Educational Computer Systems, Inc. ("ECSI," "us", "we" or "our") respects your rights and preferences regarding data privacy.
In this Privacy Notice ("Notice"), we describe how we collect, use, share and dispose of personal information that we collect from users of our websites, forums and blogs ("Sites"), our mobile applications ("Apps"), and our other products and services including student loan servicing, tuition and fees recovery, financial aid refunds, tax document generation, payment processing, tuition payment plans, and call center support (collectively, the "Services").
This Notice applies to the Services provided by ECSI on its own behalf or in combination with one of its parents, affiliates, or subsidiaries
In this Notice, we provide information about:
- PERSONAL INFORMATION WE COLLECT AND HOW WE USE IT
- HOW WE SHARE PERSONAL INFORMATION
- TRANSFERRING PERSONAL INFORMATION GLOBALLY
- HOW WE PROTECT AND DISPOSE OF PERSONAL INFORMATION
- COOKIES AND OTHER TRACKING TECHNOLOGIES
- YOUR LEGAL RIGHTS
- OTHER INFORMATION
- CONTACT US
Please be aware that not all of the information in this Notice will be directly applicable to our handling of your personal information. This Notice provides an overview of the possible circumstances in which we interact with your personal information. If you have any questions about our processing of your personal information, please contact us at firstname.lastname@example.org.
PERSONAL INFORMATION WE COLLECT AND HOW WE USE IT
We will only collect, use, and share your personal information where we are satisfied that we have an appropriate legal basis to do so. Subject to your consent if required by law, we may collect the following types of personal information about you as relevant to the Services with which you are engaging:
- Identifiers such as your name, social security number, or account name
- Contact information including telephone number, email address, or postal address
- Username and password
- Financial account information
- Education Information including your status with the college or university with which you are affiliated (i.e. currently enrolled, not enrolled)
- Your user activity including access and payment history
- Information about the services we provide to you
- Information collected through your internet-based activity (see "Cookies" for additional information)
- Information you provide in any communication with us including correspondence transcripts and call recordings
How we use your personal information. We use your personal information to provide the Services. In providing the Services, we may use your personal information to
- Create, maintain or provide service for your account
- Process or fulfill requests from you
- Respond to customer service requests from you
- Verify your information
- Process payments
- Undertake activities to maintain the quality, safety or integrity of the Service
- Maintain data security including detecting and responding to security incidents and protecting you, and us, from fraud
- Monitor our Sites including gathering usage data and other analytic information that enables us to maintain and improve the Services
- Other uses that are required for us to meet our legal, contractual or regulatory requirements
Sources of personal information. We collect information from various sources that we use to provide our Services to you, to analyze and improve our Services, and to communicate with you. The personal information that we collect and the purpose for our collecting such information is as follows:
- Information that you provide to us: We collect personal information that you provide to us when you set up an account with us, use our Services, or communicate with us. For example, if you register for an online account with us, then we may request your name, contact information and payment information.
- Information collected from third parties: We may collect information about you from third parties in the course of providing our Services to you. For example, we may collect personal information like your name, contact information and enrollment status from your college or university in order to offer the Services to you. We may also collect personal information related to the Services from consumer reporting agencies.
- Information collected through technology: When you visit our Sites or Apps (or when you use any of our Services) we may collect certain information about your location, usage, computer or device through technology such as cookies (see below for more information on cookies).
The business purpose for our processing your personal information. Our primary business purpose for processing your personal information is to perform student loan servicing consistent with the contract terms between us and our customer. We may also use your personal information to enable the following additional business purposes: (1) detecting and managing security incidents or fraudulent activity, (2) providing customer service, fulfilling requests, and other functions directly related to the Services, (3) maintaining our software including debugging and repairing errors, and (4) maintaining the quality of the Services and developing enhancements and improvements to meet our customer needs.
Data anonymization and aggregation. Subject to your consent if required by law, we may anonymize or aggregate your personal information in such a way as to ensure that you are not identified or identifiable from it, in order to use the anonymized or aggregated data. For example, we may use anonymized or aggregated data for statistical analysis including to analyze trends, for product development, and for risk assessments and cost analysis. We may share anonymized or aggregated data with our parents, subsidiaries, affiliates or with other third parties.
This Notice does not restrict ECSI's use or sharing of any non-personal, summarized, derived, anonymized or aggregated information.
HOW WE SHARE PERSONAL INFORMATION
We disclose personal information as necessary to provide the Services which include the servicing of student loans as permitted by the Privacy Act of 1974. For additional information about the processing of Personal Information pursuant to the Privacy Act of 1974, please see below.
We share personal information in the manner and for the purposes described below:
- With ECSI affiliates where such disclosure is necessary to provide you with our Services or to manage our business.
- With third-party service providers. For example, we share personal information with IT service providers who help manage our back office systems or administer our Sites and Apps. These third-party service providers have agreed to confidentiality restrictions and have agreed to use any personal information we share with them, or which they collect on our behalf, solely for the purpose of providing the contracted service to us.
- With our customer with whom you are also engaging when you use the Services. For example, ECSI may share the personal information you provide with the school consistent with our obligations as their service provider.
- With banks and payment providers to authorize and complete card payments.
- With the National Student Loan Database consistent with our obligations to our customers.
- With credit bureaus consistent with our obligations to our customers.
ECSI does not sell personal information
In addition, subject to applicable legal requirements, we may share personal information in connection with or during negotiation of any merger, financing, acquisition, bankruptcy, dissolution, transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business assets to another company.
TRANSFERRING PERSONAL INFORMATION GLOBALLY
We operate on a global basis. This means that your personal information may be transferred to and stored in the United States or in another country outside of the country in which you reside, which may be subject to different standards of data protection than your country of residence.
We will take appropriate steps to ensure that transfers of personal information are in accordance with applicable law.
HOW WE PROTECT AND DISPOSE OF PERSONAL INFORMATION
We take seriously our responsibility to protect the security and privacy of your personal information. We maintain administrative, technical and physical safeguards designed to protect the personal information you provide against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.
Any suspected attempt to breach our policies and procedures, or to engage in any type of unauthorized action involving our information systems, is regarded as potential criminal activity. Suspected computer mischief may be reported to the appropriate authorities.
Please remember that communications over the internet such as emails are not secure. We seek to keep secure all confidential information and personal information submitted to us in accordance with our obligations under applicable laws and regulations. However, like all website operators, we cannot guarantee the security of any data transmitted through the internet.
When we no longer need your personal information to provide the Services, it will be securely deleted or de-identified in a manner that ensures you cannot be re-identified.
COOKIES AND OTHER TRACKING TECHNOLOGIES
A "cookie" is a text file that is stored to your browser when you visit a website.
Unique device identifiers like IP address or UDID recognize a visitor's computer or other device used to access the internet. Unique device identifiers are used alone and in conjunction with cookies and other tracking technologies for the purpose of "remembering" computers or other devices used to access the Sites and Apps.
We may also use other technologies like pixels or tags that allow us to measure responses to our email communications.
Cookies can be classified by duration and by source:
- Duration. The Sites use both "session" and "persistent" cookies. Session cookies are temporary - they terminate when you close your browser or otherwise end your "active" browsing session. Persistent cookies remember you on subsequent visits. Persistent cookies are not deleted when you close your browser, and they will remain on your computer or other device unless you choose to delete them (see below for "How to Delete or Block Cookies").
- Source. Cookies can be "first-party" or "third-party" cookies, which means that they are either issued by or on behalf of ECSI or by a third-party operator of another website.
The cookies that we may use on the Sites fall into the following categories:
- Strictly Necessary Cookies. These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions taken by you such as logging in or filling in forms. You can set your browser to block or alert you about these cookies, but blocking them may impede the functionality of the Sites.
- Performance Cookies. These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site. All information these cookies collect is aggregated. If you do not allow these cookies we will not know when you have visited our site, and will not be able to monitor its performance.
- Functionality Cookies. These cookies enable the Sites to provide enhanced functionality and personalization. They may be set by us or by third-party providers whose services we have added to our pages. If you do not allow these cookies then some of these services may not function properly.
How to Delete or Block Cookies
On some Sites, when technically feasible, we will enable tools to help you make choices about cookies. You may also delete or block cookies at any time by changing your browser settings. You can click "Help" in the toolbar of your browser for instruction or review the cookie management guide produced by the Interactive Advertising Bureau available at www.allaboutcookies.org. If you delete or block cookies, some features of the Sites may not function properly.
ECSI may provide links on our Sites and Apps to other websites that are not under our control. We do not endorse or make any warranty of any type regarding the content contained on such websites or products and services offered on those websites.
We encourage our users to be aware when they leave our Sites and to read the privacy statements of each and every website that collects personal information. This Notice applies solely to personal information collected by us. You should read any other applicable privacy and cookies notices carefully before accessing and using other websites.
The Services are not intended for use by children. We do not solicit or knowingly accept any personal information from persons under the age of 16. Please do not use the Services if you are under the age of 16. ECSI does not knowingly collect, use, or disclose the personal information of minors under 16 years of age.
YOUR LEGAL RIGHTS
Subject to certain exemptions, and in some cases dependent upon the processing activity we are undertaking, some users, including residents of the state of California, may have certain rights in relation to their personal information. These rights may include:
|CA Resident Rights||What does this mean?|
|Right to know about personal information collected, disclosed, and sold||You have the right to be provided with clear and easy-to-understand information about how we use your personal information. This is why we are providing you this Notice and we may provide other forms of notice, as appropriate or required by law, in the Sites and Services.|
You also have the right to access and receive a copy of the personal information we hold about you.
|Right to opt-out of the sale of personal information||You may request that we do not sell your personal information to third parties.|
|Right to request deletion||In some circumstances, you have the right to have your personal information erased or deleted.|
|Right to equal service and prices ("non-discrimination")||Your choice to exercise your privacy rights will not be used as a basis to discriminate against you in services offered or pricing.|
Privacy Act Notice. The Privacy Act of 1974 requires that the following notice be provided to you: The authorities for collecting the requested information from and about you are §421 et seq., §451 et seq., or §461 of the Higher Education Act of 1965, as amended (20 U.S.C. 1071 et seq., 20 U.S.C. 1087a et seq., or 20 U.S.C. 1087aa et seq.) and the authorities for collecting and using your Social Security Number (SSN) are §§428B(f) and 484(a)(4) of the HEA (20 U.S.C. 1078-2(f) and 1091(a)(4)) and 31 U.S.C. 7701(b). Participating in the Federal Perkins Loan (Perkins Loan) or Health Profession Loan Program and giving us your SSN are voluntary, but you must provide the requested information, including your SSN, to participate. The principal purposes for collecting the information, including your SSN, are to verify your identity, to determine your eligibility to receive a loan or a benefit on a loan (such as a deferment, forbearance, discharge, or forgiveness) under the Perkins Loan and Health Profession Loan Program, to permit the servicing of your loans, and, if it becomes necessary, to locate you and to collect and report on your loans if your loans become delinquent or default. We also use your SSN as an account identifier and to permit you to access your account information electronically. The information in your file may be disclosed, on a case-by-case basis or under a computer matching program, to third parties as authorized under routine uses in the appropriate systems of records notices. The routine uses of this information include, but are not limited to, its disclosure to federal, state, or local agencies, to private parties such as relatives, present and former employers, business and personal associates, to consumer reporting agencies, to financial and educational institutions, and to guaranty agencies in order to verify your identity, to determine your eligibility to receive a loan or a benefit on a loan, to permit the servicing or collection of your loans, to enforce the terms of the loans, to investigate possible fraud and to verify compliance with federal student financial aid program regulations, or to locate you if you become delinquent in your loan payments or if you default. To provide default rate calculations, disclosures may be made to guaranty agencies, to financial and educational institutions, or to state agencies. To provide financial aid history information, disclosures may be made to educational institutions. To assist program administrators with tracking refunds and cancellations, disclosures may be made to guaranty agencies, to financial and educational institutions, or to federal or state agencies. To provide a standardized method for educational institutions to efficiently submit student enrollment statuses, disclosures may be made to guaranty agencies or to financial and educational institutions. To counsel you in repayment efforts, disclosures may be made to guaranty agencies, to financial and educational institutions, or to federal, state, or local agencies. In the event of litigation, we may send records to the Department of Justice, a court, adjudicative body, counsel, party, or witness if the disclosure is relevant and necessary to the litigation. If this information, either alone or with other information, indicates a potential violation of law, we may send it to the appropriate authority for action. We may send information to members of Congress if you ask them to help you with federal student aid questions. In circumstances involving employment complaints, grievances, or disciplinary actions, we may disclose relevant records to adjudicate or investigate the issues. If provided for by a collective bargaining agreement, we may disclose records to a labor organization recognized under 5 U.S.C. Chapter 71. Disclosures may be made to our contractors for the purpose of performing any programmatic function that requires disclosure of records. Before making any such disclosure, we will require the contractor to maintain Privacy Act safeguards. Disclosures may also be made to qualified researchers under Privacy Act safeguards.
Changes and Updates. We reserve the right, in our sole discretion, to modify, update, add to, discontinue, remove or otherwise change any portion of this Notice, in whole or in part, at any time. When we amend this Notice, we will revise the "last updated" date located at the top of the document. We will also take reasonable steps to ensure you are made aware of any material updates including providing you direct communication about such changes or providing a notification through the Services, as appropriate. If you provide personal information to us or access or use the Services after this Notice has been changed, you will be deemed to have unconditionally consented and agreed to such changes. The most current version of this Notice will be available on the Sites and Apps and will supersede all previous versions of this Notice.
Choice of Law. This Notice, including all revisions and amendments thereto, is governed by the laws of the United States, State of Georgia, without regard to its conflict or choice of law principles which would require application of the laws of another jurisdiction.
Arbitration. By using the Services in any way, you unconditionally consent and agree that: (1) any claim, dispute, or controversy (whether in contract, tort, or otherwise) you may have against ECSI and/or its parent, subsidiaries, affiliates and each of their respective members, officers, directors and employees (all such individuals and entities collectively referred to herein as the "ECSI Entities") arising out of, relating to, or connected in any way with the Services or the determination of the scope or applicability of this agreement to arbitrate, will be resolved exclusively by final and binding arbitration administered by JAMS and conducted before a sole arbitrator in accordance with the rules of JAMS; (2) this arbitration agreement is made pursuant to a transaction involving interstate commerce, and shall be governed by the Federal Arbitration Act ("FAA"), 9 U.S.C. §§ 1-16; (3) the arbitration shall be held in Atlanta, Georgia; (4) the arbitrator's decision shall be controlled by the terms and conditions of this Notice and any of the other agreements referenced herein that the applicable user may have entered into in connection with the Services; (5) the arbitrator shall apply Georgia law consistent with the FAA and applicable statutes of limitations, and shall honor claims of privilege recognized at law; (6) there shall be no authority for any claims to be arbitrated on a class or representative basis, arbitration can decide only your and/or the applicable ECSI Entity's individual claims; the arbitrator may not consolidate or join the claims of other persons or parties who may be similarly situated; (7) the arbitrator shall not have the power to award punitive damages against you or any ECSI Entity; (8) in the event that the administrative fees and deposits that must be paid to initiate arbitration against any Global Entity exceed $125 USD, and you are unable (or not required under the rules of JAMS) to pay any fees and deposits that exceed this amount, ECSI agrees to pay them and/or forward them on your behalf, subject to ultimate allocation by the arbitrator. In addition, if you are able to demonstrate that the costs of arbitration will be prohibitive as compared to the costs of litigation, ECSI will pay as much of your filing and hearing fees in connection with the arbitration as the arbitrator deems necessary to prevent the arbitration from being cost-prohibitive; and (9) with the exception of subpart (6) above, if any part of this arbitration provision is deemed to be invalid, unenforceable or illegal, or otherwise conflicts with the rules of JAMS, then the balance of this arbitration provision shall remain in effect and shall be construed in accordance with its terms as if the invalid, unenforceable, illegal or conflicting provision were not contained herein. If, however, subpart (6) is found to be invalid, unenforceable or illegal, then the entirety of this Arbitration Provision shall be null and void, and neither you nor ECSI shall be entitled to arbitrate their dispute. For more information on JAMS and/or the rules of JAMS, visit their website at www.jamsadr.com.
If you have questions about this Notice, or if you want to exercise your rights as described in this Notice, you may contact ECSI as follows:
100 Global View Drive, Suite 800
Warrendale, PA 15086
If you designate an authorized agent to make a rights request on your behalf, we request that you notify us of such designation by contacting us using the methods listed above.