Privacy Policy

Using your personal data in a fair and transparent way is important to Open Admissions LLC, (“OET” or “we”). When you visit our website or use our desktop or mobile Apps and related Services (the “Platform”), we collect information about you, including information that can be used to identify you (“Personal Information”). The use of the phrase “Personal Information” is not intended as a legal term-of-art but rather a term as defined by this Privacy Policy and should not be construed otherwise. We know that you care how information about you is used and shared, and we appreciate your trust that we will do so carefully and sensibly. Additionally, we may obtain Personal Information about you from other third parties as described in this Privacy Policy. We collect this data to allow you to use the Platform and access other functionality on the Platform (the “Services”), as well as for the other purposes described in this Privacy Policy. Any terms not defined in this Privacy Policy shall have the same meaning as set forth in our Terms of Service.

This Privacy Policy is intended to help you understand (a) what Personal Information we collect, how we collect it, how we use it, and how we share it; (b) the choices you have related to your Personal Information; and (c) how we protect your Personal Information.

Please take a moment to review the terms of this Privacy Policy, which is incorporated into the Terms of Service governing your use of the Platform and Services, accessible at https:/openadmissions.io/.

A Note About Student Data: When using the Services, we will have access to and collect Student Data that may be provided by a variety of Users (see Terms of Service). We consider Student Data to be confidential and in general do not use such data for any purpose other than improving and providing our Services. 

Privacy Settings. OET allows users to set their own privacy settings and determine who, how, and where data is shared with third parties who have an account with OET.  Therefore, it is important that the user take time to understand and make appropriate use of those privacy settings. The users alone determine the extent to which their data is shared. Therefore, users agree to hold OET harmless for and against any claim they may have against OET related to third parties that access their data. 

By accessing the Platform or using the Services, you agree that we may collect, process, and share your information, and any Student Data you provide (including Personal Information) consistent with this Privacy Policy and the Terms of Service.

1. Types of Information We Collect. The type of Personal Information we collect may vary depending on your account type:

1. Information Provided to Us.

   • Student Data. Once registered, a student may provide information about himself/herself/themself. Personal Information collected from or about students, first and last name, email address, username/password, grade point average, SAT/ACT scores, financial aide information, sports, sports affiliations, other data typically provided as part of the college/university admissions process, along with other information associated with that Personal Information (“Student Data”). The Student may choose to link accounts with a Parent account, High School, or High School Guidance/Admissions Counselor. 

   • Parent Information. When a Parent User registers for an account, or is linked to his/her/their Student, to our Services or corresponds with us, we may collect Personal Information such as a name, e-mail address, username/password, payment information, financial information, etc. 

   • High School, or High School Guidance/Admissions Counselor. If a Student or Parent links the Student’s Account to his/her/their high school or high school guidance/admissions counselor or if the high school or high school guidance/admissions counselor creates their own account, Personal Information about the guidance/admissions counselor may be collected including first and last name, email address, username/password. 

2. Requested Information. During the course of providing the Services, we collect information about your use of the Services, as well as any information that you submit to the Services, such as answers to questions or content or messages posted or shared through the Services. In addition, we may ask you for Personal Information at other times, such as when you contact our technical support team, send us an e-mail, complete a user survey or otherwise communicate with OET.

3. Information We Receive Automatically. Like most websites and online services, OET and our vendors automatically collect certain types of usage information when you visit our Website(s), read our e-mails, use our Services or otherwise engage with us. This information is typically collected through a variety of tracking technologies, including cookies, web beacons, Locally Stored Objects (LSOs such as Flash or HTML5), log files, and similar technology (collectively, “Tracking Technologies”), and we may use third party providers to collect this information on our behalf. These tracking technologies collect information about how you access and use the Services (e.g., referring / exit pages and URLs, how frequently you access the Services, the pages you view, the links you click, and other actions you take on the Services); information about your browser and information about the device(s) you use to access the Services (e.g., Internet Protocol (IP address), browser type, browser language, Internet service provider, device type, model and manufacturer, a unique ID that allows us to uniquely identify your browser, device or account, operating system brand and model, and whether you access the Services from multiple devices). We may also collect information about your geographical location data at the city level. We may collect analytics data, or use third party analytics tools, such as Google Analytics, to help us measure traffic and usage trends for the Services and to understand more about the demographics and behaviors of our users. You can learn more about Google’s practices at http://www.google.com/policies/privacy/partners. We may also work with third party partners to employ technologies, including the application of statistical modeling tools, which permit us to recognize and contact you across multiple devices. Although we do our best to honor the privacy preferences of our users, we are unable to respond to Do Not Track signals set by your browser at this time.
   
   We use or may use the data collected through tracking technologies to secure the Services, improve the Services, to save you time, to provide better technical support, for promotional purposes, and to track website usage. For example, tracking technologies help us to:

• Keep track of whether you are signed in or have previously signed in so that we can display all the features that are available to you.

• Remember your settings on the pages you visit, so that we can display your preferred content the next time you visit.

• Customize the function and appearance of the pages you visit based on information relating to your account; for example, to default you to a particular grade level, or to remember customized settings for a report.

• Track website usage for various purposes including website optimization, website improvement, sales, marketing, and billing.

Most browsers are initially set up to accept cookies, but you can reset your browser to refuse all cookies or to indicate when a cookie is being sent. However, some features and services (particularly those that require you to sign in) may not function properly if your cookies are disabled. You may also set your e-mail options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our e-mail and performed certain functions with it. Deleting cookies does not prevent the collection of information through non-cookie technologies and does delete Local Storage Objects (LSOs) such as Flash objects and HTML5. You can learn more about Flash objects — including how to manage privacy and storage settings for Flash cookies — on Adobe’s website or by clicking here. If you choose to delete Flash objects from our sites, then you may not be able to access and use all or part of the sites or benefit from the information and services offered. 

We and our third party partners may also use cookies and tracking technologies for advertising purposes. For more information about tracking technologies, please see “Third Party Tracking & Online Advertising” below and review our Cookie Policy.

4. User Account Information. When you register for the Platform or use our Services, we ask that you provide information that can be used to personally identify you. This includes details such as your full name, email address, phone number, date of birth, delivery address, and billing address.

5. User Credentials. When you register for the Platform, you will be asked to provide credentials to allow you to access your account. These credentials may include a username, password, security questions, and responses to security questions.

6. Payment Card Information. We use third parties to process payment information. Therefore, we do not collect or store card numbers on our systems. All payments are processed using a secure third party. Payments made using the third party are subject to the Terms and Conditions and Privacy Policy for that organization. Prior to payment, you may review those documents. OET is not responsible for data or information collected and/or stored by any other third party. 

7. Precise Location Data. In some circumstances, we may collect precise geolocation data (geolocation data sufficient to identify a street name and name of a city or town) from your device when you access the Platform. 

8. User Content. We collect the data you submit when you contact OET customer support or otherwise engage directly with OET personnel. User Content may include metadata relating to the method you use to communicate with OET.

9. Usage and Device Data. We collect certain information automatically when you access the Platform or by using cookies, as described below and in our Cookie Policy. This technical information may include your browser type and operating system; your Internet Protocol (IP) address, which is the number automatically assigned to your computer whenever you access the Internet and that can sometimes be used to derive your general geographic area; websites you visited before and after visiting the Platform; pages you view and links you click on within the Platform; information collected through cookies, web beacons, and other technologies; information about your interactions with e-mail messages, such as the links clicked on and whether the messages were opened or forwarded; and standard server log information.

We may combine technical information that does not identify you with Personal Information. If we do so, we will treat the combined information as Personal Information under this Privacy Policy.

2. How We Collect Information. We may collect information from you in the following ways:

1. From You Directly. We receive Personal Information directly from you or affiliated Users (such as Parents or High Schools) when provided to us, such as when you register for the Platform. Additionally, you may be required to provide Personal Information when you contact us for support or with questions so that we can respond appropriately.

2. From Third Parties. We receive Personal Information from third parties that have legally obtained it, either directly from you or from other third parties. This may be from School Personnel, Parent Users, Colleges and Universities, accrediting bodies, or other third parties or third-party applications that you use to connect to the Services.

3. How We Use Your Information. We may use information that we collect from you for the following purposes, or as otherwise identified at the time of collection:

1. Providing Services. We may use Personal Information to make the Platform and Services available to you. For example, we may use your Personal Information to create and update your account; facilitate the fulfillment payment; administer and manage your account; authenticate your identity; protect your account; provide you with updates about your orders and account; and administer any contest or promotions.

2. To Improve, Personalize, and Develop the Services. We use information to tailor the content and information that we may send or display to Users, to offer personalized content and instructions, and to otherwise personalize your experience while using the Services, including on various devices you may use to access the Services. We collect statistics to better understand how Users access and use our Services, monitor the effectiveness of our Services, detect usage patterns, and to diagnose or fix technology problems. We also use information to demonstrate the effectiveness of the Services and perform research, and to develop, support, and improve our Services and other educational products and services.

3. Communicating With You. We may use your Personal Information to communicate with you. For example, we may send you text messages or other notifications (such as “push notifications” through your mobile device) about the status of your orders and deliveries. You may control how we communicate with you by adjusting your notifications preferences in your account settings. OET also uses the information we collect (which may include call recordings) to provide customer support, including to investigate and address user concerns, and to monitor and improve our customer support responses and processes. We do not use Student Data to send marketing communications, and we do not send marketing communications to student or child users. 

4. Data Aggregation. We may use your Personal Information to create aggregated and/or anonymous data records (collectively “Aggregate Data”). We de-identify data by removing information (including any contact information) that would allow the remaining data to be linked back to you. We may use Aggregate Data for internal purposes, such as analyzing patterns, program usage, demographic trends, and user behavior patterns and preferences to improve our Services and for other lawful purposes.

5. Compliance, Protection, and Safety. We may use your Personal Information as we believe necessary to comply with any Applicable Laws, court orders, subpoenas; to respond to lawful requests by law enforcement, regulators, or government entities; to detect, prevent, investigate or combat possible crime, such as identity theft, or other fraudulent activity; to protect the security of the Platform and Services; to enforce or apply our online Terms of Service or other agreements; to protect our own rights or property or the rights, property, or safety of our users or others; and to investigate or address claims or disputes relating to the Services.

6. Research and Development. We use data for testing, research, analysis, product development and machine learning to improve the user experience. This helps us make our Services more convenient and easier to use, enhance the safety and security of the Services, and develop new services and features. OET performs the above activities on the grounds that they are necessary for purposes of OET’s legitimate interests in improving and developing new services and features.

7. Analytics. We may use analytics, machine learning, and data models (“Analytics”) to support our data processing activities. Some of our Analytics rely upon Personal Information that we collect from you, your interactions and use of the Platform, and from third parties. Using this Personal Information, our Analytics allow us to tailor our Services to your specific needs and preferences, provide certain services to our partners, and develop new features.

4. How We Share and Disclose Your Information. We may disclose Personal Information as follows: 

1. Third Parties. We share information with consent and at your direction with Colleges and Universities, High Schools and/or High School Guidance/Admission Counselors, Parents, and/or Students. The purpose of the Platform is to share admissions related information with these Third Parties. Use of the Platform is your express consent to share the data. We use third party cloud storage and build APIs into the third parties to allow for the exchange of data to provide the Services. OET has no control over the security measures taken by those third parties. Therefore, you agree that OET is not liable, and agree to hold OET harmless, for any data breach or incident that may occur on any of the third parties used by OET.

2. Affiliates and Business Transfers. We may share your Personal Information with our subsidiaries, and affiliates for use consistent with this Privacy Policy. Additionally, we may share your Personal Information in connection with, or during negotiations of, a transaction that alters the structure of our business, such as a reorganization, merger, sale, joint venture, assignment, transfer, change of control, or other disposition of all or a portion of our business, assets or stock, including a bankruptcy or similar proceeding.

3. Service Providers. We provide data, including Personal Information, to vendors, consultants, research firms, marketing (provided that we will not knowingly use Student Data to target advertising or marketing) and other service providers. These include payment processors and facilitators; analytics, background check and identity verification providers; cloud storage providers; data analytics providers; research partners, including those performing surveys or research projects in partnership with OET or on OET’s behalf; vendors that assist OET to enhance the safety and security of the Platform and Services; lawyers, accountants, and other professional service providers; and insurance and financing partners.

4. Compliance with Laws and Protection of Rights. We may disclose your Personal Information as we believe necessary to comply with any Applicable Laws, court orders, subpoenas; to respond to lawful requests by law enforcement, regulators, or government entities; to detect, prevent, investigate or combat possible crime, such as identity theft, or other fraudulent activity; to protect the security of the Platform and Services; to enforce or apply our online Terms of Service or other agreements; to protect our own rights or property or the rights, property, or safety of our users or others; and to investigate or address claims or disputes relating to the Services.

5. With Consent. We may share your data other than as described in this notice if we notify you and obtain your consent.

5. Third Party Tracking & Online Advertising. OET does not display any targeted advertising on the Services. Please note that although we may permit third party advertising partners to collect information from visitors to adult-directed areas of the Services for the purpose of displaying advertisements on other websites or online services on our behalf, we take many steps to prevent these third party advertising networks from collecting information for targeted advertising purposes once a subscriber to our Services signs into our Services. Please note that we rely on cookies to identify whether you are a subscriber to our Services and if you delete or block cookies, you may also delete the cookie which prevents subscribers from receiving targeted advertisements on other websites or online services.
   
   We work with third party online advertising networks which use technology to recognize your browser or device and to collect certain types of usage information about your visit to or use of our Services to provide customized content, advertising and commercial messages to you on other websites or services, or on other devices you may use. We (through the third party advertising networks) use this information to direct our online advertisements to those people who may find them relevant to their interests. Typically, though not always, the information is collected through cookies or similar tracking technologies. You may be able to set your browser to reject cookies or other tracking technology by actively managing the settings on your browser or mobile device, though these tools may not be effective for all third party tracking technologies, including Flash or HTML5 cookies. To learn more about cookies, clear gifs/web beacons and online advertising technologies and how you may opt-out of some of this advertising, you may wish to visit the Digital Advertising Alliance's resources at www.aboutads.info/choices and/or the Network Advertising Initiative's online resources, at www.networkadvertising.org.
   
   If you do not want to receive targeted advertising from OET based on your visit to our Website, you can email us at support@openadmissions.io to request that OET take steps to prevent third party advertising networks from using information about your visit to our website to display targeted OET advertisements to you on other websites or services on behalf of OET. OET cannot, however, guarantee that such steps will eliminate all collection and/or display of targeted advertising, and it may take some time for your request to take effect. Such requests will not prevent you from receiving contextual advertising or other types of advertisements that are displayed without taking into consideration whether you have previously visited the Website (for example, advertisements shown on the basis of a search term keyword). Such requests will not stop the collection of information for purposes other than advertising (e.g., for website analytics). This opt-out requires the setting of a cookie in your browser to record your request (and thus will no longer be effective if the required cookie is deleted), will be effective only in the browser from which you make the request, and will be effective for a maximum of one year from the request. If you delete cookies, change your browser settings, switch browsers or computers, or use another operating system, you will need to make the request again. You may make additional requests at any time. 

6. Data Retention and Deletion. 

1. Generally. OET retains user data for as long as necessary for the purposes described above and for our internal business purposes, which may extend beyond the termination or cancellation of your subscription or User Account. Please note that we may retain your Personal Information after a deletion request due to legal or regulatory requirements. You may request deletion of your Personal Information at any time as described in more detail in the Choice and Transparency section of this Privacy Policy. We may not be able to comply with your request in all circumstances. For example, certain requests to access, update or delete Personal Information and data associated with another user’s account or license. When account information is deleted or de-identified, certain residual information may remain within our archive records, such as for customer and technical support, billing, and tax purposes. OET reserves the right to delete or modify any account created by any user if there is a period of inactivity in excess of one-hundred twenty (120) days. Nothing herein shall require OET to delete an inactive account. 

2. Student Data. We will not knowingly retain Student Data beyond the time period required to support the purpose of the Platform, unless authorized by the Student or Parent. We do not delete or de-identify any Student Data from an active student user account unless specifically instructed to do so. After a period of inactivity, after the termination or cancellation of the license subscription, or in accordance with the terms of any applicable contract with OET we may terminate access to the account. We may not be able to immediately or completely delete all data in all instances, such as information retained in technical support records, customer service records, backups, and other similar business records. We will not be required to delete any information which has been de-identified or disassociated with personal identifiers such that the remaining information cannot reasonably be used to identify a particular individual.

7. Data Protection. We maintain a number of administrative, physical, and technological measures to protect the confidentiality, privacy, and security of your Personal Information. These controls vary based on the nature of the information and industry standards. Unfortunately, no website, server or database is completely secure or “hacker proof.” We therefore cannot guarantee that Personal Information you provide will not be disclosed, misused, or lost by accident or by the unauthorized acts of others. Safeguarding your Personal Information is also your responsibility. OET will make every effort to comply with data security laws and data privacy laws but, ultimately, the security of your account is yours and yours alone. We encourage you to change your passwords often, use a combination of letters and numbers, and make sure you are using a secure device to access the Platform. If you have forgotten your password, have reason to believe that the security of your account might have been compromised, or if you suspect someone else is using your account, please let us know immediately by sending an email to support@openadmissions.io. If Personal Information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and take all steps required by Applicable Laws. Nothing herein should be construed as a promise, representation, warranty, or assurance regarding data security and data privacy. 

8. Choice and Transparency. You may exercise control over your Personal Information in the following ways:

1. Device Permissions. Most mobile device platforms (iOS, Android, etc.) have defined certain types of device data that apps cannot access without the device owner’s permission, and these platforms have different methods for how that permission can be obtained. Please check the available settings on your device or check with your provider. 

2. Platform Inbox, Push Notifications, and SMS Messaging. When you first register to use our Platform, you may authorize us to communicate with you through the Platform inbox, push notifications, and SMS messages. You can adjust these settings at any time in the OET App.

3. Email Communications. We include an “unsubscribe” link in each electronic newsletter or promotional e-mail we send you as required by Applicable Law. If you no longer wish to receive such communications from us, please click that link and follow any additional instructions.

4. Tracking Technologies. Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. If you do not accept cookies, you may experience some inconvenience in your use of the Platform. 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 the Platform.

5. Updating and Correcting Your Information. If you are a registered user, you have the ability to update or correct your Personal Information by accessing your profile page once you are logged in. If you are unable to make the necessary updates or corrections there, please request changes by sending an email to support@openadmissions.io.  

6. Deleting Your Information. You have the right to request that we delete from our records any Personal Information from our systems, subject to certain exceptions. Once we receive and confirm your verifiable request, we will delete your Personal Information from our records unless an exception applies. Please note that it may take us several days to verify your identity and process your request.

9. Region Specific Notices. 

   1. Generally, States. This notice supplements our Privacy Policy. In certain regions, you may have certain additional rights. This may include the right to request access or to update or review your information, request that it be deleted or anonymized, or object to or restrict OET using it for certain purposes. If you wish to exercise a right, please contact OET and reference the Applicable Law. Our ability to respond to specific requests may be limited by applicable law and the functionality of our Services.

   2. California Minors’ Rights. If you are a registered User under the age of 18 residing in California, you are entitled to request removal of content or information you have posted publicly on our Services. To request removal, please contact OET for assistance. Please note that your request does not ensure complete or comprehensive removal, as the content or information may be retained subject to Applicable Law.

   3. General Data Protection Regulation (“GDPR”). If you are a resident in the European Union, United Kingdom, or other countries part of the European Economic Area, you may have certain additional rights:

      1. Right of Access & Portability. The right to obtain access to your Personal Information, along with certain related information, and to receive that information in a commonly used format and to have it transferred to another data controller. 

      2. Right to Rectification. The right to obtain rectification of your Personal Information without undue delay where that Personal Information is inaccurate or incomplete.

      3. Right to Erasure. The right to obtain the erasure of your Personal Information without undue delay in certain circumstances, such as where the Personal Information is no longer necessary in relation to the purposes for which it was collected or processed.

      4. Right to Restriction. The right to obtain the restriction of the processing undertaken by us on your Personal Information in certain circumstances, such as where the accuracy of the Personal Information is contested by you, for a period enabling us to verify the accuracy of that Personal Information.

      5. Right to Object. The right to object, on grounds relating to your particular situation, to the processing of your Personal Information, and to object to processing of your Personal Information for direct marketing purposes, to the extent it is related to such direct marketing.

      6. Right to Withdraw Consent. The right to withdraw your consent at any time (though withdrawing your consent will not affect the lawfulness of processing that occurred before you withdrew your consent).You may also have the right to make a complaint to the relevant Supervisory Authority. If you need further assistance regarding your rights, please contact us and we will consider your request in accordance with Applicable Law. In some cases, our ability to uphold these rights for you may depend upon our obligations to process Personal Information for security, safety, fraud prevention reasons, compliance with regulatory or legal requirements, or because processing is necessary to deliver the services you have requested. Where this is the case, we will inform you of specific details in response to your request.

For personal data subject to the GDPR, we rely on several legal bases to process the data. These legal bases include where (a) the processing is necessary to perform our contractual obligations in our Terms of Service or other contracts; (b) the processing is necessary for the purposes of our legitimate interests, such as in improving, personalizing, and developing the Services, marketing the Services, such as new features or products that may be of interest, and promoting safety and security; (c) you give us consent to do so for a specific purpose; or (d) the processing is necessary to comply with a legal obligation, a court order or to exercise or defend legal claims.

10. Notice to Users Outside the United States. OET is based in the United States. Regardless of where you access the Platform or Services, the information collected as part of that use will be transferred to and maintained on servers located in the United States. Any Personal Information that we obtain about you will be stored in the United States where data protection laws may not be as protective as those applicable where you live. By using the Platform or Services, you consent to this collection, transfer, storage, and processing of information to and in the United States. We may provide supplemental information with respect to the provision of our Services in certain regions or in connection with specific programs we offer outside the United States.

11. How We Protect Child Privacy. OET is not intended for, nor is it marketed to children. OET products are to be used by adults, either the parent/guardian, teachers or schools. No one under the age of 13 is  permitted to create an account. By registering with OET and using the Services you specifically warrant that you are of the appropriate age to do so. OET does not knowingly collect personally identifying information from children under the age of 13 without the consent and at the direction of a parent, legal guardian, or a School. Please contact us if you believe we have inadvertently collected information from a child under 13 without parental consent so that we may delete the information as soon as possible. 

12. Opt-Out. You have the right to request that we do not sell your personal information to Advertisers. Please ensure that any request is accurate and complete in accordance with this policy. We are not responsible for processing requests that have errors or omissions, including those made through third-party platforms.

    1. If you Live in California. When you first come to our Site, you will be given the option to click on a “Do Not Sell My Information” button on our landing page. If you click this button, we will not sell your identifiable personal information to Advertisers. We may still sell de-identified information about you, but the Advertisers will not be able to trace this information back to you or use it to market their products and services specifically to you. To opt-out, you may submit your request through our webform by clicking here, or submit a general privacy request in compliance with CCPA by clicking here; or you may send us an email to support@openadmissions.io, putting the words “remove my name” in the subject line of your email and a request to opt-out in the body of the email, and our support team will guide you through the process of opting out. 

    2. If you Live in Another State If you do not initially opt-out or at some point after giving us your personally identifiable information you later decide to limit the sale of your information to our third party Advertisers, or you no longer desire to continue to receive additional information from us about OET and our Advertisers, you may “opt out” by submitting your request through our webform by clicking here, or by emailing us at support@openadmissions.io, putting the words “remove my name” in the subject line of your email and a request to opt-out in the body of the email, and our support team will guide you through the process of opting out. Please note however that an Advertiser may have saved a copy of your account and account-related information from before you opted out. In the case of our email newsletters, you may opt out by clicking on the “opt out” link at the end of each email. If you agree to receive autodialed or pre-recorded calls and/or text messages from an Advertiser and later wish to opt-out, you should follow the direction in such call(s) or text message(s) or contact the school or other Advertiser directly. 

13. NOTICE TO CALIFORNIA RESIDENTS – YOUR CALIFORNIA PRIVACY RIGHTS. 

If you are a California resident (“you” or a “California Customer”), California law may apply to how we collect and use your personal information, and what rights you have in some circumstances. The following terms supplement our Privacy Policy and explain the rights of California Customers under the California Consumer Privacy Act (“CCPA”).

OET has set forth the different types of information we collect through our Services, 

Categories of Personal Information We Collect About You: A California Customer may request information about whether we have sold or disclosed personal information to any third parties for the third parties’ direct marketing purposes or for our business purposes. In general, if we have made such a sale or disclosure of your personal information, upon receipt of a verified request from you, we are required to provide a list of all third parties to whom your personal information was either sold or disclosed for business purposes in the preceding 12 months following your request, as well as a list of the categories of personal information that were sold or disclosed, the sources of it, and what it was used for. You may also request a copy of the personal information that we have collected about you in the last 12 months. 

You may have certain additional rights under the CCPA. You may request that we delete certain information we have about you. There may be exemptions from such requests under applicable law. For example, we need certain types of information so that we can provide the Services to you and for compliance with applicable law. You may also have the right to receive information about the financial incentives that we offer to you (if any). You also have the right to not be discriminated against (as provided for in applicable law) for exercising certain of your rights under the CCPA. This means that we will not penalize you for exercising your rights by taking actions such as denying you Services; decreasing Service quality; or suggesting that we may penalize you for exercising your rights. Except as specifically stated in this Privacy Policy we do not share your personal information collected by us with third parties for their direct marketing purposes without giving you the opportunity to opt out as more fully described above. 

If you are a California resident, you may request information about our compliance with California law by calling us toll free at INSERT, emailing us at support@openadmissions.io, or by writing to us at the address for our Data Privacy Officer to “Attention: Data Privacy Officer.”  Any such request must include “California Privacy Rights Request” in the subject line and include your name, street address, city, state and ZIP code.  Please note that we are only required to respond to up to two requests per visitor each year, and we are not required to respond to requests made by means other than through this designated email address or mailing address.

Identity Verification and Additional Information Needed to Process a Request.  We reserve the right to confirm your California residence to process your requests and will need to confirm your identity to process your requests to exercise your information, access or deletion rights.  As part of this process, government identification may be required.   California Customers can empower an “authorized agent” to submit requests on their behalf.  We will require the authorized agent to have a written authorization recognized by law confirming that authority.  We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it or to verify your or your agent’s identity.

14. Do Not Track Disclosure.  California Business & Professions Code Section 22575(b) provides that California residents are entitled to know how Niche responds to “Do Not Track” browser settings. We currently do not respond to “Do Not Track” signals because a uniform technological standard has not yet been developed.

15. Nevada Privacy Rights. FOR RESIDENTS OF NEVADA ONLY. In accordance with SB 220, Nevada consumers may opt-out of the sale of their personal information to third parties, as provided by law. If you reside in Nevada and you have provided us with your personal information, you may choose to opt-out of the sale of such personal information via the Datagrail privacy request form, accessible here. If you need help to opt out using the Datagrail privacy request form, then you can email us at support@openadmissions.io, with “Nevada Privacy Right” in the subject line and we will guide you through the process. We may request additional information from you in order to verify your identity and/or the authenticity of your request. For purposes of this opt-out, a “sale” of your personal information means an exchange of it by us to another party for money and the other party buys it from us for re-sale to a third party.

16. Contact OET. If you have any questions about this Privacy Policy or our privacy practices, or would like to contact OET’s Privacy Officer, please send an email to support@openadmissions.io or by writing to us at:
    
    
    

Open Education Technologies LLC
Attn: A.J. DiValerio III, Privacy Officer
113 North Bread Street

         Philadelphia, PA 19106

17. Links to Other Websites & Services. The Services may contain links to and from third party websites of our business partners, advertisers, and social media sites. If you follow a link to any of these websites, please note that these websites have their own privacy policies, and their practices are not covered by this Privacy Policy. We strongly recommend that you read their privacy policies and terms and conditions of use to understand how they collect, use, and share information. We are not responsible for the privacy practices or the content on the websites of third party sites.

18. Updates. We may occasionally update this Privacy Policy. If we make material changes, we will notify users by updating the “last updated” date at the top of this Privacy Policy and sending notice through email or the Platform. Your continued use of the Platform or Services after we have posted the revised Privacy Policy constitutes your agreement to be bound by the revised Privacy Policy to the extent permitted by law.
    
    

COOKIE POLICY

OET LLC, its subsidiaries, affiliates (“OET”) and other partners use cookies and other identification technologies on our websites, mobile applications, email communications, advertisements, and other online services (collectively, the “Services”) for a number of purposes, including: facilitating payments, authenticating users, remembering user preferences and settings, determining the popularity of content, delivering and measuring the effectiveness of advertising campaigns, analyzing site traffic and trends, and generally understanding the online behaviors and interests of people who interact with our Services. You can read more here about the types of cookies we use, why we use them, and how you can exercise your choices.

Cookies and Related Technologies Overview. 

Cookies are small text files that are stored on your browser or device by websites, apps, online media, and advertisements that are used to remember your browser or device during and across website visits. We also utilize other technologies that may identify you or the devices you use. For example, “pixel tags” (also called beacons) are small blocks of code installed on (or called by) a web page, app, or advertisement which can retrieve certain information about your device and browser, including, for example: device type, operating system, browser type and version, website visited, time of visit, referring website, IP address, advertising identifiers, and other similar information, including the small text file (the cookie) that uniquely identifies the device. Pixels provide the means by which third-parties can set and read browser cookies from a domain that they do not themselves operate and collect information about visitors to that domain, typically with the permission of the domain owner. “Local storage” refers generally to other places on a browser or device where information can be stored by websites, ads, or third parties (such as HTML5 local storage and browser cache). “Software Development Kits” (also called SDKs) function like pixels and cookies, but operate in the mobile app context where pixels and cookies cannot always function. The primary app developer can install pieces of code (the SDK) from partners in the app, and thereby allow the partner to collect certain information about user interaction with the app and information about the user device and network information.

Your Choices.

You have the right to choose whether or not to accept cookies. However, they are an important part of how our Services work, so you should be aware that if you choose to refuse or remove cookies, this could affect the availability and functionality of the Services. Cookies, other identification technologies, and Personal Information (as defined in the Privacy Policy), to the extent not controlled by OET, are governed by the third party’s policies and procedures.

Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. To do so, please follow the instructions provided by your browser which are usually located within the “Help” or “Preferences” menu. Some third parties also provide the ability to refuse their cookies directly by clicking on an opt-out link, and we have indicated where this is possible in the table below.

For further information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, you can visit https://www.youradchoices.com/. Deleting cookies does not prevent the collection of information through non-cookie technologies and does delete Local Storage Objects (LSOs) such as Flash objects and HTML5.

For mobile users, you have controls in your device Operating System that enables you to choose whether to allow cookies, or share your advertising ID with companies like OET or our advertising service providers. For information on controlling your mobile choices, you can visit https://www.networkadvertising.org/mobile-choices.

To help control or block certain ads in mobile applications, you may choose to download and utilize the DAA mobile app.

Types and Purposes of Cookies.

The following table sets out the different categories of cookies that our Services may use and why we may use them. The lists of third party cookie providers are intended merely as illustrative and should not be viewed as a comprehensive list.

Type of Cookie

Purpose

Who Services (for example)

Strictly Necessary

These cookies (including local storage and similar technologies) are essential to enable your use of the site or services, assisting with your account login so we can show you the appropriate experience and features (such as your account information and order history), and to edit your account settings. They may also provide authentication, site security, and help localize the language based on the geography of your visit.

• OET

Site Features and Services

These provide functionality that help us deliver products and Services. For example, cookies help you log in by pre-filling fields. We may also use cookies and similar technologies to help us provide you and others with social plug-ins and other customized content and experiences, such as making suggestions to you and others.

• Google

Analytics, Performance, and Research

These are used to understand, improve and research products and Services, including when you access the OET website and related websites and apps from a computer or mobile device. For example, we may use cookies to understand how you are using site features, and segmenting audiences for feature testing. We and our partners may use these technologies and the information we receive to improve and understand how you use websites, apps, products, services and ads.

• Google

• Adobe

Advertising

These cookies and pixels are used to deliver relevant ads, track email marketing or ad campaign performance and efficiency. For example, we and our ad partners may rely on information gleaned through these cookies to serve you ads that may be interesting to you on other websites. Similarly, our partners may use a cookie, attribution service or another similar technology to determine whether we’ve served an ad and how it performed or provide us with information about how you interact with them.

• Google

• Facebook

• Instagram

• Snap

• Microsoft/Bing

Mobile-Specific

These service providers use various technologies to deliver relevant mobile ads, track mobile marketing or mobile ad campaign performance and efficiency.

• Google

Contact Us. If you have any questions regarding our use of cookies, please send an email to support@openadmissions.io.