Joint Nitro College and Scholly Privacy Policy

EFFECTIVE AS OF July 21, 2023

If you are a resident of California, Colorado, Connecticut, Utah, or Virginia, please see our U.S. State Privacy Notice for additional information about our data activities, the privacy rights available to you, and how to exercise them.

1. DESCRIPTION

At SLM NitroCollege LLC (“we” or “us”), we care about the privacy and security of your information. This Privacy Policy (this “Privacy Policy”) contains details about how we collect, use, store, disclose and protect Personal Information (as defined below) about you in relation to your use of any online service, platform, website (“Sites”), or application (“App”), commercial emails we send, and any interactive features, widgets, plug-ins, applications, content, downloads and/or other online or offline services that we own and control (including those made available through a Site and/or App), and in each case wherever this Privacy Policy is posted (collectively, the “Service”). We own and operate the Service. In the event of a conflict between any other privacy policy, statement, or notice (such as our U.S. State Privacy Notice and our GLBA Privacy Notice) and this Privacy Policy, the specialized notices will prevail.

2. SOURCES OF PERSONAL INFORMATION

In this Privacy Policy, we use the term “Personal Information” to refer to information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual (“Personal Information”).

We have access to/collect Personal Information:

  1. Directly From You.
    We may collect information directly from you in connection with an application for our scholarship sweepstakes (the “Scholarship”) offered on the Service, via the Service’s contact page, scholarship database, email, or other direct contact from you.
  2. Automatically From You or Your Device on the Service.
    As described in Section 6 below, we use cookies and other tracking technologies to collect information about you, your device, and your use of the Service.
  3. From Our Affiliates and Related Entities.
    We may receive information about you through our affiliates and related entities.
  4. From Others.
    We may receive information about you from parent/guardians submitting information on your behalf and through our business partners including Authorized Third Parties (as defined below).

3. WHAT PERSONAL INFORMATION DO WE COLLECT?

The categories of Personal Information we may collect are outlined below: 

Category of Personal Information

Identifiers and contact information (such as name, phone number, address, email address, mobile identification number, IP address, cookie ID)

Personal Records (such as name, signature, address, telephone number, education, employment, employment history, bank account number, credit card number, debit card number)

Personal Characteristics or Traits (such as age, marital status, sex, sexual orientation, veteran or military status, racial or ethnic origin, religious or philosophical beliefs, union membership or genetics data)

Transaction / Commercial Information (such as products or services used, purchased, or considered; Third-party Partners’ or Third-Party Digital Businesses’ products or services considered; and other purchasing or consuming histories or tendencies provided by business and marketing Vendors)

Internet Usage Information (such as search, browsing history, and other interactions with the Service)

Location Data (such as where you enable location-based features on your Device, or we may infer your rough location (such as zip code) part of the Services)

Audiovisual and Similar Information (such as customer service call recordings)

Professional or Employment Information (such as your title, affiliated organization, professional expertise and experience, and education related information)

Non-public Education Records (such as education institution transcripts you may upload yourself into your scholarship search account.)

Inferences from Personal Information Collected

Account information and password (we may store your account log-in in combination with a password in our systems.)

Sensitive Personal Characteristics (such as [race, ethnicity, and religious affiliation that you voluntarily provide when you utilize our education products and services)

 

4. HOW DO WE USE YOUR PERSONAL INFORMATION?

We may use your Personal Information, in support of our internal business operations (“Business Purposes”), to:

  • provide products and services requested by you;
  • provide customer support, including responding to your requests and questions and resolving any issues you may have;
  • provide you information regarding the Scholarship you requested or other scholarships you may be interested in;
  • verify the information you provide to us;
  • inform you of changes to this Privacy Policy;
  • perform research and analysis to develop and improve our services and products or develop new services and products;
  • understand and anticipate your use of or interest in our products, services, and content, and the products, services, and content of others;
  • manage our business and operations;
  • fulfill legal and regulatory requirements; and
  • prevent fraud.

We also use the Personal Information we collect for the following marketing and communications purposes (“Marketing Communications”) to:

  • communicate directly with you now or in the future, including, without limitation, by sending you emails containing content from our blog and information about promotions, and products and services that may be of interest to you, including third-party promotions, and third-party products and services; and
  • fulfill any other purpose for which you give your consent.

You may opt out of certain Marketing Communications by visiting this page or by contacting us at help@nitrocollege.com. For additional information regarding additional privacy opt-out rights you may have, please visit our GLBA Privacy Notice and the Right To Opt-Out Of Sales/Sharing/Targeted Advertising section in our U.S. State Privacy Notice.

5. TO WHOM DO WE DISCLOSE YOUR PERSONAL INFORMATION?

We may disclose your Personal Information as follows:

  • with any of our affiliated companies (i.e., companies that control, are controlled by, or are under common control with us) for Business Purposes or for cross-marketing purposes (“Affiliate Marketing Communications”);
  • we may share your Personal Information with third parties with whom we have a relationship, including third parties with whom we partner to provide contests, scholarships or co-branded services (each, an “Authorized Third Party” and collectively, “Authorized Third Parties”);
  • to fulfill your request or for the purpose explained when you provided the Personal Information; for example, if you share your name and contact information to ask a question about our services, we will use that Personal Information to respond to your inquiry;
  • to fulfill legal and regulatory requirements or comply with federal, state or local laws; civil, criminal or regulatory investigations, or disclose Personal Information to third parties if we reasonably believe that such action is necessary to (a) comply with the law and the reasonable requests of law enforcement; (b) to enforce our Terms of Use or to protect the security or integrity of our Sites, services, databases and other technology assets, and business; and/or (c) to exercise or protect the rights, property, or personal safety of us, our customers, visitors, or others;
  • to operate, maintain, and provide the features and functionality of the Service;
  • to diagnose or fix technology problems, and otherwise plan for and enhance our services;
  • with service providers for the purpose of helping us provide our products, services and customer support to you;
  • with third parties who use the information for analytical purposes;
  • posting the first and last name of the winner of our Scholarship on the Service; and
  • in the event of a transfer, sale or merger of all or part of us or our affiliates, whether through a sale, acquisition, merger, consolidation, reorganization, bankruptcy, or other corporate change involving us and/or our affiliates.

You can limit how we disclose your Personal Information by managing your communications preferences , exercising applicable privacy opt-out rights,  or by contacting us at help@nitrocollege.com.

6. ONLINE TRACKING AND ADVERTISING

We collect certain usage information through a variety of tracking technologies, including cookies, Flash objects, web beacons, file information and other similar technology (collectively, “Tracking Technologies”), and we may use third-party digital businesses including social media platforms, analytics companies, data brokers, third-party advertisers, and other tech companies that offer digital advertising services (“Third-Party Digital Businesses”), to collect information using Tracking Technologies.  Information collected using Tracking Technologies includes Personal Information described in the table above. We may share, or we may permit Third-Party Digital Businesses to collect Personal Information about your use of our Sites over time so that they may display ads that may be relevant to your interests on our Sites as well as on other websites or apps, or on other devices you may use.  We or the Third-Party Digital Businesses use this information to make the advertisements you see online more relevant to your interests.

As noted above, depending on your browser or mobile device, you may be able set your browser to refuse all cookies or notify you of Tracking Technologies by actively managing the settings on your browser or mobile device (as described below). If you delete your cookies or if you set your browser or device to decline these technologies, some services may not function properly. Our services do not currently change the way they operate upon detection of a Do Not Track or similar signal, but see “Opt-Out Preference Signals,” in the U.S. State Privacy Notice.

Clear gifs help us better manage what content is effective. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of web users. In contrast to cookies, which are stored on a user's computer hard drive, clear gifs are embedded invisibly on web pages or in emails and are about the size of the period at the end of this sentence. We use clear gifs in our HTML-based emails to let us know which emails have been opened by recipients. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns. We tie the information gathered by clear gifs in emails to our users' Personal Information.

Online Analytics

We also use various types of online analytics, including Google Analytics, a web analytics service provided by Google, Inc. (“Google”), on our Service. Google Analytics uses cookies or other tracking technologies to help us analyze how users interact with and use our services, compile reports on the related activities, and provide other services related to Site and app activity and usage. The technologies used by Google may collect information such as your IP address, time of visit, whether you are a return visitor, and any referring site or app. The information generated by Google Analytics will be transmitted to and stored by Google and will be subject to Google’s privacy policy. To learn more about Google’s partner services and to learn how to opt-out of tracking of analytics by Google, click here.

Tracking Technologies – Your Additional Choices

Browser Settings: In addition, you can exercise control over browser-based cookies by adjusting the settings on your browser, and mobile devices may offer ad and data limitation choices.  Please note that when you use cookie control tools, you will have to change your settings for each browser and device you use, and your limitation on cookies can limit the functionality of online services you use, including our services. Use the help function on your browser or click on the applicable links below to learn more:

In addition, third party tools may enable you to search for and opt-out of some of these trackers, such as the Ghostery browser plug-in available here.  

Mobile Device Settings: You can use mobile device settings to limit mobile tracking technologies and associated activities. For instance, you can adjust or reset the advertising identifiers on your mobile device in the device settings of iOS and Android devices. iOS users can visit Settings > Privacy > Advertising > Reset Advertising Identifier. Android users can visit Google settings > Ads > Reset advertising ID. These controls work much like deleting cookies in a browser—the device is harder to associate with past activity, but tracking may still occur using the new advertising identifier.

Ad Industry Tool: Some third parties that may collect Personal Information in association with your use of our online services for advertising, analytics and other purposes, and may sell that Personal Information downstream, provide you the opportunity to opt-out of their sales. Please visit https://www.privacyrights.info/ to opt-out of the sale of Personal Information by participating third parties. You must opt out on every device and browser you use in order to effectuate your “Do Not Sell” requests from these parties. However, opting out does not mean you will stop seeing ads and you may continue to still see interest-based ads. To learn more about interest-based advertising and additional opt-out choices related to it, please visit these websites (here and here).

Clearing cookies or changing settings may affect your choices described above and you may have to opt-out separately via each browser and other device you use. Cookie-enabled opt-outs signals may no longer be effective if you delete, block or clear cookies. We do not represent and are not responsible for the completeness, accuracy or effectiveness of any third-party notices, tools, or choices.

7. YOUR PRIVACY RIGHTS

If you are a resident of California, Colorado, Connecticut, Utah, or Virginia please click here to learn about your consumer privacy rights and how to exercise them. We will only use Personal Information provided in a privacy rights request to review and comply with the request.

To opt out of the Sale, Sharing, or processing of your Personal Information for Targeted Advertising or to limit the use and disclosure of your Sensitive Personal Information, visit the opt-out page by following the Link below.

“DO NOT SELL OR SHARE MY PERSONAL INFORMATION” or “LIMIT THE USE AND DISCLOSURE OF MY SENSITIVE PERSONAL INFORMATION”

8. LINKS TO AUTHORIZED THIRD PARTY WEBSITES AND SERVICES

Our Sites may permit you to access third party websites directly. It is important to remember that if you link to a third-party website from our Sites, that third-party's privacy policy and its terms and conditions of use apply to you. We encourage you to learn about each third-party's privacy policy before sharing your Personal Information with them. We are not responsible for the privacy practices or the content of the sites to which we link.

If you provide your Personal Information on a co-branded page, your Personal Information may be shared with the Authorized Third Party. Please review the Authorized Third Parties’ privacy policy and terms of use prior to providing any Personal Information. If you have any questions regarding the privacy policies of our Authorized Third Parties, please contact the Authorized Third Parties directly using the channels provided by the Authorized Third Parties.

9. MESSAGING (SMS) SERVICES

We use Message Media, a service provider, to provide a text message marketing program (the “Messaging Service”) to you. To review the terms and conditions associated with the Messaging Service, please review our SMS Terms & Conditions.

Choices and Controls

If you do not wish to receive texts (SMS) communications from us, whether on our behalf or on behalf of a third party, you can opt-out of receiving further commercial text messages by responding to any of our text messages with any of the following replies: STOP, END, CANCEL, UNSUBSCRIBE, or QUIT. For additional opt-out information, please review our Terms of Use.

Customer Care

If you are experiencing any problems with the Messaging Service, please visit https://www.nitrocollege.com/contact and submit the form with details about your problem or your request for support, or email help@nitrocollege.com.

10. CHILDREN’S PRIVACY

We do not knowingly collect or solicit any Personal Information from anyone under the age of 13 on the Sites. If we learn that we have inadvertently collected Personal Information from a child under age 13, we will delete that Personal Information promptly. If you believe that we might have any Personal Information from a child under 13, please contact us using the information listed below.

11. PROTECTION OF INFORMATION

We take a variety of physical, technical, administrative, and organizational security measures based on the sensitivity of the information we collect to protect your Personal Information against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access. Unfortunately, no online activity can be guaranteed to be 100% secure. While we strive to protect your Personal Information against unauthorized use or disclosure, we cannot ensure or warrant the security of any information you provide.

If you have reason to believe that your Personal Information is no longer secure (for example, if you feel that the security of your account has been compromised), please contact us immediately at Help@NitroCollege.com.

12. UPDATES

Our Privacy Policy may be updated or amended at any time and from time to time. The Privacy Policy will reflect the date it was last updated or amended. Please check this Privacy Policy each time you utilize our Sites to ensure you are aware of any changes in our practices. Your continued use of our Sites will indicate your acceptance of the changes to the Privacy Policy.

13. CONTACT US

If you have any questions or comments about this Privacy Policy, you are welcome to contact us at:

Customer Privacy
SLM NitroCollege LLC
P.O. Box 3010
Wilmington, DE 19804-4319
Help@NitroCollege.com