This Privacy Policy governs the manner in which Strada Education Foundation, Inc., a Delaware nonprofit corporation (“Strada,” “we,” “us,” “our”) collects, uses, and discloses information when you use our website at stradaeducation.org (the “Site”), including all content, information, and functionality available through the Site, and through the use of any other Strada products, services, or offerings, including from the Center for Consumer Insights and Institute for the Future of Work (hereinafter collectively referred to as the “Services”).  Unless stated specifically in this Privacy Policy, this Privacy Policy does not apply to Strada’s affiliates and subsidiaries, which are identified on the Site, and does not apply to The College Fair.  Please review the individual privacy policies of those affiliates, subsidiaries and related entities to identify their specific privacy practices.

Your acceptance of these terms

By using our Services, including the Site, you signify your acceptance of the terms of this Privacy Policy as they may be amended from time to time. This Privacy Policy is incorporated into our Terms of Use, which govern your use of the Services in general and of which this Privacy Policy is a part. This Privacy Policy applies to all users of the Services. By providing information to Strada, you understand and consent to the collection, maintenance, processing, and transfer of such information in and to the United States and other countries and territories, in accordance with United States law. You acknowledge and agree that it is your responsibility to review this Privacy Policy periodically and become aware of modifications.

Collection, Use & Sharing of Information

In order to provide our Services and to fulfill other purposes as outlined below, we need to collect and process some information. “Personal Information” is information that can be used to identify you, and we have provided specific examples of the Personal Information we may have collected about you below.  Personal Information does not include de-identified or aggregated information, which is information in which identifiable information is removed and that cannot reasonably be used to identify an individual.  We may use de-identified or aggregated information for any purpose, and we may share de-identified or aggregated demographic information not linked to any Personal Information with our business partners, affiliates, and advertisers.

Categories of Personal Information We Collect:

• Identifiers, such as name, mailing address, phone number, email address, and internet protocol address.
• Demographic information, such as race, national origin, citizenship, marital status, physical or mental disability, or sex (including gender or gender identity).
• Geolocation data is gathered when users interact with the Site.
• Professional or employment information may be gathered from use of our Services.
• Audio, textual, and video content may be gathered from using or participating in our Services, including webinars, panels and story sharing.
• Education information, such as information subject to the Family Educational Rights and Privacy Act, may be gathered from use of our Services.
• Profile information, such as inferences drawn from Personal Information reflecting a user’s preferences, characteristics, behavior, attitudes, intelligence, abilities, and aptitudes gathered during use of our Services.
• Internet or other similar network activity, including browsing history, search history, links, and information regarding your interaction with an internet website, application, or advertisement.

Categories of Sources for Personal Information We Have Collected:

• We have received Personal Information from users of the Services through their direct interactions with our Services, including when corresponding with us through our Site or in conjunction with a Service.
• We may receive Personal Information from the affiliated companies in Strada’s network, which are listed on our Site.
• We have collected Personal Information, such as technical data, usage data, and internet and other similar network activity, through automated technologies and users’ interactions with our Services and from service providers.
• We have collected Personal Information from educational institutions and market research and survey companies.

Our Business or Commercial Purposes for Collecting Personal Information and Categories of Third Parties to Whom the Information Was Disclosed.

• Identifiers are collected to market to individuals, provide users with our Services, to improve the quality, safety, and security of the Services, to customize and improve our Services, to administer your account and process your requests related to the Services, and to respond to direct inquiries. We may share identifiers with affiliated companies in Strada’s network, our service providers that assist us to provide users with the Services and with parties to which you have authorized us to share your Personal Information.
• Demographic information is collected to market to individuals, provide users with our Services, to improve the quality, safety, and security of the Services, to customize and improve our Services, to administer your account and process your requests related to the Services, and to respond to direct inquiries. We may share demographic information with affiliated companies in Strada’s network, our service providers that assist us to provide users with the Services and with parties to which you have authorized us to share your Personal Information.
• Geolocation data is collected to market to individuals, to provide users with our Services, to improve the quality, safety, and security of the Services, to customize and improve our Services, and to detect security incidents and protect against malicious, deceptive, fraudulent, or illegal activity. We may share geolocation data with affiliated companies in Strada’s network, our service providers that assist us to provide users with the Services and to provide fraud protection, and with parties to which you have authorized us to share your Personal Information.  We may share geolocation data with advertising service providers to serve relevant advertisements and obtain analytics information concerning our advertising.
• Professional or employment information is collected to market to individuals, provide users with our Services, to improve the quality, safety, and security of the Services, to customize and improve our Services, to administer your account and process your requests related to the Services, and to respond to direct inquiries. We may share professional or employment information with affiliated companies in Strada’s network, our service providers that assist us to provide users with the Services, and with parties to which you have authorized us to share your Personal Information.
• Audio, textual, and video content is collected to market to individuals, provide users with our Services, to improve the quality, safety, and security of the Services, and to customize and improve our Services. We may share audio, textual, and video content with affiliated companies in Strada’s network, our service providers that assist us to provide users with the Services and with parties to which you have authorized us to share your Personal Information.  When users submit audio, textual, or video content in connection with any of our Services, such as webinars, panels and story sharing, some identifying information also may be disclosed publicly or to other partners, such as educational institutions.
• Education information is collected to market to individuals and to improve the quality, safety, and security of the Services. We may share education information with affiliated companies in Strada’s network, our service providers that assist us to provide users with the Services, and with parties to which you have authorized us to share your Personal Information.
• Profile information is collected to market to individuals and to improve the quality, safety, and security of the Services. We may share profile information with affiliated companies in Strada’s network, our service providers that assist us to provide users with the Services, and with parties to which you have authorized us to share your Personal Information.
• Internet or other similar network activity is collected to market to individuals, to provide users with our Services, to improve the quality, safety, and security of the Services, to customize and improve our Services, and to detect security incidents and protect against malicious, deceptive, fraudulent, or illegal activity. We may share internet or other similar network activity with affiliated companies in Strada’s network, our service providers that assist us to provide users with the Services and to provide fraud protection, and with parties to which you have authorized us to share your Personal Information.  We may share internet or other similar network activity with advertising service providers to serve relevant advertisements and obtain analytics information concerning our advertising.

In addition, where consistent with applicable laws and regulations, we may disclose Personal Information in all categories above:

• to prepare, negotiate, or perform a contract with you;
• to respond to subpoenas, court orders, or other legal process or otherwise as required by law or the competent government or judicial authorities;
• to establish or preserve a legal claim or defense;
• as part of corporate restructuring, sale of assets, merger, or divestiture; or
• to prevent fraud or other illegal activities, such as willful attacks on our information technology systems.

Sale of Personal Information

We do not sell your Personal Information to others, as the term Sell is defined under the California Consumer Privacy Act.  We also do not disclose any Personal Information to third parties for their direct marketing purposes.

Choices and Access

Your choices regarding our use and disclosure of Personal Information

We give you certain choices regarding our use and disclosure of your Personal Information for promotional purposes.  You may opt out from receiving electronic communications from us by contacting us at privacy@stradaeducation.org.  If you no longer want to receive promotional-related emails from us, you may opt out according to instructions in such communications.  Please note that if you opt out of receiving marketing-related messages, we may still send you important administrative messages.

Access, change or deletion of Personal Information

To the extent applicable law provides you with the right to review, correct, update, or delete Personal Information that you previously have provided to us, please contact us at privacy@stradaeducation.org to do so.  We will respond to your request consistent with applicable law.

Data Integrity and Retention

The security of your Personal Information is important to us.  We employ reasonable organizational, technical, and physical safeguards designed to protect the Personal Information we collect.  However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your Personal Information.

We will only retain your information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for your information, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of your information, the purposes for which we process your information and whether we can achieve those purposes through other means, and the applicable legal requirements.

Data Relating to Children Under 13

Our Services are not directed at, and we do not knowingly collect Personal Information from, anyone under the age of 13 (or such other age as may be restricted under local law). If we are made aware that we have received such information, or any information in violation of our policy, we will use reasonable efforts to locate and remove that information from our records.  If you wish to have your child’s information removed, please contact us using the information below.

Changes to this Privacy Policy

Please note that this Privacy Policy may change from time to time. We reserve the right, at our discretion, to change, modify, add, or remove portions from this Privacy Policy at any time.  When we do, we will post a notification on the main page of our Site, and revise the updated date at the bottom of this page. We encourage users to frequently check this page for any changes to our Privacy Policy.

Contacting Us

If you have any questions about this Privacy Policy or any of our Services, including the Site, please contact us at:

Strada Education Foundation
Attn:  Legal Department
10 West Market Street, Suite 1100
Indianapolis, IN  46204
privacy@stradaeducation.org
October 19, 2020