Privacy Policy

Last revised: December 1, 2020

ADX Media, LLC ("we", "us", "our") works hard to build and maintain a relationship of trust with you. This Privacy Policy (the "Privacy Policy") governs our collection, use, and disclosure of your Personal Information (as defined below) in connection with your use of our website(s) ("Site"), such as collegeeducation.info, and any services, transactions, engagements, or other interactions you might have with us (collectively, "Services").

This Privacy Policy explains what information we collect about you, how we use or disclose such information, how to exercise any rights you may have with respect to your Personal Information (including any rights to opt-out of certain uses of your information), and the safeguards we have in place to reduce the risk of unauthorized access and use.

Please carefully read this Privacy Policy, which is part of our Terms of Use, before using our Site and/or Services. If you do not agree with our Terms of Use and/or this Privacy Policy, you must refrain from using our Site/Services. By accessing or using our Site or Services, you agree to our use of your information consistent with our Terms of Use and this Privacy Policy.

PRIVACY POLICY CHANGES

This Privacy Policy is subject to change. We encourage you to review this Privacy Policy frequently for any revisions or amendments. Changes to this Privacy Policy will be posted on this Site and will be effective immediately upon posting. You will be deemed to have been made aware of and have accepted the changes by your continued use of our Site or Services. If we determine that a change to this Privacy Policy will result in using your Personal Information acquired before the change being used in a materially new way, we will provide you notice before using your Personal Information in the new way.

CONFLICT BETWEEN THIS POLICY AND LOCAL LAWS AND REGULATIONS

When federal, state, and local laws and regulations require a higher level of protection for your Personal Information, they take precedence over this Privacy Policy. In addition, the specific requirements of this Privacy Policy apply only when local laws and regulations permit.

Information We Collect as a Business

Personal Information

We collect information that personally identifies, relates to, describes, or is capable of being associated with you ("Personal Information"), including, but not limited to:

Personal Identifiers (e.g., name, IP address, date of birth);
Characteristics of Protected Classifications (e.g., gender, age, citizenship, ethnicity, military or veteran status);
Commercial Information (e.g., ownership or access to a computer, access to high speed internet, URL of site visited with advertisement, desired appointment);
Education Information (e.g., education plans, education level, graduation year, education program start date, college and program of interest, entrance exam scores);
Contact Information (e.g., mailing address, email address, phone number);
Inferences drawn from the above categories of Personal Information that relate to your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

The types of Personal Information we collect about you may vary based on how you use the Site and/or Services and your relationship with us.

Business Information

We also collect information about businesses and their representatives that engage with us such as EIN, TIN, contact person name, address, phone number, contact person email address, bank account information, and number of years in business (collectively, "Business Information"). This information is generally not considered Personal Information because it relates to a business or a business contact; however, to the extent we must treat any Business Information as Personal Information under applicable laws we will do so.

Usage Data and Site Activity

We automatically collect information in connection with the actions you take on the Site ("Usage Data"). For example, each time you use the Site, we may automatically collect the type of web browser you use, the type of device you use, your operating system, your Internet Service Provider, the pages you view, referring and exit pages, the date and time of your visit, and the number of clicks to, from, and within the Site, and the duration of your visits to the Site. If this information is capable of being associated with you, directly or indirectly, we treat it as Personal Information. If this information is not capable of being individually associated with you, we treat it as Usage Data.

Communication Recordings

We may record calls and retain the content of text messages or other written/electronic communications between you and us. By communicating with us, you consent to our recording and retention of communications.

How We Collect Information

Voluntary Disclosure

We may ask you to provide us with Personal Information and/or Business Information when you communicate with us (online or offline), make a purchase from us, enter into an agreement with us, and at other times.

Third-Party Data Sources

We may collect Personal Information directly or indirectly from third-party data sources such as data brokerages, marketing/advertising agencies, analytics firms, corporate affiliates, lead scoring and lead compliance companies, and government agencies (e.g., U.S. Census Bureau, U.S. Postal Service, state and local recording offices).

Cookies & Other Automated Tools

We use cookies (a small text file placed on your computer to identify your computer and browser) and other automated tools such as tracking pixels to improve the experience of the site and Services, such as saving your preferences from visit to visit to present you with a customized version of the Website. Many web browsers are initially set up to accept cookies. You can reset your web browser to refuse all cookies or to indicate when a cookie is being sent. Instructions for how to manage cookies in popular browsers are available at: Internet Explorer, Firefox, Chrome, Safari (iOS) , Safari (Mac), and Opera. However, certain features of the Site may not work if you delete or disable cookies.

We use the following types of cookies:

Session Cookies: Session cookies keep track of you or your information as you move from page to page within the Site and are typically deleted once you close your browser. For example, session cookies allow your online credit application to function properly.
Analytics Cookies: Analytics cookies help us understand how our Site is working and who is visiting our Site. Google Analytics is one tool we use, and you can learn more by reviewing Google's Privacy Policy.

We employ software technology that enables us to track certain aspects of a user's visit to the Site. This technology helps us better manage content on the Site by informing us what content is effective, how consumers engage with the Site, and how consumers arrive at and/or depart from the Site. The software typically uses two methods to track user activity: (1) "tracking pixels" and (2) "clear gifs." Tracking pixels are pieces of executable code that are embedded in a web page that track usage activity including which pages are viewed, when they are viewed, and how long the pages are viewed. Clear gifs are tiny graphics with unique identifiers which are embedded in web pages and email messages that track whether or not a user has viewed a particular web page or email message. User activity information may be associated with additional information about a user's session and Personal Information, if provided by the user.

If you arrive at the Site by "clicking through" from another website, then certain information about you that you provided to that other website, such as the terms you were searching on that led you to the Site, may be transmitted to us and we may use it. You should review the Privacy Policy of any website from which you reached the Site to determine what information was collected by that website and for what purpose(s) you agreed that website could use that information. We may retain information about you provided to us by other websites and will only use it in accordance with this Privacy Policy. Such information may be associated with other Usage Data or Personal Information.

Social Media Widgets

The Site may include social media features, such as the LinkedIn widget. These features may collect information about your IP address and the pages you visit on our site as well as other Personal Information. A cookie may be set to ensure that a feature properly functions. Your interactions with features are governed by the privacy policies of the companies that provide them.

How We Use and Share Information As A Business

Generally

We use Personal Information for internal purposes, such as to:

Provide you with the Site and Services;
Service our clients' accounts;
Market our products and services to you;
Perform marketing and other types of data analytics;
Operate information security and anti-fraud programs;
Perform day-to-day business operations; and
Respond to governmental and other legal requests.

Service Providers

We may establish a relationship with other businesses to provide services to us which may include corporate affiliates ("Service Providers"), including for:

Payment processing;
Reporting data usage;
Facilitating marketing and non-marketing communications;
Marketing design and development;
Business analytics (both marketing and non-marketing related);
IT and network administration such as data storage and management, website hosting, and data security;
Professional services such as legal and accounting;
Contacting individuals by phone, email, text message, and other media;
Quality control;
Lead scoring and lead compliance analysis;
Obtaining legal records;
Collection of accounts; and
Day-to-day business operations such as courier services, facilities management, and document destruction.

We only provide our Service Providers with the information necessary for them to perform these services on our behalf. Each Service Provider is expected to use reasonable security measures appropriate to the nature of the information involved to protect your Personal Information from unauthorized access, use, or disclosure. Service Providers are prohibited from using Personal Information other than as specified by us.

We share the following types of Personal Information with one or more Service Providers: personal identifiers; financial information; characteristics of protected classifications; commercial information; employment/professional information; education information; contact information; inferences drawn from the above categories of Personal Information.

Third-Party Sharing/Selling

We may share or sell your Personal Information with other companies who do not provide services to us ("Third Parties") such as companies that market and/or sell products and services to consumers and the service providers for those companies. We sell Personal Information to businesses looking to connect with potential new customers, including, but not limited to, educational institutions, rideshare services, insurance agencies/companies, food delivery services, home improvement companies, military branches, travel companies, job and career services, healthcare services, and financial service companies. We share or sell the following types of Personal Information with one or more Third Parties: personal identifiers; financial information; characteristics of protected classifications; commercial information; employment/professional information; education information; contact information; inferences drawn from the above categories of Personal Information.

SECURITY

We recognize the importance of safeguarding the confidentiality of Personal Information from loss, misuse, or alteration. Accordingly, we employ commercially reasonable administrative, technical, and physical safeguards to protect such Personal Information from unauthorized access, disclosure, and use. Even with these safeguards, no data transmission over the Internet or other network can be guaranteed 100% secure. As a result, while we strive to protect information transmitted on or through our Site or Services, you do so at your own risk.

OTHER WEBSITES

Please be aware that third-party websites accessible through the Site or recommended through our Services may have their own privacy and data collection policies and practices. We are not responsible for any actions, content of websites, or privacy policies of such third parties. You should check the applicable privacy policies of those third parties when providing information.

COMPLIANCE WITH LAWS AND LAW ENFORCEMENT

We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We may disclose Personal Information and any other information about you to government or law enforcement officials or private parties if, in our discretion, we believe it is necessary or appropriate to respond to legal requests (including court orders, investigative demands and subpoenas), to protect the safety, property, or rights of ourselves, consumers, or any other third party, to prevent or stop any illegal, unethical, or legally actionable activity, or to comply with law.

OTHER TRANSFERS

We may share Personal Information and Usage Data with businesses controlling, controlled by, or under common control with us. If we are merged, acquired or sold, or in the event of a transfer of some or all of our assets, we may disclose or transfer Personal Information and Usage Data in connection with such transaction.

HOW LONG WE RETAIN YOUR DATA

We retain your Personal Information for as long as we have a relationship with you. We also retain your Personal Information for a period of time after our relationship with you has ended where there is an ongoing business need to retain it. This includes retention to comply with our legal, regulatory, tax, and/or accounting obligations. Generally, we retain Personal Information for approximately seven (7) years after our relationship with you has ended, but the term for which we retain your Personal Information may be longer or shorter. We do so in accordance with our data retention policies and applicable law.

CHILDREN'S PRIVACY

The Site and Services are not intended for children under the age of 16 and we do not knowingly collect Personal Information from children under the age of 16. If we become aware that we have inadvertently received Personal Information from a child under the age of 16, we will delete such information from our records.

ADDITIONAL CALIFORNIA CONSUMER RIGHTS

If you are a resident of California, you have additional rights to access and control your Personal Information, including a right to request that we disclose the Personal Information we collect, use, disclose, and sell, under the California Consumer Privacy Act.

Right to Know

You have the right to request twice per 12-month period that we provide you (i) the categories or specific pieces of Personal Information we collected about you; (ii) the categories of sources from which your Personal Information was collected; (iii) the business or commercial purpose for which we collected your Personal Information; (iv) the categories of Third Parties with whom we shared your Personal Information; and (v) the categories of Third Parties to whom we sold your Personal Information. We are not permitted to provide access to specific pieces of Personal Information if the Personal Information is sensitive or creates a high risk of potential harm from disclosure to an unauthorized person such as financial information, social security numbers, and driver's license numbers.

To request access to your Personal Information and the information listed above, you may submit a request through our CCPA request page or by calling us at 253-218-1966. This page has more information about how you can verify your identity or designate an authorized agent to submit a request on your behalf.

Right to Deletion

You have the right to request that we delete any Personal Information we have collected about you. Please understand that we are not required to honor a deletion request if a legal exemption applies such as if we need the information to complete a requested or reasonably anticipated transaction, prevent security incidents or fraud, enable internal uses that are reasonably aligned with your expectations, or comply with legal obligations.

To request deletion of your Personal Information and the information listed above, you may submit a request through our CCPA request page or by calling us at 253-218-1966. This page has more information about how you can verify your identity or designate an authorized agent to submit a request on your behalf.

Right to Opt-Out from the Sale of Personal Information

You have the right to direct us not to sell your Personal Information to Third Parties. You may exercise your Right to Opt-Out by submitting a request via our "Do Not Sell My Info" request page or by calling us at 253-218-1966. This page has more information about how you can verify your identity or designate an authorized agent to submit a request on your behalf.

Non-Discrimination Notice

We will not discriminate against any consumer for exercising their privacy rights under law or this Privacy Policy.

California "Do Not Track" Disclosure

Do Not Track is a web browser privacy preference that causes the web browser to broadcast a signal to websites requesting that a user's activity not be tracked. At this time, our Site and Services do not respond to "do not track" signals.

CONTACT US

If you have any questions about our Site, Services, or this Privacy Policy, please email us at info@adx.media, call us at 253-218-1966, or send us a letter to the following address:

ADX Media, LLC
Attn: Privacy
401 Broadway Suite 100
Tacoma, WA 98402