Last Updated: June 28, 2017
XAP Corporation including its subsidiary Bridges Transitions Inc. (collectively, "XAP") (the company that operates www.IHaveaPlanIowa.org) has adopted the following Privacy Statement for the information collected at this website. When you use I Have a Plan Iowa™ XAP has access to your information and may use your information to operate and maintain www.IHaveaPlanIowa.org and in accordance with the terms of this Privacy Statement.
As www.IHaveaPlanIowa.org evolves, we may update this Privacy Statement to reflect changes in the manner in which we deal with personal information, whether to comply with then-applicable regulations and self-regulatory standards or otherwise. The Privacy Statement posted here will always be current. We encourage you to review this Statement regularly. Please see additional information regarding amending this Statement in the Section entitled "Amending this Privacy Statement" below.
IMPORTANT NOTICE: Please see the information in the Section entitled "With whom personally identifying information and automatically collected information may be shared" for an understanding regarding the parties who may access your information.
WHAT THIS PRIVACY STATEMENT COVERS:
- Your agreement to this Privacy Statement
- Types of information collected
- Creating an account when you are under the age of 18
- Reasons we collect personally identifying information
- Ways in which personally identifying information and automatically-collected information may be used
- With whom personally identifying information and automatically-collected information may be shared
- Security measures to protect information; Disclaimer
- Modifying your information
- Retention and Storage
- Amending this Privacy Statement
YOUR AGREEMENT TO THIS PRIVACY STATEMENT
When you use www.IHaveaPlanIowa.org, you signify and affirm that you have read, understand, and agree to the terms of this Statement; that you are competent and capable of understanding, agreeing to, and complying with this Statement; and that this Statement forms a legally-binding agreement between you and XAP. You agree that this Statement is supported by reasonable and valuable consideration (which includes your use of www.IHaveaPlanIowa.org), and you acknowledge your receipt of and the sufficiency of such consideration. If you do not agree with all of the provisions of this Statement, you may not use www.IHaveaPlanIowa.org).
TYPES OF INFORMATION COLLECTED
This Statement covers information you expressly enter into www.IHaveaPlanIowa.org and information that we automatically collect as you use www.IHaveaPlanIowa.org.
THE PERSONALLY IDENTIFYING INFORMATION WE COLLECT
To use certain features of www.IHaveaPlanIowa.org we will require you to provide us with information that personally-identifies you ("Personally Identifying Information" or "PII"). If you choose not to provide us your Personally Identifying Information, you will not be able to use certain features of www.IHaveaPlanIowa.org. When you do provide us your PII, you are authorizing us to use that PII in accordance with this Statement and to store your PII on our servers in the United States. The categories of PII that www.IHaveaPlanIowa.org may collect from you include your name, date of birth, address, email address, phone number, grade level, Social Security number, username and password, demographic data (such as your gender, ethnicity, and zip code), parent's or guardian's names, parent's or guardian's addresses and phone number and other contact information, user preferences, and such additional information as you choose to actively enter into www.IHaveaPlanIowa.org and include in your portfolio or are required to provide by the college and/or financial aid applications that you choose to complete or other actions you choose to take through www.IHaveaPlanIowa.org. Further, some schools may provide students' transcript information to us, including at least the following student PII contained on the applicable student's transcript: Name, address, date of birth, gender, ethnicity, graduation year, email address, grade point average (GPA), Student number (from your school district), and State Student ID. If a school provides us this transcript information about you, we will automatically include that information in your account on www.IHaveaPlanIowa.org.
When you use www.IHaveaPlanIowa.org, we automatically track, collect, and store the following types of information (referred to as "Automatically-Collected Information"): 1) Date and time you access www.IHaveaPlanIowa.org; 2) pages visited and features used, and the order of use; 3) type of computer or other operating device accessing www.IHaveaPlanIowa.org and type of browser used to access www.IHaveaPlanIowa.org; 4) referring source (meaning the website you visit prior to visiting www.IHaveaPlanIowa.org); and 5) other similar information about the interaction between your browser and www.IHaveaPlanIowa.org and activities in which you engage while using www.IHaveaPlanIowa.org. Unless otherwise stated in this Statement, Automatically-Collected Information may be combined with your PII.
When you visit www.IHaveaPlanIowa.org, we collect your Internet Protocol ("IP") address to track and aggregate Automatically-Collected Information. We also collect IP addresses of users when they log onto their account portfolios on www.IHaveaPlanIowa.org in order to confirm the applicable user's identity.
CREATING AN ACCOUNT WHEN YOU ARE UNDER THE AGE OF 18
Between Age 13 and 17
If you are between the ages of 13 and 17, by using www.IHaveaPlanIowa.org, you represent and warrant that you possess legal parental or guardian consent to use www.IHaveaPlanIowa.org and provide PII and Automatically-Collected Information through www.IHaveaPlanIowa.org.
Under Age 13
If you are under the age of 13 and you indicate to us that you are under age 13 when you enter your birthdate into www.IHaveaPlanIowa.org, you can only create an anonymous account that does not require you to enter your name or other Personally Identifying Information. When there are open fields required in order to create such an anonymous account, you may not use any of these open fields to enter Personally Identifying Information, and your account portfolio will not include your Personally Identifying Information. Further, you will be restricted from using any areas of www.IHaveaPlanIowa.org that require you to enter Personally Identifying Information. You will only be able to use www.IHaveaPlanIowa.org features or modules that do not require you to enter Personally Identifying Information.
REASONS WE COLLECT PERSONALLY IDENTIFYING INFORMATION
www.IHaveaPlanIowa.org collects PII from you primarily for three reasons. The first reason is to perform a task on www.IHaveaPlanIowa.org requested by you, such as filling out a financial aid application. The second reason is to enable you to submit, in a convenient and efficient manner, information that is likely to be needed when you complete college admission, financial aid, and other applications and forms made available through www.IHaveaPlanIowa.org or undertake a scholarship search on www.IHaveaPlanIowa.org. The third reason is to enable XAP to respond to your questions or contact you when necessary in connection with the functioning of www.IHaveaPlanIowa.org or to provide required notices.
WAYS IN WHICH PERSONALLY IDENTIFYING INFORMATION AND AUTOMATICALLY-COLLECTED INFORMATION MAY BE USED
Upon your instructions to do so, www.IHaveaPlanIowa.org will use your PII to complete the following forms and surveys, to obtain information for you, and to effect transactions on your behalf:
- Complete financial aid applications
- Complete financial aid calculators
- Complete a scholarship search
- Complete Your Plan of Study, which can assist you in selecting courses and otherwise planning to meet admission requirements
- Communicate your requests for information or material to colleges or other institutions you have specified
- Complete applications for admission to educational institutions
Your PII and Automatically-Collected Information may also be used for the following purposes:
- We may use your PII and Automatically-Collected Information to help diagnose problems with the www.IHaveaPlanIowa.org server and to administer www.IHaveaPlanIowa.org.
- We may use your PII and Automatically-Collected Information to customize and tailor your experience using www.IHaveaPlanIowa.org, displaying content on www.IHaveaPlanIowa.org that we think you might be interested in and according to your preferences (but we do not track your activity across multiple websites for the purpose of serving targeted advertising to you).
Summary data consisting of a compilation of de-identified and aggregate data representing www.IHaveaPlanIowa.org users may be collected by XAP and provided to various entities including colleges and other educational institutions represented on www.IHaveaPlanIowa.org. NO PII IS MADE AVAILABLE AS PART OF THESE SUMMARY REPORTS. Some examples of summary data are the number of monthly visitors to www.IHaveaPlanIowa.org, the number of admission applications submitted over www.IHaveaPlanIowa.org, and the www.IHaveaPlanIowa.org functions utilized by students in specified age or grade ranges.
WITH WHOM PERSONALLY IDENTIFYING INFORMATION AND AUTOMATICALLY-COLLECTED INFORMATION MAY BE SHARED
Except as set forth below, PII you enter on www.IHaveaPlanIowa.org is not made available or distributed to third parties, except with your express consent or at your express direction. In particular, XAP will not give, sell, rent, trade, transfer, otherwise provide or provide access to your PII to any company, individual, or organization for its use in marketing or commercial solicitation or for any other purpose, except with your express consent and at your direction, unless it is pursuant to one of the exceptions listed below or necessary for operation of www.IHaveaPlanIowa.org.
We may share your PII as follows:
- School Administration and Staff. Your account is meant to help you set goals and plan for the future. If you connect your account to a school or other site using www.IHaveaPlanIowa.org as part of a career and education planning program, then professional staff at that school or site designated by the administration of the school or site to have access to the www.IHaveaPlanIowa.org Professional Center will have access to view (i) your www.IHaveaPlanIowa.org portfolio, including your PII that is part of your portfolio, (ii) email communications to and from you through www.IHaveaPlanIowa.org, (iii) and all other PII and other content that you add to www.IHaveaPlanIowa.org as part of your portfolio. This access is granted to these professional users so that they may assist you in a guidance capacity with your career and education planning.
- Parents and Guardians. You may request that your parent or legal guardian be given permission to view your portfolio (including all PII and other content that you add to www.IHaveaPlanIowa.org as you use www.IHaveaPlanIowa.org). And if you do make this request, your parent or legal guardian will be granted access to your portfolio and may view all of your PII associated with your portfolio.
- Bridges Transitions Inc. XAP Corporation and Bridges Transitions Inc. reserve the right to share PII with one another (regardless of which entity first collected the information) in connection with the maintenance and operation of www.IHaveaPlanIowa.org and for use in accordance with this Statement.
- As Directed by You. Any time you request that we perform a task that involves a transfer of PII, the PII related to the performance of that task will be made available to a recipient you designate. For example:
- If you submit an application for admission to a college or other educational institution, the PII required to complete that application and any other PII you entered onto the application will be provided on your behalf to the admissions office of the institution to which you are applying.
- If you request that a college or other educational institution send you material, your contact information will be provided to that institution so the institution can send you material and contact you.
Note: If you begin an application for admission to a college or other educational institution, your name and other PII entered on that application may be provided to the admissions office of that institution, even though you have not yet submitted a completed application to that institution. The institution may then contact you regarding your potential attendance.
Required by Law. When required by law to comply with any valid legal process such as a statute, regulation, search warrant, subpoena, or court order, XAP may supply PII contained in your www.IHaveaPlanIowa.org account as XAP reasonably determines, based on the advice of counsel, it is legally required to supply. XAP may also disclose PII in emergency situations, to protect your safety or the safety of others, to defend against legal claims, to enforce XAP's contractual or other rights, or to take actions regarding illegal activities or suspected fraud.
Merger, Acquisition, or Sale of XAP. XAP may transfer your PII and Automatically-Collected Information to another entity if XAP is involved in a merger, acquisition, reorganization, restructuring, or other sale or transfer of all or any portion of its assets or business. In this event, we will, if allowed, use reasonable efforts to notify you when your information is transferred to a third party (this notification may be made via email to you or by posting a prominent notice on www.IHaveaPlanIowa.org). Unless you consent otherwise, XAP will contractually require any successor to treat your PII in accordance with the promises made in this Statement, even after the transfer. But any information you provide after the transfer will likely be subject to a new privacy statement, and you should review that statement.
Third-Party Payment Processor. We use a third-party intermediary to manage payment processing when you submit payment to apply to an educational institution through www.IHaveaPlanIowa.org. This intermediary is not permitted to store, retain, or use your financial information or other PII, except for the sole purpose of processing payments you initiate.
Third-Party Service Providers. We may share Automatically-Collected Information with our third-party service providers who assist us by performing services related to our operation of www.IHaveaPlanIowa.org (such as hosting, data storage, and security). Such third-party service providers are not authorized to use your information in any way other than as described here and are required to keep the information confidential.
Third-Party Analytics Services. We may use third-party analytics services to assist us in better understanding our www.IHaveaPlanIowa.org users. For example, we use these services to track and analyze certain Automatically-Collected Information, such as feature usage. We only ever provide these service providers with (or allow these service provides to collect on our behalf) Automatically-Collected Information. We use the information collected from these service provides to make www.IHaveaPlanIowa.org better and easier to use. The information we receive from these third parties may be re-associated with your PII after we receive it back from these third parties. These third parties are not authorized to use the information in any other way and are required to keep it the information confidential.
SECURITY MEASURES TO PROTECT INFORMATION; DISCLAIMER
XAP uses industry standard physical, electronic, and procedural security measures to protect against the loss, misuse, and unauthorized access, disclosure, alteration, and destruction of PII and Automatically-Collected Information we collect and store. For example, www.IHaveaPlanIowa.org encrypts the PII you enter when it is in route from your browser to the www.IHaveaPlanIowa.org web servers, and again when your PII is in route from the web servers to the back-end database servers using TLS 1.2. This practice helps prevent unauthorized third parties from intercepting and gaining access to your PII during transmission over the Internet. www.IHaveaPlanIowa.org is WC3 compliant and performs properly on all major operating system platforms as well as all major modern internet browsers specifically including, but not limited to, Windows, Macintosh, Linux, iOS, Chrome, Safari, Firefox, Edge, Internet Explorer, and the build-in Internet browsers for iOS and Android.
PII residing on the www.IHaveaPlanIowa.org server is password protected, and account access is provided only to the account holder who created the password, anyone to whom that account holder entrusted the password, designated school administrators and staff, and those employees of XAP who require such access to administer and maintain the www.IHaveaPlanIowa.org system or to provide requested customer support to users of www.IHaveaPlanIowa.org. Each XAP employee who has access to the PII residing on the www.IHaveaPlanIowa.org server has agreed in writing to respect the privacy of all such PII. XAP trains employees to protect customer information and only authorize access for employees who XAP believes have a business need for that information. XAP holds employees accountable to a Code of Conduct and Ethics to protect user information.
The safety and security of your PII also depends on you. You should not send us sensitive PII via email, as this is not secure. You are also responsible for keeping your account username and password confidential. Please notify us if you become aware that your PII is lost, stolen, or used without permission; we may disable access to your account in order to prevent an unauthorized third party from accessing your account.
While we take industry-standard security measures to protect the privacy of your PII, we cannot guarantee that your PII will never be compromised. No Internet or wireless network transmission is ever 100% secure, and no security system can prevent all security breaches. We do not and cannot guarantee that there will be no unintended disclosures of your PII or that unauthorized third parties will not defeat our security measures or use nonpublic information for improper purposes.
We use third-party services provided by Google Analytics to track and analyze your www.IHaveaPlanIowa.org activity. In order to gather this Automatically-Collected Information, we use a Google Analytics cookie on www.IHaveaPlanIowa.org. If you don't want your Automatically-Collected Information used by Google Analytics, Google recommends installing the Google Analytics Opt-out Browser Ad-on, located here: https://tools.google.com/dlpage/gaoptout/
We also have third-party widgets on www.IHaveaPlanIowa.org, such as widgets provided by YouTube, PollDaddy and Screencast. When you use these third-party widgets by using features of our site, the widgets may place cookies associated with these widgets on your computer or other operating device.
Don't want cookies?
MODIFYING YOUR INFORMATION
You may update on www.IHaveaPlanIowa.org any PII you previously provided. To modify PII: (i) Sign in to www.IHaveaPlanIowa.org, (ii) access either your portfolio or an application containing the information you want to change, (iii) modify that information using standard word-processing techniques, and (iv) save the change. If you want to remove PII that is in a required field (and not replace it with other data), you will need to contact XAP at 1-800-281-1168 and request that your account be inactivated.
Please recognize that if you delete information, it will no longer be available on www.IHaveaPlanIowa.org. Similarly, when accessed over www.IHaveaPlanIowa.org, PII that has been updated or otherwise modified will appear in its then-current form, rather than in the form in which it may have been submitted at some earlier time. Please note that if you modify or delete any PII, we may retain the earlier-submitted PII, as described in the section below entitled "Retention and Storage."
RETENTION AND STORAGE
We retain all PII and Automatically-Collected Information in our databases to fulfill the purpose for which the information was collected. Because www.IHaveaPlanIowa.org is intended to help you set goals and plan for your future education and career path, the PII you put into www.IHaveaPlanIowa.org will be retained until you ask us to remove your information. Note that even after you ask that we remove your information from our databases, it may be impossible to remove some information, such as information tracked in our web server log files and information that may reside in backup files. We may also retain Automatically-Collected Information even after you request that we remove your information from our databases, for use in the aggregate and to analyze and improve www.IHaveaPlanIowa.org. Further, even after you request that we remove your information from our databases, we may retain PII and Automatically-Collected Information to comply with applicable laws, rules, regulations, or guidelines; to prevent fraudulent activity; to protect ourselves against liability; to resolve disputes; and to enforce our contractual or other rights. Notwithstanding the foregoing, XAP will not retain PII for longer than is allowed under applicable law.
AMENDING THIS PRIVACY STATEMENT
XAP may amend this Privacy Statement from time to time. We will post any new Statement here, and you should review this Statement regularly to make sure you are aware of its terms. You can determine if this Statement has been revised since your last visit to www.IHaveaPlanIowa.org by referring to the "last updated" date at the top of this Statement. If XAP makes any substantial changes to this Privacy Statement, XAP may also notify you (i) by posting a message on the www.IHaveaPlanIowa.org homepage for at least thirty (30) days; or (ii) by providing direct notice to you via your contact information or by requiring that you agree to the revised Statement to next time you log into your account on www.IHaveaPlanIowa.org. Once posted to www.IHaveaPlanIowa.org, the new Privacy Statement will apply to all data previously submitted and subsequently submitted to www.IHaveaPlanIowa.org, unless such use is prohibited by law.
If any part of this Statement is determined to be invalid, illegal, or unenforceable under applicable law, then the invalid, illegal, or unenforceable provision will be deemed to be superseded by a valid, legal, and enforceable provision that most closely matches the intent of the original provision, and the remainder of this Statement will continue in full force and effect.
If you have any questions about this Privacy Statement and the privacy practices on this site, you may contact us at firstname.lastname@example.org.