CCPA PRIVACY NOTICE FOR CALIFORNIA RESIDENTS
INTERNATIONAL TERMS FOR RESIDENTS IN THE EUROPEAN ECONOMIC AREA (“EEA”), UNITED KINGDOM (“UK”) OR SWITZERLAND
- Personal Information we collect
- How we use personal information
- How we share personal information
- How we store your personal information
- Your choices about receiving email
- How to access and update your personal information or preferences
- How we protect your personal information
- How we make updates to this policy
- How to contact us for more information
1. Personal Information We Collect:
Information You Provide.
We collect information you choose to provide us through the Site or via email. For example, we obtain information when you create an account, complete a registration form or feedback form, contact us requesting information, purchase our Services, respond to a survey, contact a customer support representative, or opt-in to provide information to one or more of our affiliates through the Site.
This information may include:
- Contact information and registration information for example, your name, email address, postal address, phone number
- Education information: including information about your institution (for example, a school’s name and address), and other education information (not sourced from Credentials, including college admissions information, and test scores (e.g. SAT, GRE, etc.), which may be collected if you choose to use certain admissions tools available through the Site.
- Identity Information: If requested by your school in order to correctly identify your Credentials, we may request additional personal information from you, which may include the full social security/insurance number or last four digits of your social security/insurance number.
- Profile Information, you choose to provide information associated with your discovery profile which may include a profile photo, educational background, personal background, test scores, extracurricular activities, work or internship history, awards/achievements, certain demographic information, such as contact information, race, ethnicity, or gender. Provision of certain information such as race or ethnicity is optional and you can remove it at any time.
- Transactional information: billing and payment information, as well as details about your transactions.
- Inquiries and feedback: comments and questions you submit through customer service interactions with us.
- Research or survey information: information you provide if you participate in a survey (including demographic and statistical information, educational and employment information, usage information, and feedback).
You can choose not to provide us with certain information, but then you may not be able to successfully use the Services or take full advantage of the features of our Site.
If you provide us personal information about others, or if others give us your information, we will only use that information for the specific reason for which it was provided to us. You should not provide us with information about others unless you have been expressly authorized by the other person to provide this information to us.
Information We Get from Others.
We may also get information about you from other sources, for example, if you have agreed to share information with one of our partners for purposes of the electronic ordering, fulfillment, and delivery of academic credentials and data or other use related to the Services. The type of personal information collected from other sources is similar to the personal information outlined above under “Information You Enter”. We may add this to information we get from you in our Services.
We may combine other publicly available information, such as information related to the organization for which you work, with the personal information that you provide to us through our Services.
Information We Get from Members.
We may also receive personal information from our Members, which are academic institutions, school districts, state agencies, public and private boards, and non-academic private entities. The type of personal information collected from our members is similar to the personal information outlined above under “Information You Enter” and may also include student contact information, student demographic information such as age and gender, and student records, such as grades, transcripts, class lists, student schedules, student identification codes, or student disciplinary records.
When we obtain your personal information indirectly from our Members, we rely on their lawful authority to collect and use your personal information and provide it to us so that we can provide you with Services on behalf of our Member. Our members are solely responsible for obtaining all required consents and authorizations from the relevant individuals and for satisfying all obligations or rights owed to the member’s data subjects under applicable privacy law. Parchment is not responsible for the privacy policies or practices of its members. Changes to Your Personal Information.
It is important that the personal information we hold about you is accurate and current. Please let us know if your personal information changes during your relationship with us by updating your account information or emailing us at email@example.com.
Automatic Collection of Information
Like many websites on the Internet, we automatically gather certain non-personally identifiable information and store it in log files. This information may include,
- Device information and related identifiers: including your IP address,
- your IP address, browser type, and Internet connection speed, device IDs, characteristics, systems, mobile device’s service provider, platform type, advertising identifiers, operating system, and the city, state or country from which you accessed the Site.
- Usage information: When you use our Site we and our service providers collect and analyze information about your usage activity, such as referring and exit pages and URLs, the number of clicks, files you download, domain names, landing pages, pages viewed and the order of those pages, the amount of time spent on particular pages, the date and time you used the Site, error logs, language preferences, and other similar information.
We may employ the use of “cookies” in certain areas of our Site to collect the information above. We use this information to analyze trends, to administer the site, to track users’ activity on the site, and to gather demographic information about our user base as a whole. We may link this automatically collected data to other information we collect about you.
Technologies such as cookies, beacons, tags and scripts are used by Parchment and our partners, affiliates, or service providers. These technologies are used in analyzing trends, administering the Site, tracking users’ movements around the Site and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.
We may collect information using “cookies.” Cookies are small data files stored on the hard drive of your computer or mobile device by a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience on the Site.
We use two broad categories of cookies: (1) first party cookies, served directly by us to your computer or mobile device, which we use to recognize your computer or mobile device when it revisits the Site; and (2) third party cookies, which are served by service providers on the Site, and can be used by such service providers to recognize your computer or mobile device when it visits other websites.
Cookies we use.
Our Site uses the following types of cookies for the purposes set out below:
|Type of cookie||Purpose|
|Essential Cookies||These cookies are essential to provide you with services available through the Parchment Site and to enable you to use some of its features. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services. This includes Session cookies. Session cookies allow a website to remember your actions during a browsing session and expire once you close your web browser. Session cookies may be used for a variety of purposes, such as remembering that you logged into one of our websites and enables payment where applicable.|
|Functional Cookies||These cookies allow our Site to remember choices you make when you use the Site. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you visit the Site.|
|Analytics and Performance Cookies||These cookies are used to collect information about traffic to the Parchment Site and how users use our Site and Services. The information gathered may include the number of visitors to our Site, the websites that referred them to our Site, the pages they visited on our Site, what time of day they visited our Site, whether they have visited our Site before, and other similar information. We use this information to help operate our Site more efficiently, to gather broad demographic information, monitor the level of activity on our Site, and improve the Site. The information gathered does not identify any individual visitor. The information is aggregated and anonymous.
We use Google Analytics for this purpose. Google Analytics uses its own cookies. You can find out more information about Google Analytics cookies here and about how Google protects your data here. You can prevent the use of Google Analytics relating to your use of our Site by downloading and installing the browser plugin available here.
|Advertising or Marketing Cookies||These cookies are used to identify Site visitors that are either known or unknown to enhance the experience they have on our Site. These cookies allow us to provide content that is personalized to match visitors’ browsing or user history.
You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings,” “help” “tools” or “edit” facility). Many browsers are set to accept cookies until you change your settings.
Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org.
If you do not accept our cookies, you may experience some inconvenience in your use of our Site. For example, we may not be able to recognize your computer or mobile device and you may need to log in every time you visit our Site. However, declining cookies will not prevent you from transacting with us.
Do Not Track Signals.
Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We do not currently respond to do not track signals. To find out more about “Do Not Track,” please visit www.allaboutdnt.com.
2. Why do we collect your information and how is it used?
Personal or Institution Information.
Any personal information that we collect is used to
- provide our Services and develop new ones
- facilitate the provision of Services that you may order and any related transactions and to further operate and improve our Services,
- personalize your account,
- allow communication between Parchment (its affiliates and service providers) and you and to manage your account including to send administrative or customer service related emails and respond to your requests,
- Conduct research including product and services surveys,
- Conduct advertising and marketing (including sending emails about upcoming products or services), when express consent has been given where required by applicable privacy law,
- as otherwise described to you when collecting your personal information; and
- as otherwise required or permitted by applicable privacy law.
Under certain law, we only collect, use or disclose your personal information with your consent, which may be implied by your use of our Services with knowledge of how we use your personal information, unless we are required or permitted by law to obtain your personal information without consent. We will request your consent to use your personal information where required by law, such as where we use certain cookies or similar technologies or would like to send you certain marketing messages. If we request your consent to use your personal information, you have the right to withdraw your consent any time in the manner indicated when we requested the consent or by contacting us at https://support.parchment.com.
Sensitive Personal Information.
Anonymous and De-Identified Data.
We may create anonymous data from your personal information and other individuals whose personal information we collect. We make personal information into anonymous data by excluding information that makes the data personally identifiable to you.
We may use anonymous information in aggregate form to provide institutions with analytics on Credential exchange activity through the Services, including analysis to track where requests are coming from and going to, benchmarking information, and for any other lawful business purpose. Additionally, we may use anonymous information in aggregate form to provide users with certain admissions-related analytics. These analytics rely solely on aggregated, anonymized data, and do not include any data from the Credentials we process.
We may use a vendor to assist us in collecting and analyzing information as described below.
3. How we disclose your information?
Our business hinges on security and the trust you place in us. We take great care to ensure that your personally identifiable information is only disclosed in the following limited circumstances:
- Designated Institutions or Third Parties. When a student, academic institution, or other user uses our Services, we will access certain data, including personal information, and may transmit, fulfill, or otherwise disclose Credentials and related data to such other academic institutions or third parties as authorized by such user. The consent of a student-user’s parent may be required to submit a Credential request for non-postsecondary students under the age of 18. We will disclose certain information with the institutions from which we obtain your Credentials in order to fulfill your order.
- Professional Advisors. We may disclose your personal information to professional advisors, such as lawyers, auditors, and insurers, where necessary in the course of the professional services they render to us.
- Academic Research. We may share anonymous data with researchers at academic institutions for academic research purposes, including the study of topics of relevance to the admissions process, college access, and labor market outcomes. Researchers and academic institutions are only permitted to handle such data in compliance with the terms of a restricted use agreement with Parchment; additionally, such academic institutions must be accredited and the research must be approved by the researching institution’s institutional review board (IRB), passing review of the methods proposed for research to ensure that they are ethical.
- Other Third-Parties. Parchment may disclose personal information to other third-parties without your consent where required or permitted by law, including without limitation where: (i) the information is public as permitted by law; (ii) it is reasonable for the purposes of investigating a breach of an agreement, or actual or suspected illegal activity; (iii) it is necessary to identify an individual who is injured, ill or deceased; or (iv) due to an emergency that threatens the life, health or security of an individual.
International Data Transfer
By contacting Parchment at firstname.lastname@example.org, you may request information from Parchment on the specific jurisdictions in which Parchment and/or its service providers will process personal information, including how to access such information and who to contact about the specific privacy practices involving the personal information.
European Union users should read the important information provided here about transfer of personal information outside of the European Economic Area. Canadian users authorize the transfer of their personal information into the United States and elsewhere as directed and authorized by the Canadian user or Member to Parchment. Parchment will take all reasonable measures to ensure that the personal information will not be used, transferred, or disclosed for purposes not relevant to the purposes of its collection or as authorized by you or a Member.
4. Storage and Retention of Information
Once a Credential request has been fulfilled, Parchment does not retain such Credential, unless requested by the individual user, the sending institution, or the receiving institution, for the convenience of such user, or to meet our legal and contractual obligations. For example, it is Parchment’s policy to comply with the sending institution’s preferences until the Credential is delivered. After the Credential is delivered, Parchment follows the receiver’s preferences regarding the retention and analysis of the transmitted Credential. If an individual user requests Parchment retain their Credentials on their behalf, Parchment will comply with such request and maintain the Credentials on behalf of such user in their personal account. Similarly, if an institution requests that Parchment store Credentials in the Parchment credential library, Parchment will comply with such request and maintain the Credentials on behalf of such institution in its credential library, subject to the applicable agreement between such institution and Parchment.
We will retain your other information for as long as your account is active or as needed to provide you Services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Personal information that is subject to an access request will be retained even if access is denied in accordance with applicable privacy laws until the requestor has exhausted all recourses and/or appeal mechanisms under such laws. Where personal information is no longer needed and the requests identified above have been complied with, the personal information will be securely destroyed or permanently anonymized or de-identified.
5. Your Rights and Choices
Access, Correction and Deletion of Information
Depending on your jurisdiction, you may have the right to make certain requests regarding your “personal information” or “personal data” and (as such terms are defined under applicable law, and collectively referred to herein as “personal information”). Specifically, you may have the right to ask us to:
- Inform you about the categories of personal information we collect or disclose about you; the categories of sources of such information; the business or commercial purpose for collecting your personal information; and the categories of third parties with whom we disclose personal information.
- Provide you access to and/or a copy of certain personal information we hold about you.
- Correct or update personal information we hold about you.
- Delete certain personal information we have about you.
- Provide you with information about the financial incentives that we offer to you, if any.
- Opt you out of the processing of your personal information for purposes of profiling in furtherance of decisions that produce legal or similarly significant effects, if applicable.
You can access, review, correct, update, or delete the information you provide Parchment by signing in to your account and accessing the Profile tab. Account holders may also contact us at email@example.com to accomplish the foregoing or if you have additional requests or questions. We will correct, update or delete any personal information we have about you, unless we are required to keep it by law. Please note that certain information may be exempt from such requests under applicable law. For example, we need to retain certain information in order to provide our services to you. We also need to take reasonable steps to verify your identity before responding to a request, which may include verifying your name and email address. Depending on your jurisdiction, you may be permitted to designate an authorized agent to submit certain requests on your behalf. In order for an authorized agent to be verified, you must provide the authorized agent with signed, written permission to make such requests or a power of attorney. We may also follow up with you to verify your identity before processing the authorized agent’s request.
If your personal information is provided to us by a Member (defined above), then we will contact the Member or direct you to contact the Member regarding any correction, update, or deletion requests by you. If you request that we delete your information, please note that your information may continue to reside in our backup systems. Where personal information is being used to make a decision about you, we will make every reasonable effort to ensure such information is accurate and complete. We will make corrections to your personal information when notified by our members and we ask you to correct and update your information as outlined above.
Subject to restrictions and exceptions under applicable privacy law, upon request we will provide you with access to your personal information as well as information about the collection, use and disclosure of your personal information and a listing of the individuals or organizations to which your information has been disclosed. Such requests should include sufficient information to allow us to locate the records that you are seeking. Reasonable fees may apply to access requests, where permitted under Applicable Privacy Laws. We will generally respond to access requests within 30 days, except where a longer period of reply or an extension is permitted under applicable privacy law. If access is denied, we will provide you with a written explanation in accordance with applicable privacy law. Depending on applicable law, you may have the right to appeal our decision to deny your request, if applicable. To exercise such an appeal right, please contract firstname.lastname@example.org.
Opt Out of Sale of Personal Information or Sharing or Processing of Personal Information for Targeted Advertising
Depending on your location, you may opt out of certain processing of your personal information, including for targeted advertising, under applicable law. Targeted advertising is when we or our partners display ads to you based on your personal information that is collected across different businesses.
We and our advertising partners collect certain information from our visitors, such as device identifiers, cookies, advertising IDs, IP addresses and usage activity and use this information to deliver more relevant (targeted) ads to you and for related advertising activities. This activity is known as “sharing” or processing your personal information for targeted ads and may be considered “selling” your personal information under applicable law. Please note Parchment does not sell member data and/or education credential data and therefore such data is not applicable to the Sale of Personal Information or Sharing or Processing of Personal Information for Targeted Advertising. For information on disclosure please refer to “How we disclose your information?” section of this policy.
If you (or in California, your authorized agent) would like to opt out of our use or disclosure of your information for such purposes, you can follow the steps at Your Privacy Choices.
Even if you opt out, you will still see advertising, it just may be less relevant to you,. If you have enabled a legally recognized browser-based opt out preference signal (such as Global Privacy Control) on your browser, we recognize such preference in accordance and to the extent required by applicable law. You will need to turn this on for each browser you use.
We give you an opportunity to let us know your preference in terms of receiving promotional e-mail mail or telephone calls, including information on Parchment’s various Services, when you register for a service, provide us with your personal information, or when we send you e-mails. Parchment complies with applicable law with respect to such communications. If you choose not to accept this communication, you may not receive special offers that may be of value. This option applies to promotional communications only, as we may find it necessary to send you e-mail relating to the Services you have purchased, your account or your orders. You can opt-out of receiving these types of communications or access your personal information by clicking on an unsubscribe link at the bottom of each message or by contacting us at email@example.com. You may continue to receive service-related and other non-marketing messages.
If you have opted in to receive communication offered from third parties through Parchment, please contact each such party for information about their available opt-out procedures. We are unable to opt you out of third-party marketing programs.
Where we are required by law to collect your personal information, or where we need your personal information in order to provide the Services to you, if you do not provide this information when requested (or you later ask to delete it), we may not be able to provide you with the Services and may need to close your account. We will tell you what information you must provide to receive the Services by designating it as required in the Services or through other appropriate means.
We use industry-standard technology designed to protect your information and all transmissions made through our Services, and take reasonable measures to protect the confidentiality, security and integrity of personally identifiable information collected on our Services.
If you create an account, you are responsible for maintaining the confidentiality of your account password and for activity that occurs under your account credentials. Please email us at firstname.lastname@example.org if there are any unauthorized uses of your account or other breaches of security.
7. Third Party Services
Some of our partners may utilize framing techniques to serve content to and from webpages accessible through our Site while preserving the look and feel of our site. Please be aware that you are providing your personal information to these third parties and not to Parchment.
If you opt in to provide information to a third party whose services may be introduced by Parchment (e.g., through a site that is not owned or controlled by Parchment), please be aware that such collection of information is governed by the privacy statement of such third party.
Our Site offers publicly accessible blogs or community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal information from our blog or community forum, please contact us at email@example.com. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.
We may display personal testimonials of satisfied customers on our site in addition to other endorsements. With your consent we may post your testimonial along with your name. If you wish to update or delete your testimonial, please contact us at firstname.lastname@example.org.
10. Social Media Widgets
11. Single Sign-On
12. Children’s privacy
Our Site is a general audience website and no portion of the Site is directed to children under the age of 13. We do not collect personally identifiable information from any person we know is a child under the age of 13.
Should we be alerted that we have inadvertently collected personally identifiable information from a child under the age of 13, we will take steps to immediately delete it.
We further do not knowingly permit children under the age of 18 to become registered members of our Site, or to use our Services without parental consent. Parchment does not knowingly collect or solicit personal information about children under 18, except with their parent’s consent.
If you are a resident of California and under the age of 18, you may remove any content that you have posted to our Site. In the event you cannot remove the content, you may request for Parchment to remove the content by contacting privacy @parchment.com. Please note that the removal of content or information from our Site does not ensure complete or comprehensive removal of the content or information posted on our Site.
14. Contact Us
7001 N. Scottsdale Road, Suite 1050
Scottsdale, AZ 85253
Attn: General Counsel
If any concerns are not resolved to your satisfaction, you may contact the applicable privacy commissioner/regulator.
CCPA PRIVACY NOTICE FOR CALIFORNIA RESIDENTS
PRIVACY NOTICE FOR CALIFORNIA RESIDENTS
Parchment does not knowingly collect personal information from California consumers under the age of 16.
1) Information We Collect.
The Parchment Services have collected the following categories of personal information from its consumers within the last twelve (12) months:
|Identifiers.||A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, and/or email address.|
|Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||
A name, signature, address, telephone number, education, employment, or employment history.
Some personal information included in this category may overlap with other categories.
|Protected classification characteristics under California or federal law.||Age (40 years or older), or gender.|
|Commercial information.||Records of products or services purchased, obtained, or considered.|
|Internet or other similar network activity.||Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.|
|Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).||Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, or student disciplinary records.|
Personal information does not include:
- Publicly available information from government records.
- De-identified or aggregated consumer information.
- Information excluded from the scope of the CCPA.
2) Use of Personal Information; Business Purpose. We may use, or disclose the personal information we collect for one or more of the purposes set forth above, which includes without limitation, to fulfill or meet the reason you provided the personal information to Parchment, contact you; to analyze the use of our Services; to market our Services to you; for security; for legal compliance; and with your consent.
3) Disclosing Personal Information; Categories of Third Parties.
The information we have disclosed in the preceding 12 months to the above entities includes the following categories of information from Section 1 above:
Identifiers, California Customer Records personal information categories, Protected classification characteristics under California or federal law, Commercial information, Non-public education information, See “How do we share your information?” for more details.
4) Your Rights and Choices.
The CCPA provides consumers (California residents) with specific rights regarding their personal information. See your rights and choices above.
Opt Out of Sale of Personal Information or Sharing of Personal Information for Targeted Advertising
You may opt out of certain processing of your personal information, including for targeted advertising, under applicable law.
We and our advertising partners collect certain information from our visitors, such as device identifiers, cookies, advertising IDs, IP addresses and usage activity and use this information to deliver more relevant (targeted) ads to you and for related advertising activities. This activity is known as “sharing” your personal information for targeted ads and may be considered “selling” your personal information under applicable law. Please note Parchment does not sell member data and/or education credential data and therefore such data is not applicable to the Sale of Personal Information or Sharing or Processing of Personal Information for Targeted Advertising. For information on disclosure please refer to “How we disclose your information?” section of this policy.
If you (or your authorized agent) would like to opt out of our use or disclosure of your information for such purposes, you can follow the steps at Your Privacy Choices. You will need do this on for each browser you use.
Even if you opt out, you will still see advertising, it just may be less relevant to you.
We will not discriminate against you for exercising any of your CCPA rights.
Other California Privacy Rights.
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Services that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. Parchment does not disclose personal information to third parties for their direct marketing purposes. For more information, please send an email to email@example.com.
5) Changes to Our Privacy Notice.
Parchment reserves the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Website and update the notice’s effective date. Your continued use of our Site and/or the Parchment Services following the posting of changes constitutes your acceptance of such changes.
6) Contact Information.
Phone: (844) 515-2272
INTERNATIONAL TERMS FOR RESIDENTS IN THE EUROPEAN ECONOMIC AREA (“EEA”), UNITED KINGDOM (“UK”) OR SWITZERLAND
Parchment is based in and operates in the United States. As a result, we and our service providers will process personal information in the United States and in other locations outside of the European Economic Area, where there may be different data protection standards than in the EEA. By using the Services, you acknowledge that personal information will be processed in outside of the EEA.
EU-U.S. Privacy Shield
Parchment commits to resolve complaints about our collection or use of your personal information. EU individuals with inquiries or complaints regarding this Policy should first contact us at: firstname.lastname@example.org.
Parchment commits to cooperate with the panel established by the EU data protection authorities (DPAs) and comply with the advice given by the panel with regard to personal information transferred from the EU. Please contact us to be directed to the relevant DPA contacts.