Privacy

 Mobile App Privacy Policy 

Last modified: August 31, 2018 

Introduction 

The universities that developed the App (as defined below), including Oakwood University, Talladega College, Tougaloo College, and any other participating university or college that is added from time to time (collectively, “Company” or “We”) respect your privacy and are committed to protecting it through our compliance with this policy. 


COMPANY COMPLIES WITH THE FAMILY EDUCATIONAL RIGHTS AND PRIVACY ACT OF 1974, AS AMENDED (“FERPA”).  A STUDENT’S RECORD IS REGARDED AS CONFIDENTIAL AND RELEASE OF SUCH INFORMATION IS REGULATED BY FERPA.  STUDENTS HAVE THE RIGHT TO INSPECT THEIR RECORDS AT ANY TIME BY APPOINTMENT.  IN ACCORDANCE WITH FERPA, STUDENT INFORMATION (E.G., GRADES, TRANSCRIPT, ETC.) CANNOT BE RELEASED TO ANOTHER PARTY WITHOUT THE WRITTEN CONSENT OF THE STUDENT.  A COPY OF FERPA IS ON FILE IN THE RECORDS OFFICE.  PLEASE NOTE THAT CERTAIN INFORMATION APPLICABLE TO THIS POLICY MAY NOT BE COVERED OR REGULATED BY FERPA. 


This policy describes: 


·               The types of information we may collect or that you may provide when you download, install, register with, access, or use the College Pathway GEMConnect Application (the “App”). 


·               Our practices for collecting, using, maintaining, protecting, and disclosing that information. 


This policy applies only to information we collect in the App and in email, text, and other electronic communications sent through or in connection with the App. 


This policy DOES NOT apply to information that: 


·               We collect offline or on any other Company apps or websites, including websites you may access through the App. 


·               You provide to or is collected by any third party (see “THIRD-PARTY INFORMATION COLLECTION” below). 


Our websites and apps, and these third parties may have their own privacy policies, which we encourage you to read before providing information on or through them. 


Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, do not download, register with, or use the App. By downloading, registering with, or using the App, you agree to this privacy policy. This policy may change from time to time (see “CHANGES TO OUR PRIVACY POLICY” below). Your continued use of the App after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates. 

Children Under the Age of 13 

The App is not intended for children under 13 years of age, and we do not knowingly collect personal information from children under 13. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will keep such information confidential in accordance with this policy and use commercially reasonable efforts to contact the child’s guardian. If you believe we might have any information from or about a child under 13, please contact us at the applicable contact below (see “CONTACT INFORMATION”). 

Information We Collect and How We Collect It 

We collect information from and about users of our App: 


·               Directly from you when you provide it to us. 


·               Automatically when you use the App. 


Information You Provide to Us
 


When you download, register with, or use the App, we may ask you provide information: 


·               By which you may be personally identified, such as name, postal address, email address, telephone number, resume, or ANY OTHER INFORMATION THE APP COLLECTS THAT IS DEFINED AS PERSONAL OR PERSONALLY IDENTIFIABLE INFORMATION UNDER AN APPLICABLE LAW (“personal information”). 


·               That is about you but individually does not identify you, such as your major, minor, career objectives or history, resume, GPA, credits earned, student identification number, classification, academic standing, semester hours or other similar academic or career related information. 


This information includes: 


·               Information that you provide by filling in forms in the App. This includes information provided at the time of registering to use the App, posting material and requesting further services. We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with the App. 


·               Records and copies of your correspondence (including email addresses and phone numbers), if you contact us. 


·               Your responses to surveys that we might ask you to complete for research purposes. 


·               Your search queries on the App. 


You may provide information to be published or displayed (“Posted”) on the App or on public areas of websites you access through the App (collectively, “User Contributions”). Your User Contributions are Posted and transmitted to others at your own risk. Although you may set certain privacy settings for such information by logging into your account profile, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of third parties with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons. 


Automatic Information Collection
   


When you download, access, and use the App, it may use technology to automatically collect: 


·               Usage Details. When you access and use the App, we may automatically collect certain details of your access to and use of the App, including traffic data, logs, and other communication data and the resources that you access and use on or through the App. 


·               Device Information. We may collect information about your mobile device and internet connection, including the device’s unique device identifier, IP address, operating system, browser type, mobile network information, and the device’s telephone number. 


·               Stored Information and Files. The App also may access metadata and other information associated with other files stored on your device. This may include, for example, photographs, audio and video clips, personal contacts, and address book information. 


·               Location Information. The App does not collect real-time information about the location of your device. 


If you do not want us to collect this information do not download the App or delete it from your device. For more information, see “CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION” below. 


Information Collection Technologies
 


The technologies we use for automatic information collection may include: 


·               Cookies (or mobile cookies). A cookie is a small file placed on your smartphone. It may be possible to refuse to accept mobile cookies by activating the appropriate setting on your smartphone. However, if you select this setting you may be unable to access certain parts of our App. 


·               Web Beacons. Pages of the App and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related app statistics (for example, recording the popularity of certain app content and verifying system and server integrity). 

Third-Party Information Collection 

When you use the App or its content, certain third parties may use automatic information collection technologies to collect information about you or your device. These third parties may include: (1) advertisers, ad networks, and ad servers; (2) analytics companies; (3) your mobile device manufacturer or service provider. 


These third parties may use tracking technologies to collect information about you when you use the App. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites, apps, and other online services websites. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content. 


We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see “CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION” below. 

 

How We Use Your Information 

We use information that we collect about you or that you provide to us, including any personal information, to: 


·               Provide you with the App and its contents, and any other information, products or services that you request from us. 


·               Fulfill any other purpose for which you provide it. 


·               Give you notices about your academic or career path. 


·               Carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection. 


·               Notify you when App updates are available, and of changes to any products or services we offer or provide though it. 


The usage information we collect helps us to improve our App and to deliver a better and more personalized experience by enabling us to: 


·               Estimate our audience size and usage patterns. 


·               Store information about your preferences, allowing us to customize our App according to your individual interests. 


·               Speed up your searches. 


·               Recognize you when you use the App. 


We may also use your information to contact you about our own and third parties’ goods and services that may be of interest to you. If you do not want us to use your information in this way, please adjust your user preferences in your account profile. For more information, see “CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION” below. 


We may use the information we collect to display advertisements to our advertisers’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria. 

 

 

Disclosure of Your Information 

We may disclose aggregated information about our users, and information that does not identify any individual or device, without restriction. 


In addition, we may disclose personal information that we collect or you provide: 


·               To our subsidiaries and affiliates. 


·               To contractors, service providers, and other third parties we use to support our business. 


·               To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Company about our App users is among the assets transferred. 


·               To fulfill the purpose for which you provide it. For example, if you give us an email address to use the “email a friend” feature of our Website or App, we will transmit the contents of that email and your email address to the recipients. 


·               For any other purpose disclosed by us when you provide the information. 


·               With your consent. 


·               To comply with any court order, law, or legal process, including to respond to any government or regulatory request. 


·               To enforce our rights arising from any contracts entered into between you and us, including the Mobile Application EULA and for billing and collection. 


·               If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Company, our students and faculty or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction. 


 

Your Choices About Our Collection, Use, and Disclosure of Your Information 

We strive to provide you with choices regarding the personal information you provide to us. This section describes mechanisms we provide for you to control certain uses and disclosures of over your information. 


·               Tracking Technologies. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies or block the use of other tracking technologies, some parts of the App may then be inaccessible or not function properly. 


·               Promotion by the Company. If you do not want us to use your contact information to promote our own or third parties’ products or services, you can opt-out by adjusting your user preferences in your account profile by checking or unchecking the relevant boxes. You can also always opt-out by sending us an email stating your request to the applicable contact below (see “CONTACT INFORMATION” below). 


·               Targeted Advertising by the Company. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, you can opt-out by adjusting your user preferences in your account profile by checking or unchecking the relevant boxes. You can also always opt-out by sending us an email stating your request to the applicable contact below (see “CONTACT INFORMATION” below). 


We do not control third parties’ collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website. 

Accessing and Correcting Your Personal Information 

You can review and change your personal information by logging into the App and visiting your account profile page. 


You may also send us an email to the applicable contact below (see “CONTACT INFORMATION” below) to request access to, correct, or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. 


If you delete your User Contributions from the App, copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored by other App users. Proper access and use of information provided on the App, including User Contributions, is governed by our Mobile Application EULA. 

Your California Privacy Rights 

California Civil Code Section 1798.83 permits users of our App that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to the applicable contact below (see “CONTACT INFORMATION” below) or write us at the applicable mailing address for your university or college. 

Data Security 

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. 


The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our App, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. 


Unfortunately, the transmission of information via the internet and mobile platforms is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted through our App. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures we provide. 

Changes to Our Privacy Policy 

We may update our privacy policy from time to time. If we make material changes to how we treat our users’ personal information, we will post the new privacy policy on this page with a notice that the privacy policy has been updated or notify you by email to the primary email address specified in your account or an in-App alert the first time you use the App after we make the change. 


The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address and/or phone number for you and for periodically visiting this privacy policy to check for any changes. 

Contact Information 

To ask questions or comment about this privacy policy and our privacy practices, contact your university or college at the applicable contact below: 

 

Oakwood University: 


Address: 700 Adventist Blvd NW, Huntsville, AL 35896 

Email: CPGEM@oakwood.edu


Talladega College: 


Address: 627 W. Battle St., Talladega, AL 35160 

Email: msinclair@talladega.edu 


Tougoloo College: 


Address: 500 W. County Line Rd., Tougaloo, MS 39174  

Email: bgarner@tougoloo.edu