Effective Date: January 1, 2020

Last Revised: January 14, 2020

GetDesignDegrees and its affiliates, subsidiaries, and partners (collectively “GetDesignDegrees" or “we,” “us,” and “our”) provide educational lead generation services. We respect your privacy and are committed to protecting it through our compliance with this policy. This policy describes the types of information we may collect from you or that you may provide through our websites and anywhere else we interact with you. By using any of our web sites, or sharing your information with us, you are accepting and consenting to the practices described in this Privacy Policy.

Information We Collect

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (”personal information”). Personal information does not include:

• Publicly available information from government records.
• Deidentified or aggregated consumer information.

In particular, we have collected the following categories of personal information from its consumers within the last twelve (12) months:

We obtain the categories of personal information listed above from the following categories of sources:

• Directly from you. For example, from forms you complete or products and services you purchase.
• Indirectly from you. For example, from observing your actions on our Website.
• From third party marketing and data partners.
• From vendors.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following purposes:

• To fulfill or meet the reason you provided the information. For example, if you submit a request for information about a product or service on one of our Websites, we will share information about you contained in the request form with third parties regarding whose products or services you seek information. Alternatively, we may directly fulfill your request for the information you seek. Third parties who provide products or services regarding which you seek information may contact you by telephone, e-mail, or postal mail based on the information you provided. In some cases, a third party may be involved in the process - for example, we may share your information with a third party who will fulfill your request on behalf of the third party regarding whose products or services you seek.
• To administer or otherwise carry out our obligations in relation to any agreement to which we are a party.
• To provide, support, personalize, and develop our Websites, products, and services.
• To create, maintain, customize, and secure your account with us.
• To process your requests, purchases, transactions, and payments and prevent transactional fraud.
• To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
• To personalize your Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites, and via email or text message (with your consent, where required by law).
• To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.
• For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to you when collecting your personal information or as otherwise set forth in the CCPA.
• For marketing and promotions we believe you may find of interest and to provide you, or allow selected third parties to provide you, with information about products and services that may interest you.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our consumers is among the assets transferred.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

We share your personal information with the following categories of third parties:

• Service providers.
• Data aggregators.
• Market research companies.
• Educational institutions.
• Educational services companies and their third-party service providers.
• Internet cookie data recipients, like Google Analytics.
• Partners and affiliates.
• Parent or subsidiary organizations.

Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, Company has disclosed the following categories of personal information for a business purpose:

Category A: Identifiers.

Category B: California Customer Records personal information categories.

Category D: Commercial Information.

Category F: Internet or other similar network activity.

Category I: Professional or employment-related information.

Sales of Personal Information

Under the CCPA, a “sale” means providing to a third party personal information for valuable consideration. It does not necessarily mean money was exchanged for the transfer of personal information. We have taken substantial steps to identify whether any of our data sharing arrangements would constitute a “sale” under the CCPA. Due to the complexities and ambiguities in the CCPA, we will continue to evaluate some of our third-party relationships as we wait for final implementing regulations and guidance. For example, it is currently unclear whether the use of certain types of advertising partners would be considered a sale under CCPA. Additionally, while we do sell information to educational institutions and educational service companies, we do so only at the intentional direction and request of a consumer, and therefore, we believe those sales fall under one of the exceptions to the definition of “sale” under the CCPA. We will continue to update our business practices as regulatory guidance becomes available and provides clarity on what constitutes a sale transaction, particularly in the advertising ecosystem.

Cookies

When you visit our websites, we send one or more cookies to your computer or other device. We may also use cookies and other similar technologies in emails that you receive from us. A cookie is a small data file that is placed on the hard drive of your computer when you visit a website. A session cookie expires immediately when you end your session (i.e., close your browser). A persistent cookie stores information on the hard drive so when you end your session and return to the same website at a later date the cookie information is still available. We use cookies to improve the quality of our service when you visit our website and other websites of interest to you. We also use cookies to identify us of who you are, tailor measure and optimize our products, services and advertising to suit the personal interests of you and others, estimate our audience size, assist our online merchants to track visits to at our web sites, and/or analyze your visiting and e-mail interaction patterns.

If you would like to opt out of accepting cookies altogether, you can generally set your browser to not accept cookies or to notify you when you are sent a cookie, giving you the chance to decide whether or not to accept it. However, certain features of our websites or other services may not work if you delete or disable cookies.

We use Google Analytics and Facebook Pixels on our websites to collect usage data, to analyze how users use the websites and to provide advertisements to you on other websites. For more information about how to opt out of having your information used by Google Analytics, visit https://tools.google.com/dlpage/gaoptout/. For more information about how to opt out of having your information used by Facebook, visit https://www.facebook.com/full_data_use_policy.

Advertising and Online Tracking

We allow third-party companies to serve ads and/or collect certain information when you visit our websites. These companies may use information (e.g., click stream information, browser type, time and date, subject of advertisements clicked or scrolled over) collected during your visits to this and other websites in order to provide advertisements about goods and services likely to be of interest to you. These companies may also tie identifiers associated with a particular browser or device to identifiers associated with other browsers or devices used by the same user or household (e.g., a device identifier associated with a user's computer may be tied to the device identifiers of that user's tablet and phone) in order to measure and target advertisements tailored to user interests across their devices and to send personalized marketing communications. These companies typically use a cookie or third-party web beacon to collect this information. Our systems do not recognize "Do Not Track" signals, but several of these third-party companies who utilize these cookies or beacons on our web sites enable you to opt out of this behavioral advertising. To learn more or opt out from these companies you can visit http://www.networkadvertising.org/choices and https://www.aboutads.info/ we also provide you with additional tools to opt out of marketing from us or certain transfers of your information.

Notice for California Residents - Rights and Choices

This Notice applies to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this Notice. The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you (also called a data portability request).
• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
  • sales, identifying the personal information categories that each category of recipient purchased; and
  • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

• Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

• Calling us at 408-641-0859.
• Emailing us at info@GetDesignDegrees.com.
• Visiting www.GetDesignDegrees.com.

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.

We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Website and update the notice’s effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this notice, the ways in which GetDesignDegrees collects and uses your information described here, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone: 408-641-0859

Website: www.GetDesignDegrees.com

Email: info@GetDesignDegrees.com

Postal Address:
GetDesignDegrees
Attn: Compliance
97 South Second Street
Suite 100-136
San Jose, CA 95113