Privacy Policy

 

Effective date: July 14, 2020

Introduction

Student Playbook Series, LLC, and its programs (Freshman Playbook, Freshman Forms, etc.), partner organizations and affiliates (“Company”, “we” or “us”) respects your privacy and is committed to protecting it through a commitment to this Privacy Policy (“Privacy Policy” or “Policy”).  This Policy explains how we collects and processes your Personal Data when you visit and/or register on our Site which include but is not limited to www.studentplaybook.com, www.freshmanforms.com and www.freshmanplaybook.com.

Each time you use our Site, the current version of this Policy will apply. Accordingly, whenever you use our Site, you should check the date of this Policy and review any changes since the last version.

“Personal Data” is any information that we collect that enables us to provide our services to you and identify you, directly or indirectly, by reference to an identifier such as your name, identification number, location data, online identifier, or one or more factors specific to your physical or social identity.

By visiting our Site or any other affiliate websites, you acknowledge that you have read and understood the processes and policies referred to in this Privacy Notice and agree to abide them.

Users

StudentPlaybook.com

Users of StudentPlaybook.com. Users of Studentplaybook.com are college students typically in their junior or senior year who are seeking guidance and coaching as they prepare for their post-graduate career.

Not intended for any person under the age of 18. No one under age 18 may provide any information to Us through Studentplaybook.com or on the SP Platform. This service is intended solely for students above the age of 18 seeking guidance for college and post-college and therefore, we do not knowingly collect personal information from anyone under 18. If you are under 18, do not provide any information to the SP Platform or make any purchases through the SP Platform. If we learn we have collected or received personal information from anyone under 18 we will delete that information. If you believe we might have any information from or about a person under 18, please contact us immediately so we may take the appropriate actions.

 

Freshmanplaybook.com

Users of Freshmanplaybook.com. Users of Freshmanplaybook.com are high school seniors, who, with parental consent who are seeking guidance and coaching as they prepare for their college career.

Not intended for any person under the age of 18. No one under age 18 may provide any information to Us through Freshmanplaybook.com or on the FP Platform without the consent of their parents or legal guardians. This service is intended solely for students who have the requisite parental consent and therefore, we do not knowingly collect personal information from anyone under 18. If you are under 18, do not provide any information to the FF Platform or make any purchases through the FF Platform. If we learn we have collected or received personal information from anyone under 18, without parental consent, we will delete that information. If you believe we might have any information from or about a person under 18, please contact us immediately so we may take the appropriate actions.

Freshmanforms.com

Users of FreshmanForms.com. This Privacy Policy is targeted to Users in the United States (“US”) only and is governed by and operated in accordance with US laws set forth in the Terms of Use. We disclaim any representation or liability that the Platform is operated in accordance with the laws of other jurisdictions.

Not intended for any person under the age of 18. No one under age 18 may provide any information to Us through Freshmanforms.com or on the FF Platform. This service is intended solely for the parents of students and therefore, we do not knowingly collect personal information from anyone under 18. If you are under 18, do not provide any information to the FF Platform or make any purchases through the FF Platform. If we learn we have collected or received personal information from anyone under 18 we will delete that information. If you believe we might have any information from or about a person under 18, please contact us immediately so we may take the appropriate actions.

Users Under 13

Please note that our Site is not directed to children under the age of 13; if you are 13 years or younger, do not use our Site. We do not knowingly collect Personal Data from children under the age of 13. If we learn that Personal Data of persons less than 13 years of age has been collected through our Site, we will take the appropriate steps to delete this information.

How we Collect Personal Data

  1. Personal Data that you give us

With your consent, we may collect and process the following Personal Data in order to provide our services to you:

  • Contact information including name, mailing address, email, date of birth, gender and telephone number;
  • Payment information: We use PCI compliant third party payment processors (e.g. Stripe, Braintree) to process any credit card transactions. We do not store or have access to your credit card information;
  • Other information you provide us in order to allow us to provide our services to you.
  1. Technical data we collect from you

With regard to each of your visits to the Site, we will automatically collect the following information that is sent to us automatically by your web browser and we may use this information to generate aggregate statistics about visitors to our Site. We may use this for various business purposes such as providing customer service, fraud prevention, market research, and improving our Site. Please check your web browser if you want to learn what information your browser sends or how to change your settings. We will only consider this information to be Personal Data to the extent it can be used to identify you when combined with other information.

  • Preferences: Time zone, language, zoom size, etc.
  • Identifiers: IP address
  • Type: type of device, operating system or platform (Mac, Windows), browser information (type, version), etc.
  • Connection: Internet provider or mobile carrier name, connection speed and connection type; internet service provider, etc.
  • External pages: URL of the last and next page visited, etc.
    • Use of the Platform: Data, pages viewed, time spent on a page, click through, clickstream data, queries made, search results selected, history, comments made, etc.
    • Location: Geographic and network location, etc.

Additionally, we may collect information about your interactions and transactions with us including:

  • Information requested by us when you report a problem with the Platform.
  • Records and copies of your correspondence (including email addresses), if you contact us.
  • Your responses to surveys that we might ask you to complete for research purposes.
  • Details of transactions you carry out through the Platform and of the fulfillment of your orders.
  • Usage details, online activities over time and across third-party websites, buying habits and other behavioral tracking.
  1. Personal data we collect from others

This is information we receive about you if you use any of the other websites (operated by us or another member of our group) or use any other services provided by another member of our group or us.

Cookies

Like many websites, our Site uses cookies to distinguish you from other users of the Site. This helps us to analyze the use of the Site to customize and improve the content and the layout of the Site.

When you first access the Site, you will receive a message advising you that cookies are in use. By continuing to browse the Site, you agree to our use of cookies as described in this Privacy Notice.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer, if you agree. Cookies contain information that is transferred to your computer’s hard drive.

We use the following cookies:

  • Strictly necessary cookies
  • Analytical/performance cookies
  • Functionality cookies

You do not have to accept our cookies and can block them by activating the setting on your browser that allows you to refuse all or some cookies. You may also delete them after they have been placed on your hard drive. If you do not accept or delete our cookies, some areas of the Site that you access may take more time to work or may not function properly. For more information about cookies, visit: http://www.allaboutcookies.org.

We only use Google Analytics to helps us measure how Users interact with us and to optimize our website.  You can learn more about Google Analytics by going here.

“Do not track” Signals

We support “do not track” signals (“DNT”). If you have DNT enabled in your web browser, we will not receive browser-related information from our advertising partners for tailoring advertisements.

How we Use Your Personal Data

We only collect and use your data with your consent which you provide when you visit and/or register on our Site.  We will only process your Personal Data, including sharing it with third parties as necessary to provide our services, where (1) you have provided your consent which can be withdrawn at any time, (2) the processing is necessary for the performance of a contract to which you are a party, (3) we are required by law, (4) processing is required to protect your vital interests or those of another person, or (5) processing is necessary for the purposes of our legitimate commercial interests, except where such interests are overridden by your rights and interests.

We may use Personal Data for the following purposes:

To provide the Service: We use your information to operate the Platform and provide the Service to you in order to carry out our obligations arising from your subscription to, or use of, our Services, or any other contract entered into between you and us and to provide you with information, products and other services that you request from Us.

For verification: We use your information to verify your identity in connection with our provision of the Service, for example in order to complete transactions relating to online payments you make using the Platform.

To communicate with you: We use your information to communicate with you in relation to one or more of the following:

  • to respond to your questions and provide related services
  • Changes to the Platform, Service or this Privacy Policy.
  • News and information we believe will be of interest to you related to the Services provided you have not opted-out of receiving that information.
  • to provide you with information about other events, products, and services we offer that are similar to those that you have already purchased, provided you have not opted-out of receiving that information.
  • To provide you, or permit selected third parties to provide you, with information about events, products, or services we feel may interest you, provided you have given your consent.
  • Invitations to participate in surveys and provide feedback to us provided you have not opted-out of receiving that information.
  • to transfer your information as part of a merger or sale of the business
  • For internal business purposes including but not limited to one or more of the following:
  • Internal data analysis.
  • Improving the Platform.
  • Developing other products and services based on research using aggregated data and analytics.
  • Composing our printed and online publications and marketing materials which are distributed to prospective customers and/or other third parties.
  • To ensure that content from our Site is presented most effectively for you and your computer

To display advertisements: We may use your Technical Data, e.g., your time zone or browser type, (though we do not use your Personal Data) to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your personal information for these purposes, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

To showcase stories: Only with your consent, we may use your information to showcase stories resulting from the Service in a dedicated page on the Platform, or in the community where you live with your consent. When we do so, we may attribute stories to the names submitted in connection with relevant User Contributions.

For other purposes: We may use your information in any other way we may describe when you provide the information, or for any other purpose with your consent.

Use of Personal Data we receive from other sources

We will combine this information with information you give to us and information we collect about you. We will use this information and the combined Personal Data for the purposes set out above (depending on the types of information we receive).

When we Share and Who Can Access Your Personal Data

Both Freshmanplaybook.com and Studentplaybook.com are powered by BenchPrep, a trusted third party partner.  When using our Services, you will also be subject to the Privacy Policy on BenchPrep.com, found here.  Additionally, students using the Platform may have access to coaching through a partnership with Kaplan Test Prep (“Kaplan”).  When using the services of Kaplan, you will be governed by Kaplan’s privacy policy, found here.  Further, We may share your Personal Data for the purposes described in this Privacy Notice with:

  • trusted third party partners (e.g. BenchPrep), partners, suppliers, and sub-contractors that assist us in providing our Services
  • analytics and search engine providers that assist us in the improvement and optimization of our Site
  • in the event that we sell or buy any business or assets, in which case we will disclose your Personal Data to the prospective seller or buyer of such business or assets

We will only transfer your Personal Data to trusted third-parties who provide sufficient guarantees in respect of the technical and organizational security measures governing the processing to be carried out and who can demonstrate a commitment to compliance with those measures.

Security and Storage

The Personal Data that you provide to us is generally stored on servers located in the United States. If you are located in another jurisdiction, you should be aware that once your Personal Data is submitted through our Site, it will be transferred to our servers in the United States and that the United States currently does not have uniform data protection laws in place.

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on servers behind firewalls. All information provided through forms on the Platform will be encrypted using SSL technology.

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

Unfortunately, the transmission of information via the internet is not completely secure. We cannot guarantee the security of your personal information transmitted to the Platform. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Platform.

You acknowledge that access to the Platform and Service is to be provided over various facilities and communications lines, and information will be transmitted over local exchange and internet backbone carrier lines and through routers, switches, and other devices owned, maintained, and serviced by third-party carriers, utilities, and internet service providers, all of which are beyond our control (collectively, “Carrier Lines”). We assume no liability for or relating to the integrity, privacy, security, confidentiality, or use of any information while it is transmitted over Carrier Lines, or any delay, failure, interruption, interception, loss, transmission, or corruption of data or other information attributable to transmission over those Carrier Lines. Use of the Platform, Service and Carrier Lines is solely at your risk.

If required by applicable law, we shall retain your personal information in accordance with federal, state and local laws, rules and regulations.

How Long we Store Your Personal Data

We will store your Personal Data, in a form which permits us to identify you, for no longer than is necessary for the purpose for which the Personal Data is processed and needed to provide our Service to you and for a period of time after in order to comply with our business needs. We may retain and use your Personal Data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements and rights, or if it is not technically reasonably feasible to remove it. Consistent with these requirements, we will try to delete your Personal Data upon request.

Your Rights

  1. Correction and removal

You may send us an email at [email protected] to request access to, correction or deletion of any personal information that you have provided to us, including but not limited to any User Contributions showcased on our Platform. We will endeavor to comply with any such request within a commercially reasonable time. Except for any User Contributions, we cannot delete individual pieces of your personal information except by also deleting your Login. 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 Platform, copies of your User Contributions may remain viewable in cached and archived pages for which we have no control (e.g. www.archive.org AKA wayback machine).

  1. Opting Out

Additionally, if you prefer not to receive marketing messages from us, please let us know by clicking on the unsubscribe link within any marketing message that you receive, or by sending a message to us at [email protected]

  1. Your European Rights

Your Rights Under GPDR*

(Freshmanforms.com will not accept any registrations from anyone residing outside of the United States and is only intended for U.S. citizens).

If you are based in a European Union country, Iceland, Liechtenstein, Norway, the United Kingdom, or Switzerland and you provide us with your personal information, you are afforded privacy rights under the General Data Protection Regulation (GDPR).

If you are based in a European Union country, Iceland, Liechtenstein, Norway, the United Kingdom, or Switzerland (collectively, the “EU”), you may have rights over your personal information we handle about you, including but not necessarily limited to:

* The right to access, receive or correct your personal information at any time

* The right to have your personal information erased (where there is no longer legal or necessary grounds to process or store your personal information)

* The right to have your personal information transferred to another at any time

* The right to restrict or otherwise object to, the processing of your personal information at any time where your personal information is not accurate, where the processing is unlawful, where your personal information is no longer needed or where there is no longer good legitimate grounds to process your personal information

* The right to object to your personal information being processed if the lawful basis for processing your personal information is either our or a third party’s legitimate interests or a reason of public interest, or we use your personal information for direct marketing

* The right to withdraw your consent to the collection, handling, storage and/or processing of your personal information at any time

* The right to complain to us and/or the appropriate EU “supervisory authorities” if you believe any of your rights are being violated

* The right to know if you are being “profiled” or “monitored” or if certain decisions are being made automatically based on your personal information

The lawful collection and processing of your personal information is necessary for us to perform the service of providing you with use of our Services and we always seek to provide you with affirmative options so that you may decide if you want us to process your data for a particular purpose. We strive to make certain that all of the data that we request is necessary in order to provide you with our service or to otherwise accomplish the stated purpose. When we share your data with a third party, we always inform you of the name of the recipient of such data. Further, all of the opt-in consents that are presented to you are intended to fully inform you whether you want us to process your data, the purpose behind processing your data and who, if anyone, we will be sharing your data with in order to accomplish that purpose.

Please note that if you are an individual who is based in the EU and between the ages of 13 to 16, we will not process any of the personal information that you may have submitted to us until we have promptly received the express consent from your parent or legal guardian. If this consent is not promptly provided to us, any data that you may have submitted during the account creation process will be purged from our system in order to make certain that we are not retaining any of your data.

Note also that we have put into place with our partners and members certain mechanisms of cooperation, communication, and agreements so that your EU privacy rights are also honored by our partners and members. Accordingly, should you decide to access, rectify, erase, object to or otherwise transfer any of your data that you submitted to us or if you wish to withdraw any one or all of your consents, please send your instruction to [email protected]

If you have any questions or concerns about your rights under the GDPR or the steps that we have taken to comply with the GDPR, please contact us at [email protected]

Additionally, you have the right to ask us not to process your Personal Data for marketing purposes. We will usually inform you (before collecting your Personal Data) if we intend to use your Personal Data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your Personal Data. You can also exercise the right by contacting us using the Contact Us section on our Site.

Under European data protection law, in certain circumstances, you have the right to:

  • Request access to your Personal Data
  • Request correction of your Personal Data
  • Request erasure of your Personal Data
  • Object to processing of your Personal Data
  • Request restriction of processing your Personal Data
  • Request transfer of your Personal Data
  • Withdraw your consent

In addition, where you believe that we have not complied with our obligations under this Privacy Notice or European law, you have the right to make a complaint to an EU Data Protection Authority, such as the UK Information Commissioner’s Office.

You can exercise any of these rights by contacting us using the Contact Us section on our Site.

  1. Your California Privacy Rights

This section contains disclosures required by the California Consumer Privacy Act (“CCPA”) and applies only to “personal information” that is subject to the CCPA. Consumers with disabilities may access this notice by contacting us at [email protected] and requesting assistance.

We collect from consumers the following categories of personal information about California consumers:

  • Personal and online identifiers, such as name and email address;
  • Categories of information described in Section 1798.80(e) of the California Civil Code, such as telephone number;
  • Internet or other electronic network activity information, such as interactions with our website; and
  • Professional or employment-related information.

We collect personal information from consumers, our clients, social networks, data analytics providers, and other third parties. We use and disclose the personal information we collect for our commercial and business purposes, as further described in this Privacy Policy. Our commercial purposes include advertising and marketing, while business purposes include auditing related to our interactions with you; legal compliance; detecting and protecting against security incidents, fraud, and illegal activity; debugging; and performing services.

While we disclose all categories of personal information, we collect to our service providers, we do not, and will not, sell personal information under the CCPA.

California residents have certain rights with respect to the personal information collected by businesses. If you are a California resident, you may exercise the following rights regarding personal information about you, subject to certain exceptions and limitations:

  • The right to know the categories and specific pieces of personal information we collect, use, disclose, and sell about you, the categories of sources from which we collected personal information about you, our purposes for collecting or selling personal information, the categories of personal information that we have either sold or disclosed for a business purpose, and the categories of third parties with which we have shared personal information;
  • The right to request that we delete the personal information we have collected from you or maintain about you.
  • The right not to receive discriminatory treatment for the exercise of the privacy rights conferred by the CCPA.

To exercise any of the above rights, please contact us online at [email protected]

To verify your request, we will compare the information you provide in your request to any information we maintain about you. Note that we may need to request additional information from you to verify your identity or understand the scope of your request, although you will not be required to create an account with us to submit a request or have it fulfilled.

You may designate an authorized agent to make a CCPA request on your behalf by designating such an agent in writing or through a power of attorney. We will require the agent to provide us with proof that you have authorized the agent to make the CCPA request on your behalf prior to accepting a request from the agent.

Contact us and Changes to this Privacy Notice

If we make any material changes to this Privacy Notice or the way we use, share, or collect Personal Data, we will notify you by revising the “Effective Date” at the top of this Privacy Notice, prominently posting an announcement of the changes on our Site, or sending an email to the email address you most recently provided us (unless we do not have such an email address) prior to the new policy taking effect.

Any changes we make to our Privacy Notice in the future will be posted on this page and, where appropriate, a notification will be sent to you by email. Please check back frequently to see any updates or changes to this Privacy Notice.

How to contact us

If you have any questions or concerns about this Privacy Notice, please contact us using the Contact Us section on our Site. Alternatively, you can contact us by phone at by sending an email to [email protected] or by post to:

ATTENTION:

Student Playbook, LLC

7101 Wisconsin Ave, #620

Bethesda, MD 20814

Email: [email protected]

*GDPR only applies to users of the Studentplaybook.com and Freshmanplaybook.com and not users of FreshmanForms.com.  Freshmanforms.com is a U.S. ONLY service.

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