Website Privacy Policy

Scope of this Privacy Policy

This Privacy Policy governs the information collected through edvise.org and all services we provide directly to you, including the services through your institutional Edvise site. It applies to personally identifiable information for any students and end users. This Privacy Policy does not relate to anonymized, aggregated, or de-identified data.

Whether you are accessing our public website or using one of our products via a software application, this Privacy Policy governs our use of personal information for all our products and services that we provide directly to you. When we collect personal information directly from you in connection with our interactions with you, we are considered a data controller.

Connection to your institution's privacy policies

If you are an employee, student, or other end user of our partner institution, and we are collecting your personal information in connection with the products and services we provide to our partner institutions, we are considered to be a data processor. In this case, our use of your personal information is governed by the privacy policy of the institution from which we have received, or on whose behalf we collected or use, your personal information ("your institution"). Our Privacy Policy does not supersede the terms of any agreements between us and your institution, nor does it affect the terms of any agreements between you and your institution, including any prior consent you have provided concerning the use and distribution of your personal information.

Information That We Collect

The type of personal information we collect about you depends upon your relationship with us. Unless otherwise identified, information in this Privacy Policy applies to all our activities.

Website visitors

Edvise maintains a website generally accessible by the public. Our website provides general information about our company and its products and services. Our website also may contain information concerning employment opportunities and provide the opportunity for individuals to submit applications for open roles.

We collect personal information in the following manner:

End user of an institution that uses our products

Your institution decides how your personal information is used. We provide nearly all of our products and services to end users of an institution as a data processor on behalf of our partner institutions (for example, colleges, universities, and school districts). This means that the main responsibility for data privacy compliance lies with your institution as a data controller. It also means that your institution's privacy policy governs the use of your personal information rather than ours. Your institution determines what information we collect through our products and services and how it is used, and we process your information according to your institution's explicit instructions.

The following section is primarily for informational purposes and describes how your information is generally collected when we provide products and services to you on behalf of a partner institution. How your personal information is used depends on your institution, so you should read your institution's privacy policy carefully.

We collect personal information in the following manner:

How We Use and Disclose the Information That We Collect

We may share the categories of personal information we obtain about you (as described above) with the categories of third parties listed in this section. Edvise collects, retains, processes, uses, and transfers your personal information for the following purposes and to the following third parties:

To provide our services

We use personal information that we collect in order to provide our services; verify the identity of users; communicate with users of our services; provide information about briefings, events, professional development sessions, and collaboration opportunities; manage relationships with users of our services; provide support and troubleshooting services; and improve our services. We process personal information for these purposes because we have a legitimate interest in doing so.

Service providers

We use service providers to help us provide our products and services to our partner institutions and you or to perform work on our behalf. Where this requires access to personal information, we are responsible for the data privacy practices of the service providers. Our service providers are not allowed to use personal information they access or receive from us for any other purposes than as needed to carry out their work for us. Examples of our service providers include data storage providers, analytics platform providers, and email or messaging services.

Analytics and marketing

We use personal information that we collect in order to analyze use of our services; enhance the services; develop new products or services; and to perform market, trend, and statistical research and analysis. We analyze usage information for marketing purposes and for trends about our visitors' demographics and use of our websites and services. This analysis is necessary to further our legitimate interest in understanding our users and how they interact with us and our website, improving our website, and communicating with you.

Record keeping

We use personal information that we collect for our internal record keeping purposes, and for accounting, audit, and other internal functions.

On behalf of your institution

For end users of institutions that use our products, we use your information on behalf of and under the instruction of your institution, which is the data controller. We share the information that we collect in accordance with our agreement with your institution. Your institution determines how your information is used.

Product enhancements and research

To the extent permitted by applicable law or by our agreement with your institution, we may also use:

• Your personal information to evaluate and improve our products and services to develop new products and services.
• To tailor your experience on our websites.
• De-identified information for research or business purposes, like providing similarly situated institutions a benchmarking data report on completion rates or class size.

Partner institution engagement and marketing

Edvise uses your information for partner institution engagement and marketing purposes in limited circumstances, including:

• To manage the partner institution relationship, including for invoicing, notification of product updates and maintenance, and similar purposes.
• To promote Edvise's products and services.

We do not disclose personal information about students that we collect through the provision of our educational products and services to third parties for behavioral targeting of advertisements to students.

Our marketing emails will include a link so that you can opt out of receiving marketing communications from us. You can do this by clicking on the "Unsubscribe" link in the email footer.

Other types of uses and disclosures

We will also use and share your information to the extent required or appropriate in the following circumstances:

• To industry associations and other businesses with which Edvise co-hosts events, if you choose to participate.
• To comply with legal or regulatory requirements and to respond to lawful requests, court orders, and legal processes.
• To protect and defend the rights, property, or safety of us, our partner institutions, or third parties, including enforcing contracts or policies or in connection with investigating and preventing fraud.
• To process transactions when you use our services to make a deposit to one of our partner institutions, we will share your payment and transaction data with third party payment processors.
• To carry out operational tasks for legitimate business purposes.
• In the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution, or liquidation).

Specific Regional and Country Information

European Union

Edvise is not established in the European Union ("EU") or the United Kingdom ("UK"); however, in certain limited circumstances, we may be subject to the General Data Protection Regulation or the Data Protection Act of 2018 (collectively, "GDPR").

How we transfer the personal information that we collect

We may transfer the personal information that we collect about you to recipients in countries other than the country in which the personal data originally was collected, as described above. Those countries may not have the same data protection laws as the country in which you initially provided the personal information. When we transfer your personal data to recipients in other countries (such as the U.S.), we will protect that personal data as described in this notice.

If you are located in the European Economic Area ("EEA") or the United Kingdom ("UK"), we will comply with applicable legal requirements providing adequate protection for the transfer of personal information to recipients in countries outside of the EEA and the UK. In all such cases, we will only transfer your personal information if:

• The country to which the personal data will be transferred has been granted a European Commission adequacy decision or has been recognized as adequate under UK law.
• We have put in place appropriate safeguards in respect of the transfer, for example the EU or UK Standard Contractual Clauses.
• In certain limited circumstances, one or more of the derogations for data transfers provided by applicable law applies.

You may request a copy of the safeguards that we have put in place in respect of transfers of personal data by contacting us as described in the Contact Us section below.

California

California Civil Code Section 1798.83 permits users of our Site that are California residents to request certain information regarding our disclosure of Personally Identifiable Information to third parties for their direct marketing purposes. We do not provide your Personally Identifiable Information to any third parties for direct marketing purposes as defined in California Civil Code Section 1798.83. Please contact us at support@edvise.org for any questions regarding your personal information.

AB 1584 is a California law that defines student and educational agencies rights with regard to pupil records. Edvise maintains compliance with AB 1584 as described in this Privacy Policy and as described in, as applicable, a master services agreement with California institutions.

California Consumer Privacy Act (CCPA)

As set forth above, we collect the following categories of information: identifiers (such as your name, student identifier, and email address), other personal information categories listed in the California Customer Records statute (Cal. Civ. Code 1798.80(e)) (such as your name and contact information), internet or other similar network activity, geolocation data, and inferences drawn from the collected personal information. This information is collected directly from you when you provide it to us (for example when you submit a form requesting more information, or when you enter into a contract with us) or automatically as you navigate through the Site. We use this information for one or more legitimate business purposes, including to provide our services, improve our services, and offer information about our services to you.

If you are a resident of California, you have other rights under the CCPA. Any personal data that we collect is based upon your consent as detailed in this Privacy Statement. You have many choices concerning the collection, use, and sharing of your data, including the following rights:

• Right of Access: You can access your collected personal information by contacting us at support@edvise.org.
• Right to Correct, Update, or Delete: You can correct, update, or request deletion of your personal information by contacting us at support@edvise.org. We cannot make changes to or delete your information in some situations where it is necessary for us to maintain your information, for example if we need the information to comply with applicable law.
• Right to Request Disclosure of Information Collected: Please contact us at support@edvise.org to request further information about the categories of personal information we have collected about you, where we collected your personal information, and for what purpose we use your personal information.
• Right to Disclosure of Information Sold and Right to Opt Out: You have the right to know what information of yours we have sold, and you have the right to opt out of any sale of your information. We do not sell any of your information. If you have any questions about these rights, please contact us at support@edvise.org.
• Right to Non-Discrimination: We do not and will not discriminate against you if you exercise your rights under the CCPA.

When you contact us regarding any of your rights under the CCPA, we will verify your identity before we provide any information. If you have any questions or comments about your rights under the CCPA, please contact us at support@edvise.org.