The purpose of this Privacy Notice is to inform you of how College Loans, LLC (“Company” or “we” or “our” or “us”) collects, uses and discloses the personal information we collect from you when you visit www.collegeloans.me or any other website that we own or operate (the "Websites" or the “Sites”), how such information will be used by the Company (as defined below), its Advertising Partners, and/or other persons or entities with whom such information may be shared, as well as your choices regarding the collection, use and distribution of such information and the security procedures that we have implemented to protect your privacy. Please read this notice carefully to understand our policies and practices regarding your information and how it will be handled. By continuing to use the Websites, you expressly agree to be bound by this Privacy Notice, as amended from time-to-time by the Company at its sole and absolute discretion. You further agree to regularly review this Privacy Notice to ensure that you are familiar with Company's most-current policies and practices. Your continued use of the Websites after we make changes is deemed to be acceptance of those changes. If you do not agree with our policies and practices, you must not use the Websites.
If required by law, we will make reasonable efforts to contact you about material changes or updates to this notice: if you have provided us with an email address, you agree that we may email you a notice regarding such changes or updates; if you have not provided us with an email address, you agree to view this page periodically and when our site informs you that this Privacy Notice has been updated.
Last Revised: July 1, 2020
What This Notice Applies To
This notice applies to information we collect:
This Privacy Notice also applies to information collected by us offline, whether in writing or orally (if recorded) or through any other means, including on any other website operated by us or any third party, or any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Websites.
Children
These Websites are not intended to provide services or sell products to persons under the age of 13 without the consent and involvement of a parent or guardian. If you are under 13, you may use this website only with the involvement of a parent or guardian. By using the Websites, you represent and warrant that you are either at least 13 years old, or are using the services offered by these Websites with the supervision and involvement of a parent or guardian 13 years of age or older. The Company does not provide its services to children, nor do we collect any personal information from children under 13. “Children” as defined in the Children’s Online Privacy Protection Act of 1998, and for purposes of this Privacy Notice, means persons under the age of 13. If you are a child, please exit this site immediately. We will delete any personal information we have received or collected from a child under the age of 13 without parental consent. If you believe we might have information from or about a child under the age of 13, please contact us at compliance@collegeloans.me.
Information Collected
We collect several types of information from and about users of our Websites, including information:
We collect this information in several ways, either:
The information we collect on or through the Websites may include:
You may also provide information to be posted or displayed on public areas of the Websites, or transmitted to other users of the Websites and third parties, such as customer comments and reviews (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk.
While navigating through and interacting with our Websites, we may automatically collect certain information about your equipment, browsing actions, and patterns that are not tied to your user profile, including:
We may use automatic data collection technologies to gather information about your online activities on our Websites over time and across third-party websites or other online services for behavioral tracking. For example, we may use various widgets and other tracking technologies to understand how you use the Websites and what information you search for. You can also opt-out by sending an email to compliance@collegeloans.me.
Automatically collected information may include personal information or non-personal information that we associate or link to personal information that we collect in other ways, including from third parties. This helps us improve our Websites and deliver a better and more personalized service, including allowing us to:
The technologies we use to automatically collect data may include:
Third-Party Use of Cookies and Other Tracking Technologies
Some content or applications on the Websites, including advertisements, are served by third-parties, including advertisers, ad networks, ad servers, content providers, and application providers. These third parties may use cookies alone or together with web beacons or other tracking technologies to collect information about you when you use our Websites. 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 and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.
We do not control third parties’ tracking technologies or how they might use them. If you have questions about an advertisement or other targeted content, you should contact the responsible provider directly.
“Do Not Track”
You may have a feature in your browser that allows you to change your settings to “do not track.” We are required to disclose whether the Site honors the “do not track” setting in your browser. We have developed the Site to provide a consistent interface and operability to all users, and thus we do not honor your browser’s “do not track” function.
How We Use Your Information
We use information that we collect about you or that you provide to us, including any personal information:
If you choose to opt-in to receive marketing materials from us, we may 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 disable cookies used by our website or click the unsubscribe link at the bottom of any marketing emails you may receive from us. You can also opt-out by sending an email to compliance@collegeloans.me.
How Long Your Data is Stored
How long we keep information we collect about you depends on the type of information, as described in further detail below. After such time, we will either delete or anonymize your information or, if this is not possible (for example, because the information has been stored in backup archives), then we will securely store your information and isolate it from any further use until deletion is possible.
Account Information
We retain your account information until you delete your account. We also retain some of your information as necessary to comply with our legal obligations, to resolve disputes, to enforce our agreements, to support business operations and to continue to develop and improve our Websites and Services. Where we retain information for Service improvement and development, we take steps to eliminate information that directly identifies you, and we only use the information to uncover collective insights about the use of our Services, not to specifically analyze personal characteristics about you.
Information You Share on the Services
If your account is deactivated or disabled, some of your information and the content you have provided will remain in order to allow your team members or other users to make full use of the Services. For example, we continue to display comments and content you provided to our Websites.
Marketing Information
If you have elected to receive marketing emails from us, we retain information about your marketing preferences unless you specifically ask us to delete such information. We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created.
Terms Related to EU/EEA Users
Legal Bases for Processing (For EU/EEA Users)
If you are an individual in the European Union or European Economic Area (EEA), we collect and process information about you only where we have a legal basis for doing so under applicable EU laws, including the General Data Protection Regulation (GDPR). The legal basis depends on the services you use and how you use them. This means we collect and use your information only where:
All of our information, including the data we collect about you described in this notice, is stored in the United States of America.
Data Protection Officer
Our Data Protection Officer can be reached at dpo@collegeloans.me.
Your Rights as Data Subject
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:
If you wish to exercise any of the rights set out above, please contact us at dpo@collegeloans.me.
No Fee Usually Required
You will not have to paersonal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What We May Need From You
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time Limit to Respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Disclosure of Your Information
We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.
We may disclose personal information that we collect or you provide as described in this privacy notice:
We may also disclose your personal information:
Choices About How We Use and Disclose Information
We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:
Third-Party Links
The Website contains links to websites operated and maintained by third parties over which Company has absolutely no control. Any information you provide to third-party websites will be governed under the terms of the privacy notice or privacy policy of those respective third parties. Accordingly, we strongly encourage you to investigate and ask questions before disclosing any information to the operators of third-party websites, and to familiarize yourself with their privacy practices by reviewing their privacy notices and privacy policies.
Inclusion of third-party websites on or through our Websites in no way constitutes an express or implied endorsement of such websites' policies or notices.
If you have any questions regarding Company’s Privacy Policy or Privacy Notice and or related practices, please feel free to contact us at legal@collegeloans.me.
Methods Used to Protect Your Information
We use HTTPS to protect the confidentiality of your personal information including the use of SSL (Secure Sockets Layer) protocol and/or TLS (Transport Layer Security). We also use password encryption to protect all of the information stored in our database. In addition, our business practices are reviewed periodically for compliance with policies and procedures governing the security and confidentiality of its information. Our business practices limit employee access to confidential information and limit the use and disclosure of such information to authorized persons.
Our Websites use commercially reasonable technologies, processes and procedures to maintain the confidentiality, integrity, and availability of all personal data.
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 Websites, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Websites like message boards. The information you share in public areas may be viewed by any user of the Websites.
However, no data transmission over the Internet can be guaranteed to be 100% secure, and no data system can guarantee that it is free from error. Therefore, while we strive to protect your personal information, we cannot guarantee or warrant that it will be safe from theft, loss, damage, and/or corruption. Any transmission of personal information is at your own risk. By using our Websites, you hereby agree that Company and its officers, directors, employees, shareholders, insurers, attorneys, vendors, agents and representatives, shall not be liable for any theft, loss, damage and/or corruption to your information, including but not limited to your personally identifiable information. We are not responsible for circumvention of any privacy settings or security measures contained on the Websites, in this Privacy Notice, or on our Terms and Conditions.
Your Rights
You have the right to know what data is being collected from you, where it’s being processed, how it’s being used, how long it is stored for, and who we share the information with. If you have consented to our use of information about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. Where we are using your information because we or a third party have a legitimate interest in doing so, you have the right to object to that use. However, in some cases, this may mean no longer using the Websites or our services. You may also request that we transfer or erase your personal data.
How You Can Access or Correct Your Information
We do our best to respect your privacy rights and provide you access and control over your data. You can make any of the following requests regarding your data by sending an e-mail to compliance@collegeloans.me:
Because we use Amazon Web Services to back-up our information, we cannot delete your specific information from our backups. The Amazon Web Services creates images of our database every day and stores them for 7 days. After 7 days have passed, the oldest images are deleted. Furthermore, during critical stages of system changes, we sometimes create manual backups. We retain these backups for no more than 7 days.
We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change or delete information if we believe the change or deletion would violate any law or legal requirement or cause the information to be incorrect.
If you delete your User Contributions from the Websites, copies of your User Contributions may remain viewable in cached and archived pages or might have been copied or stored by other Websites users. Proper access and use of information provided on the Websites, including User Contributions, is governed by our Terms & Conditions.
Privacy Notice for California Residents
This section applies solely to all visitors, users, and others who reside in the State of California ("consumers" or "you"). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice.
Information We Collect
Our Website collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device ("personal information"). collegeloans.me has collected the following categories of personal information from its consumers within the last twelve (12) months:
Category |
Examples |
Collected |
A. Identifiers. |
A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers. |
Yes |
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). |
A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories. |
Yes |
C. Protected classification characteristics under California or federal law. |
Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
|
Yes |
D. Commercial information. |
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. |
Yes |
E. Biometric information. |
Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. |
No |
F. Internet or other similar network activity. |
Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement. |
Yes |
G. Geolocation data. |
Physical location or movements. |
Yes |
H. Sensory data. |
Audio, electronic, visual, thermal, olfactory, or similar information. |
No |
I. Professional or employment-related information. |
Current or past job history or performance evaluations. |
No |
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). |
Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. |
No |
K. Inferences drawn from other personal information. |
Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. |
No |
Personal information does not include:
We obtain the categories of personal information listed above from the following categories of sources:
Use of Personal Information
We may use, sell, or disclose the personal information we collect for one or more of the following business purposes:
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Sharing Your Personal Information
We may disclose your personal information to a third party for a business purpose, or sell your personal information, subject to your right to opt-out of those sales. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. The CCPA prohibits third parties who purchase the personal information we hold from reselling it unless you have received explicit notice and an opportunity to opt-out of further sales.
We share your personal information with the following categories of third parties:
Disclosures of Personal Information for a Business Purpose
In the preceding twelve (12) months, Company has has disclosed the following categories of personal information for a business purpose:
We disclose your personal information for a business purpose to the following categories of third parties:
Sales of Personal Information
In the preceding twelve (12) months, Company has sold the following categories of personal information:
We sell your personal information to the following categories of third parties:
Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
Once we receive and confirm your verifiable request, we will disclose to you:
Deletion Request Rights
You have the right to request that we delete from our records any of the personal information that we collect and retained, 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.
Why We May Deny Your Request
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by emailing your request to dpo@collegeloans.me.
What We May Need From You
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 additional days), we will inform you of the reason and extension period in writing.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
Fees
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Personal Information Sales Opt-Out and Opt-In Rights
If you are 16 years of age or older, you have the right to direct us to not sell your personal information at any time (the "right to opt-out"). We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the "right to opt-in") from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time.
Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales at any time by emailing your request to dpo@collegeloans.me.
You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.
Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
Other California Privacy Rights
California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our Website 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 email your request to dpo@collegeloans.me.
Contact Information
If you have any questions or comments about this notice, the ways in which we collect and use your information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us.
Email your request to dpo@collegeloans.me.
CollegeLoans, LLC.
151 Calle San Francisco Suite #200 PMB 5364
San Juan, PR 00901-1607
Att: Data Protection Officer
Changes to Privacy Notice
We reserve the right to amend this privacy notice at our discretion and at any time. If we make changes to this Privacy Notice, we will immediately post the updated notice on our website and update the notice’s effective date. Any such changes will be effective immediately upon being posted, unless otherwise stated in the change. Your continued use of our website following the posting of changes constitutes your acceptance of such changes.
Effective Date
This Privacy Notice is effective as of July 1, 2020.
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