully intercept or access transmissions or private communications.
Data Usage Policy: Non-Personal Browsing and Site Usage Information
Our Data Usage Policy covers how we maintain and use information about you that is collected by our Services or Websites.
Non-Personal Browsing Information We Collect
When you use the Services, our servers (which may be hosted by a third party service provider) may collect information indirectly and automatically (through, for example, the use of your “IP address”) about your activities while visiting the Websites and information about the browser you are using.
No Linking
We do not intentionally link browsing information or information from our OpenID or CCID server logs to the personal information you submit to us. We use this information for internal purposes only, such as to help understand how the Services are being used, to improve our Services, and for systems administration purposes. SDPS may use a third party analytics provider to help us collect and analyze non personal browsing information through operation of our Services for those same purposes.
No Selling or Sharing
Except in the unique situations identified in this Privacy Policy, SDPS does not sell or otherwise voluntarily provide the non-personal browsing information we collect about you or your website usage to third parties.
Reorganization or Spin-Offs
SDPS may transfer some or all of your personal and/or non personal browsing information to a third party as a result of a reorganization, spin-off, acquisition or similar transaction. Upon such transfer, the acquirer’s privacy policy will apply. In such event, SDPS will use reasonable efforts to notify you and to ensure that at the time of the transaction the acquirer’s privacy policy complies with the Principles.
Children
The Services are not directed at children under the age of 13. Consistent with the federal Children’s Online Privacy Protection Act of 1998 (COPPA), we will never knowingly request personal information from anyone under the age of 13 without requiring parental consent. Our Master Terms of Use specifically prohibit anyone using our Services from submitting any personally identifiable information about persons under 13 years of age. Any person who provides their personal information to SDPS through the Services represents that they are 13 years of age or older.
Third-Party Sites
The Services may include links to other websites. You should consult the respective privacy policies of these third-party sites. This Privacy Policy does not apply to, and we cannot control the activities of, such other websites.
Special Note to International Users
The Services are hosted in the United States. Please note that your personal data may be located on servers in the United States. By providing your personal data you consent to the use of your personal data for the uses identified above in accordance with the Privacy Policy.
Changes and Updates to this Privacy Policy
We may occasionally update this Privacy Policy. When we do, we will also revise the Effective Date below. We encourage you to periodically review this Privacy Policy to stay informed about how we are protecting the personal information we collect. Your continued use of the Services constitutes your agreement to this Privacy Policy and any updates.
Using this Privacy Policy for Your Own Purposes
This privacy policy is based on the Creative Commons Privacy Policy, which is dedicated to the public domain under the Creative Commons CC0 Public Domain Dedication. You are free to use and adapt this Privacy Policy and any applicable Supplemental Privacy Policy Terms for your own purposes. However, please keep in mind that this Privacy Policy may not be completely suitable for your situation. Creative Commons strongly encourages you to seek the advice of your own attorney before repurposing this Privacy Policy on your own site.
The effective date of this privacy policy is September 1, 2015.
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