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Privacy Policy

Choices360 Privacy Policy

Last Updated: June 28, 2017

XAP Corporation including its subsidiary Bridges Transitions Inc. (collectively, "XAP") (the company that operates Choices360.com) has adopted the following Privacy Statement for the information collected at this website. When you use Choices 360 XAP has access to your information and may use your information to operate and maintain Choices360.com and in accordance with the terms of this Privacy Statement.

As Choices360.com evolves, we may update this Privacy Statement to reflect changes in the manner in which we deal with personal information, whether to comply with then-applicable regulations and self-regulatory standards or otherwise. The Privacy Statement posted here will always be current. We encourage you to review this Statement regularly. Please see additional information regarding amending this Statement in the Section entitled "Amending this Privacy Statement" below.

IMPORTANT NOTICE: Please see the information in the Section entitled "With whom personally identifying information and automatically collected information may be shared" for an understanding regarding the parties who may access your information.

WHAT THIS PRIVACY STATEMENT COVERS:

  • Your agreement to this Privacy Statement
  • Types of information collected
  • Creating an account when you are under the age of 18
  • Reasons we collect personally identifying information
  • Ways in which personally identifying information and automatically-collected information may be used
  • With whom personally identifying information and automatically-collected information may be shared
  • Security measures to protect information; Disclaimer
  • Cookies
  • Links
  • Modifying your information
  • Retention and Storage
  • Amending this Privacy Statement
  • Unenforceability
  • Questions

YOUR AGREEMENT TO THIS PRIVACY STATEMENT

When you use Choices360.com, you signify and affirm that you have read, understand, and agree to the terms of this Statement; that you are competent and capable of understanding, agreeing to, and complying with this Statement; and that this Statement forms a legally-binding agreement between you and XAP. You agree that this Statement is supported by reasonable and valuable consideration (which includes your use of Choices360.com), and you acknowledge your receipt of and the sufficiency of such consideration. If you do not agree with all of the provisions of this Statement, you may not use Choices360.com).

TYPES OF INFORMATION COLLECTED

This Statement covers information you expressly enter into Choices360.com and information that we automatically collect as you use Choices360.com.

THE PERSONALLY IDENTIFYING INFORMATION WE COLLECT

To use certain features of Choices360.com we will require you to provide us with information that personally-identifies you ("Personally Identifying Information" or "PII"). If you choose not to provide us your Personally Identifying Information, you will not be able to use certain features of Choices360.com. When you do provide us your PII, you are authorizing us to use that PII in accordance with this Statement and to store your PII on our servers in the United States. The categories of PII that Choices360.com may collect from you include your name, date of birth, address, email address, phone number, grade level, Social Security number, username and password, demographic data (such as your gender, ethnicity, and zip code), parent's or guardian's names, parent's or guardian's addresses and phone number and other contact information, user preferences, and such additional information as you choose to actively enter into Choices360.com and include in your portfolio or are required to provide by the college and/or financial aid applications that you choose to complete or other actions you choose to take through Choices360.com. Further, some schools provide students' transcript information to us, including at least the following student PII contained on the applicable student's transcript: Name, address, date of birth, gender, ethnicity, graduation year, email address, grade point average (GPA), Student number (from your school district), and State Student ID. If a school provides us this transcript information about you, we will automatically include that information in your account on Choices360.com.

AUTOMATICALLY-COLLECTED INFORMATION

When you use Choices360.com, we automatically track, collect, and store the following types of information (referred to as "Automatically-Collected Information"): 1) Date and time you access Choices360.com; 2) pages visited and features used, and the order of use; 3) type of computer or other operating device accessing Choices360.com and type of browser used to access Choices360.com; 4) referring source (meaning the website you visit prior to visiting Choices360.com); and 5) other similar information about the interaction between your browser and Choices360.com and activities in which you engage while using Choices360.com. Unless otherwise stated in this Statement, Automatically-Collected Information may be combined with your PII.

When you visit Choices360.com, we collect your Internet Protocol ("IP") address to track and aggregate Automatically-Collected Information. We also collect IP addresses of users when they log onto their account portfolios on Choices360.com in order to confirm the applicable user's identity.

CREATING AN ACCOUNT WHEN YOU ARE UNDER THE AGE OF 18

Between Age 13 and 17

If you are between the ages of 13 and 17, by using Choices360.com, you represent and warrant that you possess legal parental or guardian consent to use Choices360.com and provide PII and Automatically-Collected Information through Choices360.com.

Under Age 13

If you are under the age of 13 and you indicate to us that you are under age 13 when you enter your birthdate into Choices360.com, you can only create an anonymous account that does not require you to enter your name or other Personally Identifying Information. When there are open fields required in order to create such an anonymous account, you may not use any of these open fields to enter Personally Identifying Information, and your account portfolio will not include your Personally Identifying Information. Further, you will be restricted from using any areas of Choices360.com that require you to enter Personally Identifying Information. You will only be able to use Choices360.com features or modules that do not require you to enter Personally Identifying Information.

REASONS WE COLLECT PERSONALLY IDENTIFYING INFORMATION

www.Choices360.com collects PII from you primarily for three reasons. The first reason is to perform a task on Choices360.com requested by you, such as filling out a financial aid application. The second reason is to enable you to submit, in a convenient and efficient manner, information that is likely to be needed when you complete college admission, financial aid, and other applications and forms made available through Choices360.com or undertake a scholarship search on Choices360.com. The third reason is to enable XAP to respond to your questions or contact you when necessary in connection with the functioning of Choices360.com or to provide required notices.

 

WAYS IN WHICH PERSONALLY IDENTIFYING INFORMATION AND AUTOMATICALLY-COLLECTED INFORMATION MAY BE USED

Upon your instructions to do so, Choices360.com will use your PII to complete the following forms and surveys, to obtain information for you, and to effect transactions on your behalf:

  • Complete financial aid applications
  • Complete financial aid calculators
  • Complete a scholarship search
  • Complete Your Plan of Study, which can assist you in selecting courses and otherwise planning to meet admission requirements
  • Communicate your requests for information or material to colleges or other institutions you have specified
  • Complete applications for admission to educational institutions

Your PII and Automatically-Collected Information may also be used for the following purposes:

  • We may use your PII and Automatically-Collected Information to help diagnose problems with the Choices360.com server and to administer Choices360.com.
  • We may use your PII and Automatically-Collected Information to customize and tailor your experience using Choices360.com, displaying content on Choices360.com that we think you might be interested in and according to your preferences (but we do not track your activity across multiple websites for the purpose of serving targeted advertising to you).

Summary data consisting of a compilation of de-identified and aggregate data representing Choices360.com users may be collected by XAP and provided to various entities including colleges and other educational institutions represented on Choices360.com. NO PII IS MADE AVAILABLE AS PART OF THESE SUMMARY REPORTS. Some examples of summary data are the number of monthly visitors to Choices360.com, the number of admission applications submitted over Choices360.com, and the Choices360.com functions utilized by students in specified age or grade ranges.

WITH WHOM PERSONALLY IDENTIFYING INFORMATION AND AUTOMATICALLY-COLLECTED INFORMATION MAY BE SHARED

Except as set forth below, PII you enter on Choices360.com is not made available or distributed to third parties, except with your express consent or at your express direction. In particular, XAP will not give, sell, rent, trade, transfer, otherwise provide or provide access to your PII to any company, individual, or organization for its use in marketing or commercial solicitation or for any other purpose, except with your express consent and at your direction, unless it is pursuant to one of the exceptions listed below or necessary for operation of Choices360.com.

We may share your PII as follows:

  1. School Administration and Staff. Your account is meant to help you set goals and plan for the future. If you connect your account to a school or other site using Choices360.com as part of a career and education planning program, then professional staff at that school or site designated by the administration of the school or site to have access to the Choices360.com Professional Center will have access to view (i) your Choices360.com portfolio, including your PII that is part of your portfolio, (ii) email communications to and from you through Choices360.com, (iii) and all other PII and other content that you add to Choices360.com as part of your portfolio. This access is granted to these professional users so that they may assist you in a guidance capacity with your career and education planning.
  2. Parents and Guardians. You may request that your parent or legal guardian be given permission to view your portfolio (including all PII and other content that you add to Choices360.com as you use Choices360.com). And if you do make this request, your parent or legal guardian will be granted access to your portfolio and may view all of your PII associated with your portfolio.
  3. Bridges Transitions Inc. XAP Corporation and Bridges Transitions Inc. reserve the right to share PII with one another (regardless of which entity first collected the information) in connection with the maintenance and operation of Choices360.com and for use in accordance with this Statement.
  4. As Directed by You. Any time you request that we perform a task that involves a transfer of PII, the PII related to the performance of that task will be made available to a recipient you designate. For example:
    • If you submit an application for admission to a college or other educational institution, the PII required to complete that application and any other PII you entered onto the application will be provided on your behalf to the admissions office of the institution to which you are applying.
    • If you request that a college or other educational institution send you material, your contact information will be provided to that institution so the institution can send you material and contact you.
    Note: If you begin an application for admission to a college or other educational institution, your name and other PII entered on that application may be provided to the admissions office of that institution, even though you have not yet submitted a completed application to that institution. The institution may then contact you regarding your potential attendance.
  5. Required by Law. When required by law to comply with any valid legal process such as a statute, regulation, search warrant, subpoena, or court order, XAP may supply PII contained in your Choices360.com account as XAP reasonably determines, based on the advice of counsel, it is legally required to supply. XAP may also disclose PII in emergency situations, to protect your safety or the safety of others, to defend against legal claims, to enforce XAP's contractual or other rights, or to take actions regarding illegal activities or suspected fraud.
  6. Merger, Acquisition, or Sale of XAP. XAP may transfer your PII and Automatically-Collected Information to another entity if XAP is involved in a merger, acquisition, reorganization, restructuring, or other sale or transfer of all or any portion of its assets or business. In this event, we will, if allowed, use reasonable efforts to notify you when your information is transferred to a third party (this notification may be made via email to you or by posting a prominent notice on Choices360.com). Unless you consent otherwise, XAP will contractually require any successor to treat your PII in accordance with the promises made in this Statement, even after the transfer. But any information you provide after the transfer will likely be subject to a new privacy statement, and you should review that statement.
  7. Third-Party Payment Processor. We use a third-party intermediary to manage payment processing when you submit payment to apply to an educational institution through Choices360.com. This intermediary is not permitted to store, retain, or use your financial information or other PII, except for the sole purpose of processing payments you initiate.
  8. Third-Party Service Providers. We may share Automatically-Collected Information with our third-party service providers who assist us by performing services related to our operation of Choices360.com (such as hosting, data storage, and security). Such third-party service providers are not authorized to use your information in any way other than as described here and are required to keep the information confidential.

    Further, if your school, district or other organization purchases an optional license to use (and to allow you to use) the Do What You Are and/or Learning Style Inventory products provided by the third party HumaneSources, and if you elect to use one or both of these products and you click on the Do What You Are link and/or Learning Style Inventory link, you will be redirected to a HumaneSources' website. Any PII and Automatically-Collected Information you provide through such HumaneSources website when using the Do What You Are or Learning Style Inventory products will be collected by HumaneSources [and subject to HumaneSources' Privacy Policy (viewable at www.humanesources.com) when in HumaneSources' possession], but such information will be provided to us as well. When in our possession, such PII and Automatically-Collected Information will be subject to this Privacy Statement.
  9. Third-Party Analytics Services. We may use third-party analytics services to assist us in better understanding our Choices360.com users. For example, we use these services to track and analyze certain Automatically-Collected Information, such as feature usage. We only ever provide these service providers with (or allow these service provides to collect on our behalf) Automatically-Collected Information. We use the information collected from these service provides to make Choices360.com better and easier to use. The information we receive from these third parties may be re-associated with your PII after we receive it back from these third parties. These third parties are not authorized to use the information in any other way and are required to keep it the information confidential.

SECURITY MEASURES TO PROTECT INFORMATION; DISCLAIMER

XAP uses industry standard physical, electronic, and procedural security measures to protect against the loss, misuse, and unauthorized access, disclosure, alteration, and destruction of PII and Automatically-Collected Information we collect and store. For example, Choices360.com encrypts the PII you enter when it is in route from your browser to the Choices360.com web servers, and again when your PII is in route from the web servers to the back-end database servers using TLS 1.2. This practice helps prevent unauthorized third parties from intercepting and gaining access to your PII during transmission over the Internet. Choices360.com is WC3 compliant and performs properly on all major operating system platforms as well as all major modern internet browsers specifically including, but not limited to, Windows, Macintosh, Linux, iOS, Chrome, Safari, Firefox, Edge, Internet Explorer, and the build-in Internet browsers for iOS and Android.

PII residing on the Choices360.com server is password protected, and account access is provided only to the account holder who created the password, anyone to whom that account holder entrusted the password, designated school administrators and staff, and those employees of XAP who require such access to administer and maintain the Choices360.com system or to provide requested customer support to users of Choices360.com. Each XAP employee who has access to the PII residing on the Choices360.com server has agreed in writing to respect the privacy of all such PII. XAP trains employees to protect customer information and only authorize access for employees who XAP believes have a business need for that information. XAP holds employees accountable to a Code of Conduct and Ethics to protect user information.

The safety and security of your PII also depends on you. You should not send us sensitive PII via email, as this is not secure. You are also responsible for keeping your account username and password confidential. Please notify us if you become aware that your PII is lost, stolen, or used without permission; we may disable access to your account in order to prevent an unauthorized third party from accessing your account.

While we take industry-standard security measures to protect the privacy of your PII, we cannot guarantee that your PII will never be compromised. No Internet or wireless network transmission is ever 100% secure, and no security system can prevent all security breaches. We do not and cannot guarantee that there will be no unintended disclosures of your PII or that unauthorized third parties will not defeat our security measures or use non-public information for improper purposes.

COOKIES

We collect and store Automatically-Collected Information through a standard feature found in browser software called a "cookie." A cookie is a small file that a website transfers to a user's computer or other operating device, which may then be stored on the computer's or operating device's hard drive. Choices360.com uses cookies to remember you and personalize your web-viewing experience by keeping track of your session when using Choices360.com. Cookies enable you to maintain continuity as you move from page to page on Choices360.com and to avoid the nuisance of being asked to provide the same information repeatedly. Cookies also allow us to make sure that only your browser can exchange information regarding your account with our servers. Cookies also provide us Automatically-Collected Information about Choices360.com features used and activities conducted while using Choices360.com. We may use cookies to aggregate data about user traffic on and user interaction with Choices360.com so we can offer better experiences and tools in the future. The cookies we use are called session cookies, meaning they are set when you use Choices360.com and are erased when you end your session on Choices360.com or completely close your browser. The XAP cookies we use do not remain on your hard drive after you end your session on Choices360.com or completely close your browser.

Third-Party Cookies

We use third-party services provided by Google Analytics to track and analyze your Choices360.com activity. In order to gather this Automatically-Collected Information, we use a Google Analytics cookie on Choices360.com. If you don't want your Automatically-Collected Information used by Google Analytics, Google recommends installing the Google Analytics Opt-out Browser Ad-on, located here: https://tools.google.com/dlpage/gaoptout/.

We also have third-party widgets on Choices360.com, such as widgets provided by YouTube, PollDaddy and Screencast. When you use these third-party widgets by using features of our site, the widgets may place cookies associated with these widgets on your computer or other operating device.

Don't want cookies?

Most browsers are initially set to accept cookies. If you don't want cookies, you can set your browser to disable or refuse cookies or to alert you when cookies are being used. Please refer to your browser for information on how to disable and control cookies. You should note, however, that various Choices360.com services and features might not function properly when cookies are not utilized.

LINKS

Choices360.com hosts links to other sites or resources, and you may link to one of those sites or resources for a variety of purposes, such as but not limited to visiting an official college website and/or the HumaneSources website. These sites and resources have privacy statements that may differ from that of Choices360.com, and for your protection, we recommend that you read and understand the privacy policy at any website prior to providing personal information on that website or otherwise continuing to use that website. XAP is not responsible for the privacy practices or the content of any websites to which Choices360.com links or for the conduct of persons operating those websites. XAP does not have control over such external sites and resources. XAP shall not be liable for any content, advertising, products, or other materials on or available from such sites or resources. In addition, XAP shall not be responsible or liable, directly or indirectly, for any damage or loss caused or alleged to be caused by or in connection with use of or reliance on any such content, advertising, products, or materials on or available through any such site or resource.

MODIFYING YOUR INFORMATION

You may update on Choices360.com any PII you previously provided. To modify PII: (i) Sign in to Choices360.com, (ii) access either your portfolio or an application containing the information you want to change, (iii) modify that information using standard word-processing techniques, and (iv) save the change. If you want to remove PII that is in a required field (and not replace it with other data), you will need to contact XAP at 1-800-281-1168 and request that your account be inactivated.

Please recognize that if you delete information, it will no longer be available on Choices360.com so that, for example, if a college to which you previously submitted an application were to attempt to retrieve that application from Choices360.com after you made the deletion, the deleted information would no longer be accessible. Similarly, when accessed over Choices360.com, PII that has been updated or otherwise modified will appear in its then-current form, rather than in the form in which it may have been submitted at some earlier time. Please note that if you modify or delete any PII, we may retain the earlier-submitted PII, as described in the section below entitled "Retention and Storage."

RETENTION AND STORAGE

We retain all PII and Automatically-Collected Information in our databases to fulfill the purpose for which the information was collected. Because Choices360.com is intended to help you set goals and plan for your future education and career path, the PII you put into Choices360.com will be retained until you ask us to remove your information. Note that even after you ask that we remove your information from our databases, it may be impossible to remove some information, such as information tracked in our web server log files and information that may reside in backup files. We may also retain Automatically-Collected Information even after you request that we remove your information from our databases, for use in the aggregate and to analyze and improve Choices360.com. Further, even after you request that we remove your information from our databases, we may retain PII and Automatically-Collected Information to comply with applicable laws, rules, regulations, or guidelines; to prevent fraudulent activity; to protect ourselves against liability; to resolve disputes; and to enforce our contractual or other rights. Notwithstanding the foregoing, XAP will not retain PII for longer than is allowed under applicable law.

AMENDING THIS PRIVACY STATEMENT

XAP may amend this Privacy Statement from time to time. We will post any new Statement here, and you should review this Statement regularly to make sure you are aware of its terms. You can determine if this Statement has been revised since your last visit to Choices360.com by referring to the "last updated" date at the top of this Statement. If XAP makes any substantial changes to this Privacy Statement, XAP may also notify you (i) by posting a message on the Choices360.com homepage for at least thirty (30) days; or (ii) by providing direct notice to you via your contact information or by requiring that you agree to the revised Statement to next time you log into your account on Choices360.com. Once posted to Choices360.com, the new Privacy Statement will apply to all data previously submitted and subsequently submitted to Choices360.com, unless such use is prohibited by law.

UNENFORCEABILITY

If any part of this Statement is determined to be invalid, illegal, or unenforceable under applicable law, then the invalid, illegal, or unenforceable provision will be deemed to be superseded by a valid, legal, and enforceable provision that most closely matches the intent of the original provision, and the remainder of this Statement will continue in full force and effect.

QUESTIONS?

If you have any questions about this Privacy Statement and the privacy practices on this site, you may contact us at tech-support@xap.com.