Privacy Addendum for Virginia Residents

Effective Date: January 1, 2023
Last Revised on: December 12, 2022

This Privacy Addendum for Virginia Residents ("Disclosure") supplements the information contained in Nitro College's Privacy Policy and applies solely to individual residents of the State of Virginia ("consumers" or "you").

Please note that this Disclosure describes how we collect, use, disclose or otherwise process Personal Data of Virginia residents, either online or offline, through our websites (our “Sites”), within the scope, of the Virginia Consumer Data Protection Act (“VCDPA”) Va. Code §§ 59.1-571 et seq. "Personal Data" means any information that is linked or reasonably linkable to an identified or identifiable natural person.

For the purposes of this Disclosure, Personal Data does not include:

  • Publicly available Personal Data from government records;
  • Deidentified or aggregated Personal Data;
  • Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA); and
  • Personal Data covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA), and the Driver's Privacy Protection Act of 1994.

Any terms defined in the VCDPA have the same meaning when used in this Disclosure.

Personal Data Collected by Us

We may have collected the following categories of Personal Data from consumers:

*This category of Personal Data is considered Sensitive Personal Data under VCDPA.

Sources of Personal Data Collected by Us

We may have collected Personal Data listed above from the following sources:

** Parties with whom we have a contractual relationship and a lawful basis for collecting the Personal Data (each an “Authorized Third Party” or collectively, “Authorized Third Parties”).

Use and Disclosure of Personal Data

See Section 3 (HOW DO WE USE YOUR PERSONAL INFORMATION?) and Section 4 (HOW DO WE DISCLOSE YOUR PERSONAL INFORMATION) in the Nitro College Privacy Policy.

Disclosure of Personal Data

We may disclose your Personal Data for our internal business operations (“Business Purposes”) to the following Authorized Third Parties:

Your Rights and Choices

If you are a Virginia resident, the VCDPA provides you with certain rights with respect to your Personal Data. This section describes your VCDPA rights and explains how to exercise those rights, subject to VCDPA exceptions.

If you would like to exercise your privacy rights, you do not need to create an account. However, we may ask you to provide additional Personal Data so that we can properly identify you in our dataset to track compliance with request.  We will only use Personal Data provided in a request to review and comply with the request.  If you chose not to provide this information, we may only be able to process your request to the extent we are able to identify you in our data systems.

If you have provided us with information to apply for or obtain a Nitro College service, please refer to the Nitro College Privacy Policy to learn about our privacy practices with respect to this information and how you may be able to opt-out of certain types of sharing with Authorized Third Parties.

The Right to Knowledge / Specific Information
You have the right to request the following information relating to the Personal Data we may have collected and disclosed:

  • The categories of Personal Data we have collected about you;
  • The categories of sources of the Personal Data;
  • The purposes for collecting the Personal Data;
  • The categories of third parties with whom we share the Personal Data; and
  • If we sold or disclosed your Personal Data for a business purpose, two separate lists disclosing:
    • the categories of Personal Data that was disclosed for a business purpose and the categories of recipients of such information; and
    • the categories of Personal Data that we sold to third parties and the categories of recipients of such information.

The Right to Access / Data Portability
You have the right to access and obtain a copy of the specific pieces of Personal Data we have collected about you, upon verification of your identity.

The Right to Correct
You have the right to request that Nitro College correct the inaccurate Personal Data that we collected and maintain about you.

The Right to Request Deletion
You have the right to request that Nitro College delete the Personal Data that we collected from you, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Data from our records, unless an exception applies.

To Submit a Request to Exercise Your Right to Knowledge, Access (Portability), Correct and Deletion
Call us at 1-833-618-0661 Monday-Friday 8am-8pm EST or complete the Consumer Rights Request Form.

We will need to verify your identity before processing your request, and this verification may require us to obtain additional Personal Data from you. We will only use Personal Data provided in a consumer request to review and comply with the request. In certain circumstances, we may decline a request to exercise the rights described above.

If you wish to submit a verifiable consumer request on behalf of your minor child, the verifiable consumer request must:

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

Response Timing and Format
We will endeavor to respond to a verifiable consumer request within forty-five (45) days of receipt. If we are unable to process your request in such time, we will inform you of the delay in writing.

We will deliver our written response by mail or electronically, depending on your preference selection.

Right to Appeal
If we are unable to comply with all or a portion of your request, we will explain the reasons we cannot comply.  You may appeal our decision by resubmitting a request and we will inform you of any action taken or not taken in response to the request and explain the reasons for our decision within 60 days of receiving the request.  To Submit a complaint to the VA Attorney General, click here.

Information provided in response to a consumer request will be provided free of charge, up to twice annually per consumer.  We reserve the right to charge a fee to process or respond to your verifiable consumer request if we determine that such request 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.

The Right to Opt-Out of Targeted Advertising, Sale or Sharing of Personal Data 
You have the right to direct us not to process your Personal Data for the purposes of (i) targeted advertising; or (ii) sell or share Personal Data we have collected about you to and with Authorized Third Parties. You have the right to limit the use and disclosure of Sensitive Personal Data we have collected about you.

To opt out of the potential sale or sharing of your Personal Data or to limit the use and disclosure of your Sensitive Personal Data, 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”

Minor children under age 16.
We do not sell the Personal Data of consumers we know to be less than 16 years of age, unless we receive affirmative authorization (the “right to opt in”) from a consumer who is between 13 and 16 years of age. Nitro College does not knowingly solicit, sell, or collect any Personal Data from anyone under the age of 13. If we learn that we have inadvertently collected Personal Data from a child under age 13, we will delete the Personal Data promptly. Consumers who opt-in to Personal Data sales may opt-out of future sales at any time. If you believe that we may have any Personal Data from a child under 13, please call us at 1-833-618-0661 to opt-out of future sales or to inform us if your minor-child, is under the age of 13.

The Right to Non-Discrimination
You have the right to be free from discrimination for exercising any of the rights described above.

The right to non-discrimination does not prohibit us from offering you certain financial incentives that may result in different prices, rates or quality levels of products or services. In addition, please note that if the exercise of the rights described above limits our ability to process Personal Data (such as in the case of a deletion request), we may not be able to offer our services to you in the future.

Changes to This Disclosure

This Disclosure may be updated or amended at any time and from time to time and will reflect the date it was last updated or amended. Under certain circumstances, we may also elect to notify you of updates or amendments to this Disclosure by sending you an email. Please check this Disclosure each time you utilize the Sites to ensure you are aware of any changes in our practices. Your continued use of our Sites indicates your acceptance of and agreement with the changes to this Disclosure.

Contact Information

If you have any questions or comments in connection with this Disclosure or Nitro College’s Online Privacy Policy, please do not hesitate to contact us at: help@nitrocollege.com

Website: https://www.nitrocollege.com/legal/privacy-policy