Privacy Policy

#Privacy Policy

Last revised: February 14, 2022

Scholarship Services, Inc. (“we,” “us,” “our”) respects the privacy of its customers and visitors (“you”) and is committed to maintaining the privacy and confidentiality of your information including your personal information (collectively, “information”). This Privacy Policy explains what information we collect about you on our website(s) (“Site”) and through other internet-based mechanisms (e.g., email and social media), our online and mobile applications, and our services generally (collectively, “Services”), how we use and disclose such information, and the safeguards we have in place to reduce the risk of unauthorized access and use of such information. We offer various products and services including ScholarshipOwl and ScholarshipApp. How we collect, use, and disclose your information will vary based on your relationship with us, the Site(s) you visit, and the Services you use.

This Privacy Policy also provides information about information we process as a service provider to scholarship providers and other organizations (“Clients”).

By visiting our Site and/or using our Services, you accept our privacy practices described in this Privacy Policy. This Privacy Policy is also a part of our Terms of Use.

Table of Contents

1 - PRIVACY POLICY CHANGES 2 - INFORMATION WE COLLECT AS A BUSINESS a. Personal Information b. Sensitive Personal Information c. Business Information d. Usage Data e. Communication Recording 3 - HOW WE COLLECT INFORMATION AS A BUSINESS a. Voluntary Disclosure b. Third-Party Data Sources c. Cookies d. Information from Advertisements and Affiliate Marketers e. Tracking Pixels and Clear GIFs f. Social Media Widgets 4 - HOW WE USE AND SHARE INFORMATION AS A BUSINESS a. Generally b. Testimonials & Submissions c. Service Providers d. Third-Party Selling e. Mail & Email Marketing 5 - SECURITY 6 - BLOGS, FORUMS, TESTIMONIALS 7 - OTHER WEBSITES 8 - COMPLIANCE WITH LAWS AND LAW ENFORCEMENT 9 - OTHER TRANSFERS 10 - HOW LONG WE RETAIN YOUR DATA 11 - CHILDREN’S PRIVACY 12 - PERSONAL INFORMATION WE COLLECT AS A SERVICE PROVIDER FOR OUR CLIENTS 13 - CONTACT US 14 - ADDITIONAL CALIFORNIA CONSUMER RIGHTS a. Right to Know b. Right to Deletion c. Right to Opt-Out from the Sale of Personal Information d. Authorized Agent e. Non-Discrimination Notice f. California “Do Not Track” Disclosure g. California Site Ownership Disclosure 15 - ADDITIONAL NEVADA CONSUMER RIGHTS

1. PRIVACY POLICY CHANGES

This Privacy Policy is subject to change. We encourage you to review this Privacy Policy frequently for any revisions or amendments. Such changes to this Privacy Policy will be posted on the Site and will be effective immediately upon posting. You will be deemed to have been made aware of and have accepted the changes by your continued use of the Site or Services after the changes have been posted.

2. INFORMATION WE COLLECT AS A BUSINESS

a. Personal Information

We collect information that personally identifies, relates to, describes, or is capable of being associated with you (“Personal Information”), including:

  • Personal Identifiers (e.g., name, date of birth, social security number, email address, mailing address, IP address, login username & password, links to social media profiles)
  • Personal Characteristics of Protected Classifications (e.g., gender, ethnicity, citizenship, military affiliation)
  • Education Information (e.g., high school name, college name, grade point average, career goals, field of study, grade level, major, essays, transcripts, recommendation letters)
  • Commercial Information (e.g., payment method, subscription history, transaction history, scholarship history, donation history)
  • Internet or Other Electronic Network Activity (e.g., device information such as operating system and browser type, email system data such as inbox and outbox content, affiliate marketing data such as transaction ID and offer ID, device type, other technical information regarding your use of our Site/Services that can be associated with you)
  • Professional or Employment-Related Information (e.g., occupation)
  • Audio & Visual Data (e.g., photos, videos)
  • Approximate Geolocation Data (city)
  • Inferences drawn from the above categories of Personal Information that relate to your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

The types of Personal Information we collect about you may vary based on how you use our Site(s) and/or Services.

b. Sensitive Personal Information

We collect limited amounts of Personal Information that may be deemed “sensitive” under applicable laws and regulations including: ethnicity, citizenship, and the content of messages sent to or received from third parties via our services. We use this sensitive Personal Information to assist in scholarship matching and to provide our Services to you. We may disclose sensitive Personal Information to our Service Providers (described below). We may also sell ethnicity and citizenship information as personal characteristics of protected classifications to the extent described more fully below.

c. Business Information

We also collect information about businesses and their representatives that engage with us such as EIN, TIN, name, address, phone number, email address, bank account information, and employee ID number (collectively, “Business Information”). This information is generally not considered Personal Information because it relates to a business or a business contact.

d. Usage Data

We automatically collect information in connection with the actions you take on a Site and in connection with using the Services (“Usage Data”). For example, each time you use a Site, we automatically collect your IP address, location, hardware settings, browser type and settings, time and duration of your connection, and other device information. We use this information to improve the performance and functionality of our Site(s) and Services, and to better understand how individuals interact with our Site(s) and Services. If this information is capable of being associated with you, directly or indirectly, we treat it as Personal Information. If this information is not capable of being individually associated with you, we treat it as Usage Data.

e. Communication Recording

We and/or our Service Providers (as defined below), may record calls and retain the content of chat conversations or other written/electronic communications between you and us and/or our Service Provider. By communicating with us and/or our Service Provider, you consent to such recording and retention of communications.

3. HOW WE COLLECT INFORMATION AS A BUSINESS

a. Voluntary Disclosure

We may ask you to provide us with Personal Information when you register with our Site(s)/Services, purchase a service, complete a scholarship application, claim a scholarship, leave a testimonial, communicate with us (online or offline), and at other times. You are not required to provide us your Personal Information; however, if you choose not to provide the requested information, you may not be able to use some or all of the features of the Site or Services or we may not be able to fulfill your requested interaction.

b. Third-Party Data Sources

We collect Personal Information from third-party data sources such as market research firms, scholarship sponsors or providers, tutoring and essay services, college placement and employment assistance services, social media, and data brokerage companies. This Personal Information may be appended to Personal Information we have already collected from or about you.

c. Cookies

We use cookies (a small text file placed on your device to identify your device and browser) to improve the experience of a Site and Services, such as keeping track of your activities on the Site, recognizing return visitors, and analyzing our promotions and Site traffic. Some third parties who advertise on our Site(s) may also use cookies similar technologies. Many web browsers are initially set up to accept cookies. You can reset your web browser to refuse all cookies or to indicate when a cookie is being sent. Instructions for how to manage cookies in popular browsers are available at: Internet Explorer, Firefox, Chrome, Safari (iOS), Safari (Mac), and Opera. However, certain features of our Site(s) or Services may not work if you delete or disable cookies.

We use the following types of cookies:

  • Session Cookies: Session cookies keep track of you or your information as you move from page to page within the Site/Services and are typically deleted once you close your browser.
  • Persistent Cookies: Persistent cookies reside on your system and allow us to customize your experience if you leave and later return to the Site/Services. For example, persistent cookies may allow us to remember your preferences.
  • Strictly Necessary Cookies: Strictly necessary cookies are, as their name suggests, necessary for the operation of the Site and/or Services. These are cookies that facilitate our compliance with laws, allow us to verify your identity before you access restricted areas of the Site/Services, manage our network, or keep track of user input.
  • Advertising Cookies: Advertising cookies are used to learn more about you and advertise our or another person’s products/services that might interest you.
  • Analytics Cookies: Analytics cookies help us understand how our Site and Services are working and who is visiting our Site or using our Services. Google Analytics is one tool we use, and you can learn more by reviewing Google’s Privacy Policy.

Depending on the circumstances, we may use cookies to collect Personal Information, Usage Data, or both.

d. Information from Advertisements and Affiliate Marketers

If you arrive at a Site via an advertisement (e.g., banner ad) or an affiliate marketer, we may collect information regarding the advertisement or affiliate marketer with which you interacted and your interactions (e.g., item clicked, date, time, offer ID, affiliate ID).

Some third parties who advertise on our Site(s) may also use cookies and similar technologies. For example, third-party remarketers, including Google, AdRoll, AdSense, HasOffers, and Facebook use cookies to serve ads based on a user’s prior visits to our website(s). Google’s use of advertising cookies enables it and its partners to serve ads based on visits to our Site(s) or other sites on the internet. Information collected by these third-party companies from uses of the Site or Services is governed by their respective privacy policies. You can opt out of Google’s personalized advertising by visiting Google’s Ads Settings. Alternately, you can opt out of many other third-party vendors’ use of cookies by visiting the Digital Advertising Alliance’s (DAA) opt out page at http://www.aboutads.info/choices or http://www.aboutads.info/appchoices. You may also set your browser to refuse or delete cookies after a period of time. To find out more about how Google uses data it collects please visit Google Privacy & Terms.

e. Tracking Pixels and Clear GIFs

We employ software technology that enables us to track certain aspects of a user's visit to a Site. This technology helps us better manage content on the Site(s) by informing us what content is effective, how consumers engage with the Site(s), and how consumers arrive at and/or depart from the Site(s). The software typically uses two methods to track user activity: (1) "tracking pixels" and (2) "clear gifs." Tracking pixels are pieces of executable code that are embedded in a web page that track usage activity including which pages are viewed, when they are viewed, and how long the pages are viewed. We utilize tracking pixels provided by third-party social media platforms such as Pinterest, Facebook, and TikTok. Clear gifs are tiny graphics with unique identifiers which are embedded in web pages and email messages that track whether or not a user has viewed a particular web page or email message. User activity information may be associated with additional information about a user's session, such as IP addresses and the type of browser used, and Personal Information, if provided by the user.

If you arrive at a Site by "clicking through" from another website, then certain information about you that you provided to that other website, such as the terms you were searching that led you to that Site, may be transmitted to us and we may use it. You should review the Privacy Policy of any website from which you reached a Site to determine what information was collected by that website and for what purpose(s) you agreed that website could use that information. We may retain information about you provided to us by other websites and will only use it in accordance with this Privacy Policy. Such information may be associated with other Usage Data or Personal Information.

f. Social Media Widgets

The Site may include social media features, such as the Facebook and Twitter widgets. These features may collect information about your IP address and the pages you visit on our Site(s) as well as other Personal Information. A cookie may be set to ensure that a feature properly functions. Your interactions with social media features and the collection of Personal Information by them is governed by the social media companies’ privacy policies.

4. HOW WE USE AND SHARE INFORMATION AS A BUSINESS

a. Generally

We use Personal Information for internal purposes, such as to

  • Provide you with our Site(s) and Services;
  • Process or complete transactions you requested;
  • Improve our Site(s) and Services, including customization and personalization;
  • Market and remarket our products and services and the products and services of select third parties to you;
  • Communicate with you about our Site(s) and Services;
  • Develop new products and services and enhance existing products and services; and
  • Compile information and analyses to enhance the customer experience and improve our business.

b. Testimonials & Submissions

If you provide a testimonial or other submission of information, we may post it publicly on our Site(s), via our Services, or in other advertising material. By providing a testimonial or submission, you give us permission to use it in any manner and for any purpose, including in marketing and advertising communications, and to share it with traditional and social media providers.

c. Service Providers

From time to time, we may establish a relationship with other businesses who provide services to us and that we believe are trustworthy and have privacy practices consistent with ours that may include corporate affiliates (“Service Providers”). We contract with Service Providers to provide certain services to us, including:

  • Online hosting and maintenance;
  • Mobile and online application development, operation, and maintenance;
  • Marketing and advertising design, distribution, tracking, and analysis;
  • Payment processing;
  • Management of access to services;
  • Customer service & support;
  • Information provision and notifications;
  • Professional services such as legal, accounting, and management professionals;
  • Data storage and management;
  • Analysis of the Site and Services for performance, business, technical, and user experience optimization; and
  • Identity and contact information validation.

We only provide our Service Providers with the information necessary for them to perform these services on our behalf. Each Service Provider is expected to use reasonable security measures appropriate to the nature of the information involved to protect your Personal Information from unauthorized access, use, or disclosure. Service Providers are prohibited from using Personal Information other than as specified by us. In the past twelve months, we have disclosed each category of Personal Information we collect (listed above) with one or more Service Providers.

d. Third-Party Selling

We sell your Personal Information to third-party companies who may market products or services likely to be of interest to you or who provide services that you request. When you provide Personal Information to us, you agree to be contacted by such third parties including without limitation schools or institutions in which you expressed interest. In the past twelve months we have sold Personal Information with third parties are outlined below:

1 - Scholarship providers

  • Personal identifiers
  • Personal characteristics of protected classifications
  • Education information

2 - Colleges/Universities

  • Personal identifiers
  • Personal characteristics of protected classifications
  • Education information

3 - Education finance providers

  • Personal identifiers
  • Personal characteristics of protected classifications
  • Education information

4 - Advertising and marketing companies

  • Personal identifiers
  • Personal characteristics of protected classifications
  • Education information

5 - Student support organizations

  • Personal identifiers
  • Personal characteristics of protected classifications
  • Education information

6 - Market research firms

  • Personal identifiers
  • Personal characteristics of protected classifications
  • Education information

7 - Non-college/university education providers

  • Personal identifiers
  • Personal characteristics of protected classifications
  • Education information

8 - Traditional and Social Media

  • Personal identifiers
  • Personal characteristics of protected classifications
  • Commercial information
  • Education information
  • Professional or employment-related information
  • Audio & visual data

If you would like to opt out of having your Personal Information sold to third-party companies for their marketing purposes, please let us know by submitting a request via our “Do Not Sell My Info” page or by sending us an email at contact@scholarship.app with the subject line “Sale Opt Out” or by mail to the address in the Contact Us section below. Include in your request at least your name, email address, phone number, and a clear statement of your desire to opt out. We may contact you to verify or obtain additional information to process your request. Please allow up to ten (10) business days to process your opt-out request.

Please note that even if you opt out, your information may still be shared with certain third parties for transactional purposes such as to apply for scholarships. Additionally, third parties who have already received your Personal Information may continue to communicate with you and use your Personal Information. We do not control and are not responsible for third-party communications or the use of your Personal Information by third parties. Use of your information by a third party will be governed by that third party’s terms of use and/or privacy policy.

e. Mail & Email Marketing

We may use your Personal Information to market products or services likely to be of interest to you, or to provide you with special offers and opportunities, via mail & email. With respect to commercial email communications from us, you may opt out of these emails via a link in the footer of all commercial email messages. You may also opt out of mail and email marketing communications by emailing us at contact@scholarship.app.

5. SECURITY

We recognize the importance of safeguarding the confidentiality of your Personal Information. Accordingly, we employ commercially reasonable administrative, technical, and physical safeguards to protect your Personal Information from unauthorized access, disclosure, and use. For example, we work to protect the security of your information during transmission using Secure Sockets Layer (“SSL”) software and have deployed commercially reasonable encryption, firewalls, and access controls. Even with these safeguards, no data transmission over the Internet or other network can be guaranteed 100% secure. As a result, while we strive to protect information transmitted on or through our Site(s) and Services we cannot, and do not, guarantee the security of any information you or we transmit on our Site(s) or using our Services, or that you or we transmit over any other electronic network. You understand and agree that data and communications, including information collected and/or transferred via our Site(s) or Services, may be accessed by unauthorized third parties at rest or in transit. Your provision of information to us is at your own risk and is subject to this Privacy Policy and our Terms of Use.

6. BLOGS, FORUMS, TESTIMONIALS

Our Site(s) and/or Services may contain features such as blogs, forums, message boards, testimonial opportunities, or other public-facing message systems. If you use one of these features, your comments, including any Personal Information you share, will be viewable to other users and the public. You use such features at your own risk. We are not responsible for the Personal Information you share using such features or any consequences that result therefrom. We reserve the right, but are under no obligation, to remove any comments from such features that we believe, in our sole discretion, constitute defamation, libel, slander, obscenity, pornography, profanity, hate speech, discrimination, or otherwise offend other users or our brand.

7. OTHER WEBSITES

Please be aware that third-party websites and social media platforms accessible through our Site(s) and/or Services have their own privacy and data collection policies and practices. We are not responsible for any actions, content of websites, or privacy policies of such third parties. You should check the applicable privacy policies of those third parties before providing information to them.

8. COMPLIANCE WITH LAWS AND LAW ENFORCEMENT

We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We may disclose Personal Information, Usage Data, and any other information about you to government or law enforcement officials or private parties if, in our sole discretion, we believe it is necessary or appropriate to respond to legal requests (including court orders, investigative demands, and subpoenas), to protect the safety, property, or rights of ourselves, users, or any other third party, to prevent or stop any illegal, unethical, or legally actionable activity, to enforce this Privacy Policy, our Terms of Use, or any other agreement you have with us, or to comply with law.

9. OTHER TRANSFERS

We may share Personal Information and Usage Data with businesses controlling, controlled by, or under common control with us. If we are merged, acquired, or sold, or in the event of a transfer of some or all of our assets, we may disclose or transfer Personal Information and Usage Data in connection with such transaction. You will have the opportunity to opt out of any such transfer if, in our reasonable judgment, the new entity plans to handle your information in a way that differs materially from this policy.

10. HOW LONG WE RETAIN YOUR DATA

We retain your Personal Information for as long as we have a relationship with you. We also retain your Personal Information for a period of time after our relationship with you has ended where there is an ongoing business need to retain it. This includes retention to comply with our legal, regulatory, tax, and/or accounting obligations. Generally, we retain Personal Information of individuals who do not become paid customers for approximately seven years from last login. If an individual becomes a ScholarshipOwl customer, we retain their Personal Information for up to approximately seven (7) years after their last login or expiration of their subscription (whichever is later). The time period may be shorter based on the individual’s year of study at subscription. If an individual creates an account with us as the parent or legal guardian of a student, we will retain their Personal Information for approximately the same period of time as we retain the Personal Information of the underlying student or three (3) years, whichever is longer. If you are an individual associated with a Client using our ScholarshipApp service, we will retain your Personal Information for approximately three (3) years after the last active scholarship posted by the Client under the account expires. The exact period for which we retain your Personal Information may be longer or shorter in accordance with our data retention policies and applicable law.

11. CHILDREN’S PRIVACY

The Site is not intended for children under the age of 16 and we do not knowingly collect or sell Personal Information from children under the age of 16. If we become aware that we have inadvertently received Personal Information from a child under the age of 16, we will delete such information from our records.

12. PERSONAL INFORMATION WE COLLECT AS A SERVICE PROVIDER FOR OUR CLIENTS

When acting on behalf of our Clients as a service provider, we may collect, use, and disclose Personal Information for the purpose of servicing those Clients. The specific categories of Personal Information collected and how that Personal Information is used or disclosed is determined by our Client and will vary.

The Personal Information collected, used, and disclosed on our Clients’ behalf is governed by their privacy policies. If you request information about the Personal Information we collect, use, and disclose on our Clients’ behalf, we will direct you to contact the applicable Client(s).

13. CONTACT US

If you have any questions about our Site, Services, or this Privacy Policy, please email us at contact@scholarship.app. You may also send us a letter to the following address:

Scholarship Services, Inc.

831 N Tatnall Street Suite M #224 Wilmington, Delaware 19801

14. ADDITIONAL CALIFORNIA CONSUMER RIGHTS

If you are a resident of California, you have additional rights to access and control your Personal Information, including a right to request that we disclose the Personal Information we collect, use, disclose, and sell, under the California Consumer Privacy Act on our own behalf. If you request to exercise any of the following rights with regard to Personal Information we collect, use, and/or disclose on behalf of our Client(s), we will direct you to contact the applicable Client(s).

a. Right to Know

You have the right to request twice per 12-month period that we provide you (i) the categories or specific pieces of Personal Information we collected about you; (ii) the categories of sources from which your Personal Information was collected; (iii) the business or commercial purpose for which we collected your Personal Information; (iv) the categories of Third Parties with whom we shared your Personal Information; and (v) the categories of Third Parties to whom we sold your Personal Information. We are not permitted to provide access to specific pieces of Personal Information if disclosure of the Personal Information creates a high risk of potential harm such as financial information, social security numbers, and driver’s license numbers. We will not provide specific pieces of Personal Information in response to a request unless you expressly request them.

To request access to your Personal Information and the information listed above, you may submit a request by emailing us at contact@scholarship.app. Please include at least your name, mailing address, email address, and a description of your request.

After you submit your request, we may contact you to obtain additional information necessary to verify your identity. For example, we may require you to verify certain information in our files or submit a signed declaration under penalty of perjury verifying your identity. We will not process your request without verifying your identity, so please respond promptly. If you do not timely respond to our requests for information, we may deny your request.

We will process verified requests within 45 days of receipt, subject to any applicable exemptions and extensions permitted by law up to 90 days. If you request specific Personal Information and that information creates a high risk of potential harm from disclosure to an unauthorized person, we will withhold that information and replace it with a category identifier. For example, if we withhold a social security number, we will inform you that we have a social security number on file. If you have an online account with us, we will provide the response to your request via the online account, otherwise, we will give you the option to choose between mail and electronic delivery.

b. Right to Deletion

You have the right to request that we delete any Personal Information we have collected about you. Please understand that we are not required to honor a deletion request if a legal exemption applies such as if we need the information to complete a requested or reasonably anticipated transaction, prevent security incidents or fraud, enable internal uses that are reasonably aligned with your expectations, or comply with legal obligations.

To request deletion of your Personal Information and the information listed above, you may submit a request by calling us at 800 494 4908 or emailing us at contact@scholarship.app. If you submit your request via email, please include at least your name, mailing address, email address, and a description of your request.

After you submit your request, we may contact you to obtain additional information necessary to verify your identity. For example, we may require you to verify certain information in our files or submit a signed declaration under penalty of perjury verifying your identity. We will not process your request without verifying your identity, so please respond promptly. If you do not timely respond to our requests for information, we may deny your request.

We will process verified requests within 45 days of receipt, subject to any applicable exemptions and extensions permitted by law up to 90 days. If you have an online account with us, we will provide the response to your request via the online account, otherwise, we will give you the option to choose between mail and electronic delivery. We will retain a copy of your deletion request for at least two years as required by law.

c. Right to Opt-Out from the Sale of Personal Information

You have the right to direct us not to sell your Personal Information to third-party companies. You may exercise your Right to Opt-Out by submitting a request via our “Do Not Sell My Info” page or by emailing us at contact@scholarship.app.

d. Authorized Agent

If you are an authorized agent submitting a request on behalf of a California resident, you must provide a copy of a lawful power of attorney or a written signed authorization from the consumer along with proof your identity. You may provide this documentation via email to contact@scholarship.app after submitting the request. We may contact you and/or the consumer on whose behalf you claim to act to verify your authorization.

e. Non-Discrimination Notice

We will not discriminate against any consumer for exercising their privacy rights under law or this Privacy Policy.

f. California “Do Not Track” Disclosure

Do Not Track is a web browser privacy preference that causes the web browser to broadcast a signal to websites requesting that a user’s activity not be tracked. At this time, our Site and Services do not respond to “do not track” signals.

g. California Site Ownership Disclosure

Under California Civil Code Section 1789.3, California residents are entitled to the following information: The provider of the Site is Scholarship Services, Inc., 831 N Tatnall Street Suite M #224 Wilmington, Delaware 19801. To file a complaint regarding the Site or to receive further information about the Site, please contact us. You may also contact the Complaint Assistance Unit of the Division of Consumer Services of the Department of Consumer Affairs in writing at 1625 North Market Blvd., Suite N 112, Sacramento, California 95834 or by telephone at (800) 952-5210.

15. ADDITIONAL NEVADA CONSUMER RIGHTS

If you are a resident of Nevada, you have the right to direct us not to sell your Personal Information to third parties. You may exercise these rights by sending an email to contact@scholarship.app with the subject line “Nevada Opt Out.” Although Nevada law gives us 60 days to respond to your request, plus an additional 30 days in certain instances, we will strive to respond to your request as soon as reasonably possible. We may request additional information in order to verify your identity or locate your Personal Information.

Update History

February 2022– Updated Privacy Policy to reflect company name change, include additional detail regarding record retention, and clarify other aspects of information collection, use, and disclosure.

September 2021– Updated Privacy Policy to incorporate additional detail regarding information collection, use, and disclosure.

September 2020– Updated Privacy Policy to incorporate additional detail regarding information collection, use, and disclosure.

September 2019– Updated Privacy Policy to incorporate additional detail regarding information collection, use, and disclosure; add California Consumer Privacy Act provisions; and add Nevada opt out rights.

November 2017– Revised provisions related to California privacy rights; information security; and collection and disclosure of information.

June 2017– Privacy Policy created.