Effective date: March 3, 2022
− Categories of Personal Data We Collect
− Categories of Sources of Personal Data
− Our Commercial or Business Purposes for Collecting Personal Data
How We Share Your Personal Data
Tracking Tools and Opt-Out
Data Security and Retention
Personal Data of Children
Other State Law Privacy Rights
European Union and United Kingdom Data Subject Rights
Categories of Personal Data We Collect
This chart details the categories of Personal Data that we collect and have collected over the past 12 months:
Categories of Personal Data We collect
Categories of Sources of Personal Data
We collect Personal Data about you from the following categories of sources:
o When you provide such information directly to us.
▪ When you create an account or use our interactive tools and Services.
▪ When you voluntarily provide information in free-form text boxes through the Services or through responses to surveys or questionnaires.
▪ When you send us an email or otherwise contact us.
o When you use the Services and such information is collected automatically.
▪ Through Cookies (defined in the “Tracking Tools and Opt-Out” section below).
▪ If you use a location-enabled browser, we may receive information about your location.
● Third Parties
▪ We may use analytics providers to analyze how you interact and engage with the Services, or third parties may help us provide you with customer support.
▪ We may use vendors to obtain information to generate leads.
Our Commercial or Business Purposes for Collecting Personal Data
● Providing, Customizing and Improving the Services
o Creating and managing your account or other user profiles.
o Processing orders or other transactions; billing.
o Providing you with the products, services or information you request.
o Meeting or fulfilling the reason you provided the information to us.
o Providing support and assistance for the Services.
o Improving the Services, including testing, research, internal analytics and product development.
o Personalizing the Services, website content and communications based on your preferences.
o Doing fraud protection, security and debugging.
o Carrying out other business purposes stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws.
● Marketing the Services
o Marketing and selling the Services.
● Corresponding with You
o Responding to correspondence that we receive from you, contacting you when necessary or requested, and sending you information about ScholarSite or the Services.
o Sending emails and other communications according to your preferences or that display content that we think will interest you.
● Meeting Legal Requirements and Enforcing Legal Terms
o Fulfilling our legal obligations under applicable law, regulation, court order or other legal process, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities.
o Protecting the rights, property or safety of you, ScholarSite or another party.
o Enforcing any agreements with you.
o Responding to claims that any posting or other content violates third-party rights.
o Resolving disputes.
We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated or incompatible purposes without providing you notice.
How We Share Your Personal Data
We disclose your Personal Data to the categories of service providers and other parties listed in this section. Depending on state laws that may be applicable to you, some of these disclosures may constitute a “sale” of your Personal Data. For more information, please refer to the state-specific sections below.
● Service Providers. These parties help us provide the Services or perform business functions on our behalf. They include:
o Hosting, technology and communication providers.
o Payment processors.
▪ Our payment processing partner Stripe, Inc. (“Stripe”) collects your voluntarily-provided payment card information necessary to process your payment.
● Analytics Partners. These parties provide analytics on web traffic or usage of the Services. They include:
o Companies that track how users found or were referred to the Services.
o Companies that track how users interact with the Services.
● Business Partners. These parties partner with us in offering various services. They include:
o Businesses that you have a relationship with.
▪ For example, if you are referred to the Services by one of our Business Partners, we may share your names and Net Promoter Score feedback with such Business Partner.
o Companies that we partner with to offer joint promotional offers or opportunities.
● Parties You Authorize, Access or Authenticate
o Other users.
We may share any Personal Data that we collect with third parties in conjunction with any of the activities set forth under “Meeting Legal Requirements and Enforcing Legal Terms” in the “Our Commercial or Business Purposes for Collecting Personal Data” section above.
All of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part). Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.
Data that is Not Personal Data
We may create aggregated, de-identified or anonymized data from the Personal Data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified or anonymized data and share it with third parties for our lawful business purposes, including to analyze, build and improve the Services and promote our business, provided that we will not share such data in a manner that could identify you.
Tracking Tools and Opt-Out
We use the following types of Cookies:
● Essential Cookies. Essential Cookies are required for providing you with features or services that you have requested. For example, certain Cookies enable you to log into secure areas of our Services. Disabling these Cookies may make certain features and services unavailable.
You can decide whether or not to accept Cookies through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your device. If you do this, however, you may have to manually adjust some preferences every time you visit our website and some of the Services and functionalities may not work.
To explore what Cookie settings are available to you, look in the “preferences” or “options” section of your browser’s menu. To find out more information about Cookies, including information about how to manage and delete Cookies, please visit http://www.allaboutcookies.org/ or https://ico.org.uk/for-the-public/online/cookies/ if you are located in the European Union or United Kingdom.
Data Security and Retention
We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data. You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.
We retain Personal Data about you for as long as you have an open account with us or as otherwise necessary to provide you with our Services. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.
Personal Data of Children
State Law Privacy Rights
California Resident Rights
Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties’ direct marketing purposes; in order to submit such a request, please contact us at firstname.lastname@example.org.
Nevada Resident Rights
If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third parties who intend to license or sell that Personal Data. You can exercise this right by contacting us at email@example.com with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. Please note that we do not currently sell your Personal Data as sales are defined in Nevada Revised Statutes Chapter 603A.
European Union and United Kingdom Data Subject Rights
EU and UK Residents
If you are a resident of the European Union (“EU”), United Kingdom (“UK”), Lichtenstein, Norway or Iceland, you may have additional rights under the EU General Data Protection Regulation, as incorporated into applicable local law (collectively, the “GDPR”) with respect to your Personal Data, as outlined below.
For this section, we use the terms “Personal Data” and “processing” as they are defined in the GDPR, but “Personal Data” generally means information that can be used to individually identify a person, and “processing” generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure. ScholarSite will be the controller of your Personal Data processed in connection with the Services.
Personal Data We Collect
The “Categories of Personal Data We Collect” section above details the Personal Data that we collect from you.
Personal Data Use and Processing Grounds
The “Our Commercial or Business Purposes for Collecting Personal Data” section above explains how we use your Personal Data.
We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity and our “legitimate interests” or the legitimate interest of others, as further described below.
o Profile or Contact Data
o Payment Data
● Legitimate Interest: We process the following categories of Personal Data when we believe it furthers the legitimate interest of us or third parties:
o Commercial Data
o Device/IP Data
o Web Analytics
o Geolocation Data
o Social Network Data
o Consumer Demographic Data
o Professional or Employment-Related Data
o We may also de-identify or anonymize Personal Data to further our legitimate interests.
Examples of these legitimate interests include (as described in more detail above):
o Providing, customizing and improving the Services.
o Marketing the Services.
o Corresponding with you.
o Meeting legal requirements and enforcing legal terms.
o Completing corporate transactions.
● Consent: In some cases, we process Personal Data based on the consent you expressly grant to us at the time we collect such data. When we process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection.
● Other Processing Grounds: From time to time we may also need to process Personal Data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.
Sharing Personal Data
The “How We Share Your Personal Data” section above details how we share your Personal Data with third parties.
EU and UK Data Subject Rights
You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email us at firstname.lastname@example.org. Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.
● Access: You can request more information about the Personal Data we hold about you and request a copy of such Personal Data. You can also access certain of your Personal Data by logging on to your account.
● Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. You can also correct some of this information directly by logging on to your account.
● Erasure: You can request that we erase some or all of your Personal Data from our systems.
● Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Services.
● Portability: You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.
● Objection: You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes, such as for direct marketing purposes.
● Restriction of Processing: You can ask us to restrict further processing of your Personal Data.
● Right to File Complaint: You have the right to lodge a complaint about ScholarSite's practices with respect to your Personal Data with the supervisory authority of your country or EU Member State or UK Information Commissioners Office (“UK ICO”). A list of Supervisory Authorities is available here: https://edpb.europa.eu/about-edpb/board/members_en , and information regarding the UK ICO can be found here: https://ico.org.uk/about-the-ico/.
Transfers of Personal Data
The Services are hosted and operated in the United States (“U.S.”) through ScholarSite and its service providers, and if you do not reside in the U.S., laws in the U.S. may differ from the laws where you reside. By using the Services, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to ScholarSite in the U.S. and will be hosted on U.S. servers, and you acknowledge that ScholarSite may transfer, store and process your information to and in the U.S., and possibly other countries. You hereby acknowledge that such transfer of your data to the U.S. may occur pursuant to a data processing agreement incorporating standard data protection clauses promulgated by the European Commission, a copy of which can be obtained at https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj?uri=CELEX:32021D0914&locale=en (as may be modified pursuant to applicable law), if ScholarSite is processing your Personal Data as a processor.
● 415 994 7284
● Suite 501, 466 Geary St, San Francisco, CA 94102
General Data Protection Regulation (GDPR) – European Representative
Pursuant to Article 27 of the General Data Protection Regulation (GDPR), Scholarsite has appointed European Data Protection Office (EDPO) as its GDPR Representative in the EU. You can contact EDPO regarding matters pertaining to the GDPR:
● by using EDPO’s online request form: https://edpo.com/gdpr-data-request/
● by writing to EDPO at Avenue Huart Hamoir 71, 1030 Brussels, Belgium
UK General Data Protection Regulation (GDPR) - UK Representative
Pursuant to Article 27 of the UK GDPR, Scholarsite has appointed EDPO UK Ltd as its UK GDPR representative in the UK. You can contact EDPO UK regarding matters pertaining to the UK GDPR:
● by using EDPO’s online request form: https://edpo.com/uk-gdpr-data-request/
● by writing to EDPO UK at 8 Northumberland Avenue, London WC2N 5BY, United Kingdom