CollegeNET, Inc. Privacy and Security Statement

(Last Updated: September 21, 2012)

Introduction

The security of our users' personally identifiable information is a high priority for CollegeNET, Inc. ("CollegeNET"). This Privacy Statement ("Statement") applies to personally identifiable information collected by CollegeNET on its Web sites at www.collegenet.com, http://www.corp.collegenet.com, www.contribute.com,www.applyweb.com and www.collegenet.cn. We also act as an outsourced service provider for colleges, universities, nonprofits, and other organizations (referred to in this Statement as our "client institutions"). When our client institutions collect information about you through the use of our facilities, their privacy policies and practices govern their use and disclosure of that information.

Personally identifiable information, which we call "personal information" in this Statement, is information that directly identifies or is directly associated with an identifiable person. Some examples of personal information include a user's name, address, email address, social security number, citizenship, date and place of birth, and parents' names and addresses. Personal information does not include aggregate information or de-identified information. "Aggregate information" is information about the use of our Web sites, such as information collected about site users, or a category of services or users, from which any personal information has been removed. An example of aggregate information would be de-identified data indicating that forty-seven percent of the site's registered users have identified themselves as male.

Overview

Collection. We collect personal information on our Web sites, such as when you register for and participate in our Scholarship Election System or USAcademy. We also collect personal information for our client institutions in the course of providing Web-based and email transaction processing services branded to them. We obtain this information via email and in "forms" that we host for our client institutions.

Use. When we collect personal information for a client institution, we provide it to that client institution. The client institution's privacy policies and practices, and not this Statement, govern the client institution's use of that personal information. When we collect personal information on our Web sites, we use the information to complete the transactions requested by you, to administer, improve, and develop our sites and services, and for the other purposes described in this Statement.

Disclosure. We do not rent or sell your personal information to third parties. We provide personal information that we collect for a client institution to that client institution. We do not disclose your personal information to third parties other than for the limited purposes described in this Statement.

The remainder of this Statement gives more detailed information about our collection, use and disclosure of personal information, in addition to the measures we take to protect personal information while in our control.

Our Business

We host Web-based admissions, housing, parking, tuition, registration, contribution, scholarship, and other services for our client institutions. In the course of providing these services, we collect personal information in email that we receive and in scholarship, admissions, donation, contribution, and other Web-based forms. These forms are hosted on CollegeNET servers, but users may link to the pages and forms associated with our services via our Web sites or via the sites of the client institutions identified on the forms. We also provide a service called USAcademy that allows users to access information about US culture, US colleges and universities, and the experience of attending college in the United States.

Personal Information That We Collect

We collect personal information from you when you voluntarily provide such information by registering for a CollegeNET account. We require you to register for an account in order to fill out an application, contribution, scholarship, or other form we host for a client institution. If you participate in our Scholarship Election System or in USAcademy, we require you to establish a CollegeNET account and to provide additional personal information.

When you create a CollegeNET account, we ask you to create a username and password and to provide your first name, last name, and email address. When you submit an application, make a donation, or otherwise use our facilities to perform an action that requires the payment of a fee to the client institution (e.g., to pay admission application fees or to make a donation to a client institution), we collect your electronic payment information.

We also automatically collect some information when you use our sites, such as your IP address (a unique number assigned to a specific computer on the Internet) and standard information included with every communication sent on the Internet. This information allows us to determine your browser version and type, operating system, browser language, Internet service provider, and which pages you view on our Web sites. All of this information may be aggregated and used for various purposes. It is not, however, used to identify you personally.

An application or other form is "in process" from the time you start it until the time you complete it. While it is in process, you may access the form and modify the information you have entered into it by following the instructions on the application or other form. Once you submit a form, you will not be able to access or modify the information submitted on that form through CollegeNET.

Scholarship Election System

In order to participate in our Scholarship Election System, you must register for a CollegeNET account. The Scholarship Election System allows a registered user to become a candidate for scholarships for which he or she is eligible, to vote for other scholarship candidates, to post comments, essays, candidate statements, and other information, and to indicate a relationship to a candidate.

Scholarship Election System registration is separate from general CollegeNET account registration. To register for the Scholarship Election System, you are required to provide your full name, city of residence, email address, valid mobile telephone number (capable of receiving text messages), the US college to which you would like CollegeNET to apply any scholarship funds that you may be awarded, and the date on which you anticipate that any scholarship funds that you may win would be used. You may also provide optional information, including the name of your high school, a photo of yourself (or another image), and a general statement (regarding, for example, the reasons why users should vote for you to receive a scholarship). Your mobile telephone number is used to send you a text message containing a passcode. You must enter that passcode on the Scholarship Election System Web site in order to confirm your registration.

Your Scholarship Election System user name, photo or other image, high school, and general candidate statements, posts you make to discussions, other information you may put in your profile, and any relation to a candidate you indicate on the site, will all be publicly available on the site. Please keep this in mind when you choose a user name and if you choose to disclose your photo, statements, discussion postings, and other information in connection with the Scholarship Election System. Please do not write or post any images or information that you do not want publicly available.

USAcademy

In order to participate in USAcademy, you must register for a CollegeNET account. USAcademy allows a registered user to access information about US culture, US colleges and universities, and the experience of attending college in the United States and to participate in interactive areas of the site.

Your USAcademy user name, photo or other image, other information you may put in your profile, questions you ask, and posts you make to discussions, will all be publicly available on the site. Please keep this in mind when you choose a user name and if you choose to disclose your photo, statements, discussion postings, and other information in connection with USAcademy. Please do not write or post any images or information that you do not want publicly available on the site.

Use of Personal Information

We use personal information that you provide to us to complete the transactions requested by you, to administer USAcademy and our Scholarship Election System (which may include, but is not limited to, contacting you to verify your account, to provide updates on your election standing, and to let you know how many ballots you have left) and, if applicable, to contact you for administrative purposes or provide you with customer service, respond to your questions, problems, or complaints, request feedback, organize the Web sites to better serve you, customize our products and services, and develop new products and services. We may also use publicly available postings, submissions, and other content that you post or transmit to or within our Scholarship Election System or USAcademy (collectively, "Postings") for any purpose.

Disclosure of Personal Information

We do not rent or sell personal information to third parties. We may disclose personal information that you provide to us in connection with USAcademy or our Scholarship Election System to the person or school that you designate.

When you provide information to us in forms that we host for client institutions, we transmit your personal information (excluding your electronic payment information, if applicable) to those parties identified in the applications, contributions, scholarships, or other forms you choose to submit and, if applicable, to the third party service providers specified by the client institutions. Client institutions may initiate transmission of your data to third parties through CollegeNET-served technologies. We also disclose your electronic payment information to our payment processor in order to complete any online payment of admission application fees, contributions, or other fees to the parties you have selected.

Except as set forth in this Statement, CollegeNET will not disclose your personal information to third parties. CollegeNET may disclose your personal information to third parties when CollegeNET reasonably believes it is necessary to do so in order to prevent abuse, fraud, or unlawful use of our Web sites or our services, protect our rights, safety, or property, or protect the rights, safety, or property of our client institutions or other end users; or when we believe doing so is necessary to comply with the law. We also may disclose personal information in connection with any merger, acquisition, or sale of our assets, as well as in the event of an insolvency, bankruptcy, or receivership in which personal information could be transferred to third parties as part of our business. Finally, we may also disclose personal information to third party vendors and service providers who assist us in performing internal functions necessary to operate our business (for example, analyzing data, processing electronic payments, and fulfilling or delivering orders or other materials).

By providing us with your personal information, you are giving us your express consent to our disclosure of your personal information but only for the purposes described in this Statement.

Third Party Privacy Practices

While we strongly support the protection of privacy on the Internet, we do not have control over, and cannot be responsible for, the actions of our client institutions or other third parties. When we collect personal information in the course of acting as a service provider to our client institutions, the privacy policies and practices of the client institution whose form you have submitted will govern how that client institution treats your personal information. Our client institutions typically provide privacy statements at their sites describing how they treat personal information. We encourage you to review each such third party's privacy statement, if any, and to otherwise understand its privacy practices, before providing personal information directly to it or in our forms on which it is named. Additionally, you may be able to access non-CollegeNET sites from our Web sites (for example, by clicking on an advertisement or a search engine link). When you access non-CollegeNET sites from our Web sites, the policies described in this Statement, along with all other CollegeNET policies, no longer govern.

Children Under 13

Our sites and the forms accessible using our technology are not intended to collect personal information from children under the age of 13. If you are under 13 years old, you should not create an account with us, otherwise provide personal information to us through our sites or other services, or create any applications or other forms through our services.

Cookies

We may use cookies, Web beacons, or other technologies to identify users, to collect information about their preferences and history, and to customize their experiences. Our cookies contain no personal information about you. We use cookies to prevent you from having to repeatedly enter your login information, to save college and scholarship searches temporarily, to administer our Web sites and help us understand how visitors use them, and to improve our Web sites and related products and services.

We may use third parties, including network advertisers and other third party ad servers, to deliver ads or other functionality to you. These third parties may use cookies, Web beacons, or other technology to collect information about your visits to our Sites and may use that information to present news and advertisements that may be of interest to you (including while you are no longer on our Sites) or to integrate with social networking sites. This Statement does not apply to, and we are not responsible for, cookies, Web beacons, or similar technologies in third party services, and we encourage you to check the privacy policies of such third parties to learn about their use of cookies and other technology.

You may refuse to accept cookies by following the procedures specific to your Web browser. If you do so, your browser may react strangely and you may not be able to complete, save, or submit a form or use some services on our Sites.

Security

We use reasonable security measures in an effort to prevent loss, misuse, or alteration of personal information under our control. When you submit an application or other form through our sites, provide electronic payment information that we request, or log in to your CollegeNET account, we use encryption, such as the Secure Socket Layer ("SSL") protocol, to protect such information while in transit. We also limit access to personal information while in our control and use firewalls in order to restrict access to it. We provide any electronic payment information you provide to us on our sites or in our forms to our payment processor, and use SSL or other encryption to protect it while in transit. We do not store it after it is transmitted to the payment processor.

Despite these measures, we cannot guarantee protection of all information against interception, misappropriation, misuse, or alteration, or promise that your information will not be disclosed or accessed by accidental circumstances or by the unauthorized acts of others. We have no control over the security of Web pages we do not serve, for example our client institutions' sites or other sites you might visit.

Passwords

Your account information, if you create an account, is accessible online through the use of a password. To protect the confidentiality of personal information that you provide in connection with a user account, you must keep your password confidential and not disclose it to any other person. CollegeNET is not responsible for the consequences of any passwords that you disclose or which are lost or stolen. Please advise us immediately if you believe your password has been misused or otherwise misappropriated.

Location of Personal Information

Our client institutions, as well as our payment processor, maintain separate servers, sites, and other facilities, all of which may reside outside of the jurisdiction, and perhaps the country, where you originally entered the information. By providing us with personal information, you consent to the disclosure of your personal information to entities in jurisdictions other than your own.

P3P

Some of CollegeNET's Web sites may support the Platform for Privacy Preferences ("P3P"). P3P allows Web site operators to convey their privacy policies, to the extent possible, in standardized, machine-readable code. This allows P3P-enabled browsers like Internet Explorer to "interpret" the code and automatically compare it to privacy preferences selected by the user in the browser's settings. In some cases, users may not have selected privacy preferences but instead rely on the default settings in the browser. A P3P-enabled browser automatically informs the user if the Web site's privacy practices do not meet the browser's settings. The user may use this information to decide whether or not to view the site.

Even if a CollegeNET Web site supports P3P, the resulting code does not convey all of CollegeNET's privacy practices. There are certain inherent limitations in trying to explain human concepts about privacy in machine-readable code. For example, P3P is not capable of coding policies with regard to the collection of children's information and parental consent. Moreover, different browsers may interpret CollegeNET's P3P code in different and, at times, conflicting ways. Because of these limitations, P3P does not fully, and may not accurately, express all of CollegeNET's data practices. Accordingly, P3P results obtained through use of your browser should only be considered as a shorthand expression of CollegeNET's privacy practices, whereas CollegeNET's Privacy Statement is the primary source of information and will take precedence over P3P for all purposes.

Statement Changes

We will modify this Statement if our privacy practices materially change in the future. We will notify you of any such modification only by posting the modified Privacy Statement on our sites and indicating at the top of the Statement the date it was last updated. We encourage you to review the Statement each time you visit one of our sites, to see if this Statement has been updated since your last visit to make sure you understand how personal information you provide to us will be used.

Questions / Additional Information

If you have any questions about this Statement, please email us at privacy_info@collegenet.com.