Privacy Policy – Effective May 3, 2020

Privacy Policy

Updated: April 3, 2020

BEFORE SUBMITTING ANY PERSONAL INFORMATION TO MYKLOVR.COM PLEASE REVIEW THE FOLLOWING PRIVACY POLICY.

1 Who's Who?

"myKlovr" refers to Student Global, LLC, a Delaware limited liability company. When "We" or "Us" or "Our" are used in this policy, it is a reference to myKlovr. The "myKlovr Application" is the computer system that uses information you provide that describes your educational profile and plans and career preferences and plans, and other related information, and which generates academic, college preparatory, and career advice, among other allied and ancillary services, and which you access by logging into the restricted-access section of the myKlovr.com website. The "myKlovr Platform" refers to the myKlovr Application, the public-access sections of the myKlovr.com website (the "Website") and all applications and content provided by myKlovr. "You" or "Your" refers to the person using an account created on the myKlovr Platform, or otherwise using the Website or any other component of the myKlovr Platform. If you are using the myKlovr Platform as part of your job, or on behalf of your employer, "You" or "Your" refers to both you and your employer.

2 What Does This Privacy Policy Address?

This myKlovr privacy policy (the "Privacy Policy"), applies to personally identifiable information ("PII") and non-personally identifiable information ("non-PII", PII and non-PII are referred to as "Information") that We or Our designees collect via the myKlovr Platform or by other means when You use the myKlovr Platform and describes how we gather and use that Information and Your rights regarding the use and disposition of that Information. PII is information about a user that can be associated with a specific person by means of a name, postal address, email address, IP address, MAC address, or mobile device identifier. Non-PII is information about a user that cannot be reasonably associated with a specific person.

This Privacy Policy is a part of the myKlovr Terms and Conditions available at http://www.myKlovr.com/terms-conditions (the "Terms"). You accept this Privacy Policy and the Terms by either creating an account on the myKlovr Platform, or by otherwise using or accessing the parts of the myKlovr Platform that are accessible without creating an account. If You are using the myKlovr Platform as part of Your job, or on behalf of Your employer, You are accepting it both on behalf of Yourself personally, and on behalf of Your employer and You are warranting to us that You are authorized by Your employer to enter into the Terms and agree to the terms of this Privacy Policy.

2.1 Notice

This Privacy Policy provides notice to users, including those who are California consumers, as that term is defined in the California Consumer Privacy Act of 2018 ("CCPA"), that we collect, store, use, and may sell or disclose Your Personal Information (as that term is defined in the CCPA). We also use technologies such as cookies, beacons (also known as pixels), Your IP address, and browser fingerprinting to identify You, and may use these technologies to facilitate other websites identifying You. This Policy describes the information we collect, how we use it, and what rights You have with respect to Your Information.

As required by the CCPA, the following sections of the Policy also detail the categories and sources of Personal Information collected and the business and commercial uses of the collected Personal Information. We also include a description of rights afforded to California consumers in the section titled "Rights Of California Users With Regard To Their Information" including rights to know the Personal Information we have collected and sold, the right to opt-out from the sale of Information and the right to deletion of their Personal Information.

IF YOU DO NOT UNDERSTAND AND AGREE TO HOW WE COLLECT AND HANDLE INFORMATION, DO NOT USE OR VISIT THE MYKLOVR PLATFORM.

3 Minors

The myKlovr Platform is designed to be compliant with the Children's Online Privacy Protection Act ("COPPA"). The myKlovr Platform is intended for use by high-school students, who may be minors, as well as their parents, legal guardians, and family members. We do not permit use of the myKlovr Platform by minors under the age of 13 years, and do not knowingly collect Information from users under the age of 13. We require the consent of a parent or legal guardian to enroll users under the age of 18 and request the consent of the registering party to use the Information of any minors they register in a manner consistent with the terms of this Privacy Policy.

4 Parents of Minor Children Who Use the MyKlovr Platform

When we create an account for a student who may be a minor, we also create an account for a linked parent or legal guardian. Any right we extend under this Privacy Policy to a user who is a minor we also extend to that user's parent or legal guardian, acting on the user's behalf, and we provide a means for the parent or legal guardian to exercise those rights either by means of a user interface within the parent/guardian's account that refers to the minor user specifically, or by providing a means for the parent/guardian to "log in as" the minor user and to take action on behalf of the minor user.

5 Non-US Persons

The myKlovr Platform is offered only to US residents, it is not compliant with regulations in force outside the US and is not intended for use by non-US residents. Persons who do not reside in the US and who are not located in the US at the time of their use of the myKlovr Platform are prohibited from using it. We will terminate the access of users who access the myKlovr Platform from outside the US if we become aware of that fact.

6 Personal Information We Gather

6.1 Types of Personal Information We Gather

We gather the following kinds of information about You:

  • Information we can use to identify You in communications or to personalize communications with You or for authentication, such as name, gender, postal address, email address, and phone number;
  • Information to enforce our policies such as Your date of birth or zip code;
  • Family history related to college attendance, plans for college attendance, experience in applying to college, ability to pay for college;
  • Personal and career interests, academic performance including schools attended and dates, courses taken, grades earned, opinions of courses taken, standardized test scores, extracurricular activities, and other interests, experiences, and opinions;
  • Interest in colleges, plans for college applications or attendance, and plans for extracurricular activities in college, parameters you use to search for colleges in our College Finder, colleges you access in search results, and opinions you express about colleges;
  • The content of chat sessions you have with other users whether one-on-one, in small groups, or posted in open forums;
  • Information collected from our web server log files including the dates and times You access the myKlovr Platform, the IP addresses and locations from which You access it, and characteristics of the computer and internet browser You use to access it;
  • General information shared with us by third parties who may be partners who provide content You access or consume on or through the myKlovr Platform, or from whom we may purchase data about You on the basis of other Information we have about You;
  • Information we collect from our customer support tools, credit card processer but not your credit card number, or merchants who sell goods or services on or through the myKlovr Platform; and
  • Information related to Your interaction with emails, text messages, push messages, phone calls, or other communications with You.

6.2 How We May Collect Personal Information

We collect Information about You by:

  • Asking You to provide the Information;
  • Observing how You interact with our websites or applications or the websites or applications of our partners;
  • Recording Information Your computer or browser provide to us in the ordinary course of requesting information from our web servers;
  • From other parties to whom You disclose information and who offer that information for sale;
  • From Your interaction with our service providers who communicate with You on our behalf;
  • From records of phone calls, online chats, or other communications You engage in with or through us; and
  • From Your interaction with emails and advertisements we may present to You.

6.3 How We May Use Personal Information

We use the information You provide to:

  • Verify Your right to access the myKlovr Platform and Your Personal Information stored therein;
  • Provide the services of the myKlovr Platform, including developing personalized recommendations of actions You can take to improve Your chances of admission to college;
  • Provide You with customer service and information about Your account and to otherwise communicate with You;
  • Provide You with information including content and advertising about careers, colleges, vocational training programs, or other matter which we determine may be of interest to You;
  • Permit our partners to contact You with information, including advertising, about colleges which may be of interest to You, advice or services related to financing college or vocational education, or other matters which we deem relevant;
  • Bill You for our service if You are paying us directly;
  • Select information to present to You which may best match Your needs or interests;
  • Operate our website, web servers, or interact with Your internet browser, computer, or other software on Your computer;
  • Carry out our obligations and to enforce our rights arising from any contracts between You and Us, including for purposes of our Arbitration Agreement and any inquiry specific to prior express written consent under the Telephone Consumer Protection Act ("TCPA"), CAN Spam Act, the CCPA or other applicable laws, rules and regulations;
  • Detect, investigate, and respond to any suspicious, fraudulent, or malicious activity or any other activity which we may determine to violate our Terms, Privacy Policy, or existing laws, rules, or regulations;
  • As necessary or appropriate to protect our rights or property, ensure our safety and that of our related parties, clients, advertisers, service providers, and others; and
  • Respond to subpoenas, court orders, legal process, or to establish or exercise our legal rights or to defend against legal claims or when we determine it is necessary to comply with applicable laws, regulations, or court orders.

If we are sold, merge with a third party, are acquired, or are the subject of bankruptcy proceedings, Your information may be shared with the applicable third parties.

6.4 How We May Disclose or Sell Personal Information

We may disclose or sell Your Personal Information:

  • To our advertisers or marketing partners to enable them to determine whether You may be interested in an offer they wish to present, and to enable them to contact You with that offer if they choose;
  • To our vendors and marketing partners who assist us with the delivery of email, advertising, text messaging and phone calls where You have provided Your prior express written consent (as defined in the TCPA) to be contacted by these means, and other communications from Us, whether commercial or transactional;
  • To enable third parties, including our data and list management partners, to market products and services to You;
  • To enable our customer service vendors to perform their tasks; and
  • To third party providers of information, products, and services when You consume those products or services through the myKlovr Platform or to enable those vendors to fulfill Your requests for or purchases of products or services from them.

When we share and or sell Your Personal Information, we will do so only with advertisers and marketing partners who we believe are responsible and will use Your Information in compliance with this Privacy Policy and applicable privacy laws including the CCPA. We will enter into agreements with the recipients of that Information that describe the purpose for which the Information is shared or sold, restrict its use to the agreement's specified purpose, and require that all Information remain confidential and be protected from unauthorized disclosure.

7 Use of Cookies, Beacons, and Other Identifying Technology

The myKlovr Platform uses Cookies to determine whether users have previously visited our Websites and to streamline the registration process. In addition, some of our third-party marketing partners may place Cookies on our Websites to track users' online behavior while on our Website and after they leave our Website. These third-party Cookies may enable the delivery of interest-based advertisements (to find out more about Cookies, please visit www.cookiecentral.com) based on a user's visit to our Website and/or other websites. In addition, our partners use information gathered in this manner to recognize You across different channels and platforms, including computers, mobile devices, and Smart TVs and may use this information over time for advertising, analytics, attribution and reporting purposes.

We may use Google Analytics and similar tools provided by our third-party partners to help analyze how You interact with the Website and to display customized ads and other content to You during a current browsing session or in the future when the You are online. These analytics are performed by using the technological means described above to monitor Your interactions with the Website and do not involve the collection of any additional PII.

Most computers are initially set up to accept Cookies, but You can reset Your Internet browsers to refuse all Cookies or to indicate when a Cookie is being sent. To disable and reject certain Cookies, follow the instructions associated with Your Internet browser. Even where You reject a Cookie, You may still use the Website but Your ability to use certain features or offerings may be impaired. For example, if You return to our Website, You may have to re-enter Information You previously supplied to us. We may retain Cookie data indefinitely.

You may opt-out from interest-based advertising delivered to Your web browser by companies who have elected to participate in one of the interest-based advertising opt-out mechanisms such as the Digital Adverting Alliance's opt-out program or the National Advertising Institute's opt-out program. You may also choose to opt-out of interest-based advertising on Your mobile devices.

Please note that opting out of interest-based advertising does not mean You will no longer see advertising online. Rather, it does mean that the company or companies from which You opt-out will no longer show ads that have been tailored to Your interests.

8 Protection of Personal Information

We have implemented industry-standard measures to protect the security of the Personal Information We collect via the myKlovr Platform. The financial partners We use to collect and process payment information are PCI DSS (Payment Card Industry Data Security Standard) certified. Regardless of what measures are used to protect Personal Information, no one can guarantee, and We do not guarantee, that Your Personal Information is completely secure at all times. If We determine that Your Personal Information was accessed in an improper manner, We will comply with applicable laws as We understand them and will cooperate with internal investigators or law enforcement (including by possibly disclosing Your Personal Information to such investigators or law enforcement agencies).

Given the nature of the Internet, Your Personal Information passes through entities that we are unable to control. Therefore, we cannot guarantee that our security measures or those of third parties who access or transmit Your Information will prevent Your Information from being improperly accessed, stolen or altered. As required by applicable federal and state laws, we will notify You by email and any applicable regulatory agencies if we learn of an information security breach of Your Information. Please be advised that notice may be delayed in order to address the needs of law enforcement, determine the scope of network damage, and to engage in remedial measures.

8.1 Trust of Your Credentials

By using the myKlovr Platform, You grant us the right to trust that any user who presents Your User-ID and Password ("Access Credentials") is You or Your authorized representative. Specifically, You authorize us to give access to Your account and Your Personal Information to any person who presents Your Access Credentials. To secure the privacy and control of Your Personal Information, You bear the entire responsibility for securing, preventing the disclosure of, and not sharing Your Access Credentials.

Part of Your responsibility to secure Your access credentials requires that You use an effective, secure, hard-to-guess password. We strongly advise that Your password be at least 8 characters long, include upper- and lower-case letters, at least one digit, and at least one symbol (e.g.; period, comma, hyphen, etc.), and that Your password not contain repeated characters or digits (e.g.; 'aaaaa' or '22222'), sequences of letters or digits (e.g.; 'abcd', 'qwerty', '1234', etc.), common words or phrases (e.g.; 'Password', 'secret', 'iloveyou', etc.) or information readily obtained from Your social media presence (e.g.; Your date of birth, home-town, pet's or spouse's name, favorite band or car, etc.).

To the maximum extent permitted by law, We disclaim any responsibility or liability from any misuse of Your Personal Information resulting from illegal, improper, negligent, malicious, or inappropriate acts or omissions by You or any third party, or from any conduct other than willful misconduct by Us.

9 Backups and Retention of Data

We may retain Your Personal Information for as long as You continue to use the myKlovr Platform and for as long thereafter as permitted or required by applicable law, or until You request that we delete Your data, subject to certain exceptions as provided below. If We delete Your Personal Information it may still be contained on backup media or other systems until such time as it is destroyed or overwritten.

10 Your Rights

Any right detailed below which You may exercise from within the myKlovr Application, You may also exercise by emailing Your request to support@myklovr.com and including Your myKlovr.com login email address, a valid phone number, and the nature of Your request. We reserve the right to verify the authenticity of such requests by any reasonable means, including by emailing a verification code or link to Your myKlovr login email address, and we may withhold compliance with Your request until You have authenticated Your ownership of the subject myKlovr Application account to our reasonable satisfaction, including by replying to the verification request or clicking a link we emailed to You.

10.1 Opting Out From Marketing

We provide means in the Privacy Preferences section of the Settings page of the myKlovr Application for You to opt out of some or all marketing communications. We will update our record of Your preferences within forty-eight hours of Your change, but it may take up to ten days for communications to reflect Your preferences, for example in cases where marketing emails have already been submitted to a service provider.

10.2 Accessing, Correcting, and Deleting Your Personal Information

You may request that we disclose to You, in reasonably accessible format, the Personal Information that we have about You by clicking the "Disclose My Information" request button in the Privacy Preferences section of the Settings page of the myKlovr Application. In general, we will verify your identity and reply with disclosure of Your Personal Information within 45 days by secure email or other secure means. We will verify your identity by comparing Information you have provided in your request with Information in our records, by using two factor authentication, or by any other reasonable, legally permissible means.

If Your Personal Information is incorrect, You may correct it by entering the correct information in the related data-entry field within Your portfolio pages, MyCollegePlan pages, Career Plan pages, or other pages of the myKlovr Application. If the error is not related to an available data entry field, You may submit Your request to have Your Personal Information corrected by email using the procedure specified at the beginning of this section.

10.3 Other Rights

Residents of other states may have further rights established by law, as detailed below.

11 California Notice Regarding Categories, Sources, and Business and Commercial Use of Personal Information

The CCPA gives You the right to be informed of the following regarding the collection, source and use of Your Personal Information:

Category Category Name and Description Source Business Use
A Identifiers: name, postal address, email address, IP address, telephone number Provided by user in registration and other forms, IP address collected automatically from user browser Operational use including account authentication, billing, fulfilling purchases, communications, customer service
B Personal Information categories listed in the California Customer Records statute – identifiers, education, employment information Provided by user in response to data collection forms Same as A, plus training and optimizing our artificial intelligence system, selecting information potentially of interest to You or Your family, targeting advertising
C Protected classification characteristics under California or federal law – age, date of birth, marital status, gender Same as B Determining service eligibility and terms of address
D Commercial information – products or services purchased, obtained, or considered, or other purchasing data Same as B, plus internal records of purchases and consumption of services To fulfill purchases, to provide services requested, to offer services related to or supplementary to services already consumed or purchased
E Internet or similar network activity, browsing or search history, information about a consumer's interaction with a website, application, or advertisement Collected from logs of user interactions with the myKlovr Platform Determining consumer interests, providing information of interest related to prior information requests, directing advertisements to consumers, and optimizing behavior and performance of the website
F Inferences drawn from other Personal Information, profile reflecting a person's preferences, characteristics, psychological trends and attitudes Provided by user in response to questions, collected from logs of user interactions with the myKlovr Platform Used to suggest topics of interest, to recommend corrective courses of action to the consumer, and to direct advertising to the consumer

12 CCPA Rights of California Users

The CCPA grants California consumers certain rights with respect to their Personal Information collected and used by myKlovr Platform.

12.1 Disclosure of Personal Information Collected and Sold

The CCPA gives You the right to obtain information about the categories and sources of data we have collected about You, our business and commercial purposes for collecting and selling that data, the categories of third parties with whom we have shared Your specific data, and the category of data and category of recipient for each time we sold or disclosed Your data.

You may exercise this right by clicking the "Who Has My Information" button in the Privacy Preferences page of the Settings Section of the myKlovr Application. In response, we will email You a description of the categories and sources of information that we have collected about You, our business and commercial purposes for collecting and selling that data, the categories of third parties with whom we have shared Your specific data, and the category of data, category of recipient, and specific recipient name and address for each time we sold or disclosed Your data. This response serves to comply both with CCPA and CalOPPA.

12.2 Opting Out of the Sale of Personal Information

The CCPA gives You the right to direct us not to sell Your Personal Information.

To exercise this right, click the checkbox on the sign-up page on which You request a myKlovr Application account, the button labeled "Do Not Sell My Data" in the Privacy Preferences page of the Settings section of the myKlovr Application, or the checkbox at the bottom of any page of the myKlovr Application on which we collect Personal Information about You. In response, we will register Your request promptly and will cease selling Your Personal Information.

12.3 Deletion of Information

The CCPA gives You the right to direct that we delete all Personal Information that we have about You.

You may exercise this right by clicking the "Delete My Personal Information" button on the Privacy Preferences section of the Settings page of the myKlovr Application. We will first verify your identity as described above. If we are able to verify your identity, we will delete the Information we have about You from our current database within 45 days of Your request. If we are not able to verify your identity, we will treat you deletion request as opt-out of the further sale of your Personal Information. We may retain copies of Your Personal Information in back-up copies of our database, but if we ever retrieve those back-up copies, we will promptly delete Your Personal Information before it is put into use or is accessed. If Your Personal Information is reflected in historical reports or if Your anonymized data (data without references to Your Personal identifying information) is used in original or aggregated form by our systems, such derivative data will not be updated to reflect Your deletion.

NOTICE: Once You delete Your Personal Information, we are unable to provide the service of the myKlovr Application to You, because the application depends on Your Personal Information to function. If You are paying for Your myKlovr Application account by credit card, then we will cancel Your account when You delete Your data. If You obtained Your myKlovr Application account by signing up through Your employer's (or an association or other organization) benefits portal or other third-party web service, then we are unable to cancel Your account or to terminate billing for Your account. You are responsible for cancelling Your myKlovr account by the same means You used to register for it in order to terminate Your financial responsibility for Your myKlovr account. YOUR FINANCIAL RESPONSIBILITY DOES NOT END WHEN YOU DELETE YOUR DATA, YOU MUST ALSO CANCEL YOUR ACCOUNT.

The CCPA provides several exemptions from the requirement that we delete Your Personal Information upon Your request, and under certain circumstances we may not delete Your Personal Information, or delete all of Your Personal Information, even when You request that we do. Here are some of the reasons established under the CCPA for Us not to delete some or all of Your Personal Information according to Your request:

  1. We require the data to complete a transaction for which we collected the information, or to provide goods or services You purchased;
  2. To detect or investigate security incidents;
  3. To protect, investigate, or respond to malicious, deceptive, fraudulent, or illegal activity, or to report to law-enforcement or to prosecute those responsible for such activities; or
  4. As required by law, subpoena, or other authorized governmental action.

12.4 Accessing Personal Information

The CCPA gives You the right to request that we provide to You the Personal Information that we have about You. The means for exercising this right are specified in Section 10 ("Your Rights").

12.5 Non-Discrimination

The CCPA gives You the right not to be discriminated against because You have elected not to have Your Personal Information sold.

If You elect not to have Your Personal Information disclosed or sold, then we will be unable to provide certain valuable services that are available to other myKlovr Application users that involve disclosing Your Personal Information, for example being introduced to colleges which are seeking students such as You, or being introduced to service providers that help students finance their college educations or obtain vocational training. However, we will continue to provide all aspects of the myKlovr Application service which we can provide without disclosing Your Personal Information to third parties, without bias because of Your election.

12.6 Minors

As required by the CCPA, We confirm that we do not knowingly sell the Personal Information of individuals under the age of 13. We require consent of a parent or guardian before we collect or use any Personal Information of a child below the age of 13. We will follow the CCPA guidelines for ensuring that any individual who provides consent on behalf of a minor is the child's parent or guardian and that any person requesting to know or delete a minor's Personal Information is the parent or guardian of the child. For minors over 13 years of age and less than 16 years of age, We require a two step opt-in process consenting to the sale of their Personal Information or the consent of the minor's parent or guardian.

12.7 Authorized Agent

The CCPA gives You the right to appoint an agent to act on Your behalf to exercise Your CCPA rights with respect to the myKlovr Platform. According to the CCPA, the authorized agent must register with the California Secretary of State. We will honor a request from an authorized agent on Your behalf, provided that You provide written authorization to the authorized agent to act on Your behalf, provided we can verify Your and Your agent's identities, and provided the agent submits proof of authorization to us via email sent to support@myklovr.com.

13 Other Rights of California Users

13.1 Shine the Light Rights

The California Online Privacy Protection Act ("CalOPPA") provides California residents the right to request information regarding our disclosure of their Information to third parties, including the categories of Information shared and a list of the names and addresses of third parties with whom the Information was shared. If You are a California resident and would like to exercise Your rights under the Shine the Light provision of California Online Privacy Protection Act ("CalOPPA"), click the "Who Has My Information" button on the Privacy Preferences page of the Settings section of the myKlovr Application. Section 12.1 ("Disclosure of Personal Information Collected and Sold") describes how we will respond to this request.

13.2 Browser Do Not Track Signals

Most browsers contain a "do-not-track" setting. In general, when a "do-not-track" setting is active, the user's browser notifies other websites that the user does not want their Personal information and online behavior to be tracked and used, for example, for interest-based advertising. As required by CalOPPA, we inform You that, as is the case with most websites, we do not honor do-not-track requests or alter our behavior when a user of one of our Websites has activated the "do-not-track" setting on her/his browser.

13.3 Privacy Rights for California Minors in the Digital World

The California Privacy Rights for California Minors in the Digital World Act ("PRCMDW") provides that a California minor using a website has the right to request that any content they have posted on the website be removed.

You may exercise this right by clicking the "Take Down My Posts" button on the Privacy Preferences page of the Settings section of the myKlovr Application. We will promptly disable the display of any posts made on the myKlovr Application website through Your account. If another user has copied any material You have posted and has reposted that material as their own post, we do not have the ability to take down that re-posting of Your material, nor are we obligated under the PRCMDW to take down such re-posted material.

14 Rights of Nevada Users

Nevada State residents have the right to submit opt-out requests to website operators instructing those website operators not to sell any "covered information" that the website operators have collected about the Nevada State residents to any third party unless the consumer has a direct relationship to the third party. Covered information includes a consumer's name, postal and email addresses, telephone number and Social Security Number, and includes the Information described above in Section 6 ("Personal Information We Gather"). If You are a Nevada State resident and You wish to exercise Your right to request that we to stop the sale of Your Information to third party data brokers, click the "Do Not Sell My Data" button in the Privacy Preferences page of the Settings section of the myKlovr Application. In response, we will register Your request promptly will cease selling Your Personal Information.

15 Changes to This Policy

We reserve the right to revise this Policy at any time. We will post the updated Policy on our Website. Any such revisions will be effective thirty (30) days after posting to the Website and will apply to all Information collected by us both before and following the effective date. If we expand the way we use Information, we will notify users by: (a) sending the modified Policy to our users via email or (b) by any other reasonable means acceptable under applicable state and federal law.

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