Universal College Application® Privacy Statement

Revised and Effective as of July 1, 2019.

Our privacy policy has been updated to provide additional detail concerning; (i) how we handle your data; (ii) your rights to your data; and (iii) how ApplicationsOnline addresses any questions or concerns about your data.

This Privacy Statement pertains to the Universal College Application Service, an online service provided by ApplicationsOnline, LLC ("ApplicationsOnline," "us," "we," "our") through the Universal College Application (“UCA”) website located at www.universalcollegeapp.com (the "UCA Site") and all associated sub-domains (collectively referred to as, the "UCA Service"), and explains ApplicationsOnline's practices regarding: (a) our collection of personally identifiable information through the UCA Service; (b) our use and disclosure of the information collected; and (c) the steps we take to safeguard personally identifiable information. By using the UCA Service, you accept and consent to our practices regarding the collection, use and disclosure of personally identifiable information, as described below.

1. COLLECTION OF PERSONALLY IDENTIFIABLE INFORMATION

The UCA Service uses numerous and various online, ad hoc applications, surveys, questionnaires, and other interactive webpages (collectively referred to as "UCA Applications") to collect certain types of information from users of the UCA Service. Users of the UCA Service (“Users”) generally fall into one of three categories:

User Type	Description
Applicants	Those who use the UCA Service to provide information in response to questions on UCA Applications; e.g., a high school senior is an Applicant when completing a college admission Application through the UCA Service.
Recipients	Our institutional customers for whom we set up one or more UCA Applications to facilitate the collection of information from Applicants; e.g., a college for which we have set up an admission Application is a Recipient.
Contributors	Third parties who have received a request from an Applicant to submit supplemental information about an Applicant to a Recipient; e.g., a high school guidance counselor is a Contributor when an Applicant requests that the counselor submit high school transcripts to a Recipient.

All personally identifiable information (“PII”) (i.e., information that is specific to you and identifies you individually) collected by us is voluntarily provided by the respective Users or automatically provided by the User’s browser such as a User’s IP Address. Voluntarily provided PII includes data such as an individual’s email address, nickname, social security number, contact information (i.e., phone), parent information, current grade in school, and test scores. PII may also include sensitive information such as race, ethnicity, citizenship, gender, and sex. We collect PII from all Users of the UCA Service during the process of registering for a new account, including your first name, last name, date of birth, email address, and password (collectively referred to as, "Registration Information").

After registration, an Applicant may complete the UCA Application. During this process, Applicants will be asked to fill out the generic application information that is required on every application such as their name, address, high school, GPA, email address, social security number, race, ethnicity, citizenship, contact information, parent information, test scores, honors, awards, extra-curriculars, etc. (“Generic Information”). Applicants may also be required to enter additional information ("Profile Information") by completing a "profile" questionnaire if one or more applicable Recipients have requested such additional information be included in their UCA Applications. The Profile Information collected, if any, is determined by each Recipient and, therefore will vary. The Generic and Profile Information is collected for the purpose of submitting the completed UCA Applications to the Users’ chosen Recipients. The Generic and Profile Information may include sensitive information such as race, ethnicity, citizenship, gender, sex, and religion.

Recipients may also require Applicants to include PII sent from a Contributor, such as a recommendation. We collect the PII from Contributors in order to submit the information to the Recipient. In such cases, the Applicant sends an electronic request to a Contributor to complete a recommendation on the Applicant’s behalf. If accepted, the Contributor signs into the recommender account, completes the online recommendation form, and submits the form. The recommendation goes directly to the Recipient specified by the Applicant.

From time-to-time we may also provide Applicants the opportunity to participate in our own Applicant surveys, on which we may request certain PII. Participation in these surveys is voluntary and Applicants may choose whether or not to provide the requested information. These surveys are conducted to assess User satisfaction with the service and find areas for improvement.

For the purposes of providing Users with any needed assistance, we may also collect PII when Users contact us via email for technical support or other assistance.

Some Recipients may allow Applicants to pay fees electronically using a third party, online payment processor. The information required for such electronic payments is collected directly by the online payment processor. ApplicationsOnline does not collect any PII or electronic payment information from Applicants during the payment process, nor do we process such payment. We cannot and do not control the use and/or disclosure of your PII by any online payment processor and we are not responsible for any use or misuse by those processors. You are encouraged to review the privacy policies and practices of the payment processors prior to submitting your electronic payment information. We do receive information from the payment processor in response to each attempted payment transaction, which may include PII provided by you in connection with your payment such as your name, billing address, email address, last four digits of your payment card number, and other information related to your transaction and its success or failure. However, ApplicationsOnline does not receive, collect or store your full payment card number, your PIN or your security code.

In addition to the PII collected (as described above), we automatically collect additional information from all Users of the UCA Service and the UCA Site. Some such information, such as your IP address, may be considered PII. This information is automatically provided by the User’s browser and may include information such as your IP address, Internet service provider, the type of browser you are using, your operating system, the webpages you visited on the UCA Site, and the date and time of your visit.

2. USE OF PERSONALLY IDENTIFIABLE INFORMATION

We store the PII we collect from or related to all Users in our electronic databases and/or associated files and use that information solely in connection with providing, maintaining and improving the UCA Service. You understand and agree that, regardless of your country of residence, your PII will be transferred to the United States for storage, processing and use by ApplicationsOnline and the Recipients you select to receive such information (as described below).

The information that we collect automatically from Users’ browsers is stored primarily in our log files. With the exception of an IP address, which may be stored with registration information in our database, the information is not used to identify individual users of the UCA Service. We use this information to analyze website usage, performance, loads and trends, and to administer, maintain and improve the UCA Service. We may also aggregate data for the purpose of statistical reporting. Such data will not identify any individual User.

3. DISCLOSURE OF PERSONALLY IDENTIFIABLE INFORMATION

We disclose PII only to the third parties identified below and only under the specific circumstances described. We do not intentionally sell, lease, license, share or otherwise disclose PII to any other third parties or under any other circumstances.

a. To Recipients

The UCA Site is used by Applicants to submit completed UCA Applications and Contributor information to the identified Recipients selected by the Applicants to receive such information. For each UCA Application, the Recipient(s) for whom the information is being collected is identified.

We do not make an Applicant's PII available to the Recipient until authorized to do so by the Applicant. Applicants give us express consent to make their PII available to specific Recipients (in the form of completed UCA Applications), including Profile Information, by specifically selecting the desired Recipients and clicking the "submit" button. This includes consent to send any sensitive information that the Applicant has entered into the UCA Application. We do not make an Applicant's PII available to any Recipient prior to the Applicant's authorization to "submit" such information, except when the Applicant has elected to share Profile Information with selected Recipients prior to submitting a completed UCA Application by affirmatively "opting in" for such sharing. When completed UCA Applications are "submitted" by the Applicant, the selected Recipient(s) may export and download a copy of the Applicant's completed UCA Application, including all PII provided by the Applicant and related information provided by Contributors, if applicable.

We do not share Registration Information with Recipients. However, PII that is identical or similar to Registration Information may be collected from Applicants via a completed UCA Application and such information will be shared with the applicable Recipient when submitted by an Applicant, as described above.

Note that beyond the obligations specified in our contracts with the Recipients, we cannot and do not control the use and/or disclosure of your PII by the Recipients to whom you voluntarily submit UCA Applications and except to the extend otherwise provided by applicable law, we are not responsible for any use or misuse by those Recipients or any third party. We recommend that you review the privacy policies and practices of the Recipients to whom you wish to submit an UCA Application, and/or Contributor information, prior to submission.

b. To Our Service Providers

We also may disclose PII to third-party service providers for the purpose of performing certain tasks on our behalf. These service providers assist with our data management by providing cloud storage, cloud application, and file sharing services.

c. To Successors In Interest

We may disclose PII in the event of a merger, acquisition, or sale of our business or assets, or in the event of an insolvency, bankruptcy, or receivership, if such information is transferred to one or more third parties as part of our business or assets.

d. To Others Under Certain Circumstances

We may also disclose PII and/or general information to third parties when we reasonably believe that disclosing such information is necessary to: (a) identify or contact a User of the UCA Service to satisfy a legal obligation or obligation related to our services to the Applicants or Recipients; (b) prevent abuse, fraud, or unlawful use of the UCA Service, the UCA Site or any UCA Applications; (c) protect our rights, safety, or property and/or the rights, safety, or property of others; (d) initiate or defend a legal action involving us or otherwise relating to the UCA Service; or (e) respond to or comply with a subpoena, other legal or administrative order, process or demand, or any applicable law, rule or regulation.

e. To Recipients’ Agents

In connection with the UCA Service, some Recipients utilize independent contractors, technology vendors and/or other service providers (collectively, "Agents") to assist the Recipient in managing, storing, reviewing, accessing, assembling or processing "submitted" UCA Applications. We may transfer to these Agents, or permit these Agents to export or download, a copy of the Applicant’s completed UCA Application, including all PII provided by the Applicant and related information provided by Contributors, if applicable. All Agents must be: (i) identified to us by the Recipient in writing, (ii) required by the Recipient to use the information for the sole purpose of assisting the Recipient in utilizing the UCA Service; and (iii) required by the Recipient to comply with all of the terms and conditions governing the UCA Service.

4. RETENTION

We may retain a copy of an Applicant’s PII, completed and partial UCA Application, and/or any related Contributor information in our database for such Applicant’s future use, for the use of Recipients to whom the information has been "submitted," and for our records and internal use. All such PII remains subject to this Privacy Statement, as revised from time to time, and is protected according to our security policies and practices referenced below.

We do not promise to retain your PII or general information for any minimum period of time and we may delete all or some of your information at any time, with or without notice.

We may use your email address and/or other contact information (a) to communicate with you from time to time about your account, your UCA Applications, and/or the Recipients to which you have submitted UCA Applications, (b) to provide you with administrative, technical or other information about the UCA Service or (c) to respond to your inquiries and requests for customer service. These communications are not promotional in nature.

5. ACCESS TO YOUR PERSONALLY IDENTIFIABLE INFORMATION

You may change your user name and password at any time by accessing your account; however, you are not able to independently change your name or your date of birth after your account has been created. You may access, review and update your Profile Information and UCA Applications at any time through the UCA Service. You are able to edit your name and date of birth that you use on UCA Application at any time, however if you wish to update your name and date of birth associated with your account, send your request to applywithus@universalcollegeapp.com.

Once information associated with any UCA Application is submitted to a Recipient, the information cannot be changed for that submission. To correct or change an UCA Application already submitted, you must contact the Recipient directly.

To avoid fraud, abuse and mistakes, we do not allow you to deactivate your account or close your account online. To deactivate and/or close your UCA account, you must send a signed, written request to our office address or our email address set forth below with your name, user name, the reason for your request and a telephone number by which we can reach you to verify your request. We will attempt to respond to each such request within a reasonable time after receipt. As noted above, we may retain archived copies of your PII and other information, subject to this Privacy Statement.

6. SAFEGUARDS

The steps we take to safeguard your PII are described in our Security Statement, available at www.applywithus.com/legal/security_statement,

7. OUR USE OF COOKIES

A cookie is in general a small amount of data that is sent to your browser from our server and stored in a file on your computer's hard drive. We use session cookies (which expire when you close your browser) for managing your online session while you are using the UCA Service, to save you from having to repeatedly enter your user name and password, and to secure your communications with the UCA Service, when necessary. We do not store PII in cookies. By modifying your browser preferences, you have the choice to accept all cookies, to be notified when a cookie is set, or to reject all cookies. If you choose to reject cookies from the UCA Service, you may not be able to use those parts of the UCA Service that require cookies. We do not presently employ the use of persistent cookies (which continue to exist even after you close your browser, but which typically expire after a prescribed time period) on a regular basis but we may use them in the future to test or introduce new features and functionality. If so, we will update this Privacy Statement accordingly.

8. CHILDREN UNDER THE AGE OF 16

ApplicationsOnline does not knowingly solicit or collect PII from children under the age of 16. If you believe such information has been collected, contact us immediately by any of the means described below.

9. LINKS TO OTHER WEBSITES

The UCA Service may contain links to third party websites that are not owned or controlled by or affiliated with ApplicationsOnline. We are not responsible for the privacy practices of such other third parties or their websites. We encourage you to be aware when you leave the UCA Service and UCA Site and to read the privacy policies pertaining to each website before you disclose any PII. This Privacy Statement applies only to information collected by ApplicationsOnline through the UCA Service.

10. NOTICE OF MODIFICATIONS TO THIS PRIVACY STATEMENT

ApplicationsOnline reserves the right to modify this Privacy Statement from time-to-time, as we deem necessary. ApplicationsOnline will notify you of any modifications to this Privacy Statement by electronically posting the revised Privacy Statement and date of modification on the UCA Site. We encourage you to review this Privacy Statement frequently in order to be aware of any changes in the way we collect, use and/or disclose PII. In addition, ApplicationsOnline may, but is not obligated to, notify you via e-mail and/or by other means of such modifications. The revised Privacy Statement will be effective as of the effective date displayed at the top and bottom of this document. Your continued use of the UCA Service after the effective date of the revised Privacy Statement will constitute your acceptance of and consent to the revised Privacy Statement.

11. RELATION TO TERMS OF SERVICE

This Privacy Statement forms a part of and is incorporated into the UCA Terms of Service, which govern your use of the UCA Service and are available at https://www.universalcollegeapp.com/legal/terms-of-service.

12. CONTACT US

If you have any questions, comments or concerns about the collection and subsequent use of PII by ApplicationsOnline, please contact us by any of the following means:
Email: applywithus@universalcollegeapp.com
Mail: ApplicationsOnline, LLC, 500 W. University Parkway, Suite 1M, Baltimore, MD 21210

13. EFFECTIVE DATE

This Privacy Statement was last revised on and is effective as of: July 1, 2019.