Effective Date: January 7, 2022
Please note that FACTS Management (“FACTS”, “we”, “our”, or “us”) offers Services related to education, including tuition management, payment administration and processing, financial needs assessment, school management, online application, and online enrollment. To provide these Services, we must store and maintain information about educational institutions (or other entities) we serve, along with personal information regarding administrators, staff members, parents, and students. Access to the data will be restricted to authorized associates and will be used only for the purpose of providing Services to you or the Institution.
We are committed to providing you a useful and enjoyable online experience. This Policy explains our collection and use practices regarding consumer information, including how and what we share with our related companies and with unrelated entities. Protecting your privacy is important to FACTS Management and our employees. We want you to understand what information we collect and how we use it.
This Policy is subject to change from time to time, so be sure to check back occasionally to ensure you have read the most current version. It is effective as of the date listed above and applies to our Services that link to this policy. Even if you read and/or agreed to a prior privacy statement, you need to review this updated version. We reserve the right at any time, and in our sole discretion, to change or modify this Policy. If any such changes or modifications are made, we will update the “Effective Date” appearing at the top of this web page. Such changes or modifications shall be effective immediately upon posting to the Website, and supersede any prior versions of this Policy.
This Policy governs the privacy policies of this Website or the FACTS Management mobile device application(s) only.
Information We Collect
Why We Collect Information
We collect information so we can identify you as our customer, to establish, manage and protect your accounts, to complete your transactions, to create and offer you products and services you might be interested in, to personalize and improve upon your experience with us and to comply with various legal and regulatory requirements.
We may collect information from your visit or as part of the registration and administration of your account, in order to personalize and improve upon your experience with us, such as, without limitation, age and individual preferences (“Non-Identifying Information”).
The Services may place “Cookies” on a visitor’s device. Cookies are small text files. Our Cookies save anonymized data about individual visitors, allowing our Services to recognize information about a visitor and help deliver personalized content and other services and functions. Cookies make your Internet experience quicker and more convenient. The Services use both session cookies, which terminate when a user closes his or her browser, and persistent cookies, which remain on the user’s device until they expire or are manually deleted. The Services also contain coding from our business and technology partners which generates third party cookies. Third party cookies allow our business and technology partners to store non-Identifying Information they can access when you visit this or other websites. Accepting a cookie from a web or device browser may give us access to Personally Identifiable Information for analytics purposes.
Most website and mobile device browsers allow you to control cookies, including whether or not to accept them and provide the ability to remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser. Blocking cookies may result in a lower quality experience for you while you are using our Services.
Device and Connection Information
When you use our Services, we will identify the Internet Protocol (IP) address of your computer or handheld device. The IP address does not identify you personally, but it lets us identify the device you are using. We store IP addresses in case we need to track a connection for security purposes. We may also collect other device-specific information about the device you are using, including what type of device it is and hardware model, what operating system you are using, device settings, unique device identifies, geo-location data, and crash data. Whether we collect some or all of this information often depends on what type of device you are using and its settings. Check the policies of your device manufacturer or software provider to learn more about what information your device makes available to us.
Web Beacons (1×1 Pixels or GIFS)
Our Services may contain coding known as Web Beacons that use 1×1 pixel images to capture and transmit the online activity of users on our Services. These Web Beacons typically transmit information about form completions and other activities in order to measure advertising effectiveness or store analytics information. In addition, we may use Web Beacons in HTML-based emails. This allows us to evaluate the effectiveness of our email communications and our marketing campaigns by showing how many emails recipients have opened.
Like most websites, our servers utilize log files. Log files store information including internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, platform type, date/time stamp, and number of clicks. Log files are used to analyze trends, administer the Website, track Users’ movement in the aggregate, and gather broad demographic information for aggregate use. We use log file information at times to help identify you as you browse and to gather broad technical and demographic information on who uses our website.
Google Analytics Feature
Other Analytics Tools
In addition to or in lieu of Google Analytics, we may use other similar web analytics tools to collect information about our Website. Regardless of the tool selected, we use this information only to improve the Website. Any analytics tools we use collect only the IP address assigned to you on the date you visit the Website, your name and email address. We only use analytics tools that are GDPR-compliant and that meet our auditing and privacy standards.
If you choose to link your Google Drive account to a FACTS Management product for easy access to your files, FACTS Management will use Google’s OAuth protocols to establish that connection. FACTS Management will not use this information in any manner inconsistent with this policy or for any purpose other than allowing you access to your Google Drive. FACTS Management will not read, edit, delete, or copy files or information without your permission or as instructed by you. You may disconnect FACTS Management’s site or application at any time by removing access through your Google account.
Do Not Track Signals
Do Not Track is a feature in your web browser, which enables you to opt-out of the third party tracking of your online activities over time and across third party websites. We do not track users across third party websites to provide targeted advertising, and therefore, do not process or comply with any web browser’s “do not track” signal or other similar mechanism that indicates a request to disable online tracking of individual users who visit this Website or use our Services. Third parties cannot collect any Personally Identifiable Information from this Website unless you provide it to them directly.
Personally Identifying Information
We may collect Nonpublic Personal Information about you from the following sources:
- Information from this Website or paper forms
- Information about your transactions with us or others
- Information we receive from third parties, such as your academic institution
“Nonpublic Personal Information” is nonpublic, personally identifiable financial information about you that we obtain in connection with providing a financial product or service to you. For example, Nonpublic Personal Information includes information regarding your account balance, payment history, and overdraft history, if applicable.
We may collect Personally Identifiable Information about you as well, including:
- Your first and last name
- Your home address
- Your home or work telephone number
- Your birth date
- Your email address
- Credit Card Number
- Bank Account Number
- Bank Routing Number
- Username and Password
- Social Security Number
- Driver’s License Number
- Student ID
- Medical Information
“Personally Identifiable Information” is individually identifiable information about an individual consumer collected by us and maintained in an accessible form.
How We Use Your Information
Uses of Information
Certain Non-Identifying Information would be considered a part of your Personally Identifiable Information if it were combined with other identifiers (for example, combining your zip code with your street address) in a way that enables you to be identified. But the same pieces of information are considered Non-Identifying Information when they are taken alone or combined only with other non-identifying information (for example, your viewing preferences). We may combine your Personally Identifiable Information with Non-Identifying Information and aggregate it with information collected from other Users to attempt to provide you with a better experience, to improve the quality and value of the Services and to analyze and understand how our Website and Services are used. We may also use the combined information without aggregating it to serve you specifically, for instance to deliver a product to you according to your preferences or restrictions.
We may use your Personally Identifiable Information to send you information about other products and services and product enhancements that may be of interest to you. We may also share your information with our affiliates to market financial products and services to you. You will have the opportunity to tell us you do not want to receive future messages with each message you receive. You may also opt out of receiving marketing materials by visiting the FACTS unsubscribe page. If you wish to change any of your personal information, you may change it by logging into your account; by contacting Customer Service, either through email, mail, or telephone; or by contacting your Educational Institution. Additionally, you have the right to have your information deleted if the information is no longer needed to provide the services you’ve requested. To submit a request to delete all personal information please email [email protected]
What We Share
We do not sell personal information to third parties. All personal information collected is used by us or our affiliates to perform services, send you information about new products and services, comply with laws or carry out internal functions.
FACTS Parent Alert: Schools using FACTS Parent Alert to send notifications to families in certain situations, including emergency situations. At the beginning of the school year, a test alert is sent out to parents or student contacts. If you did not receive the alert, please notify your school office to double check your contact information. Sometimes it is appropriate to text START to 22-383 to enable your alerts. If you are an emergency or pick up contact and you do not wish to receive school alerts you can opt out by texting STOP to 22-383.
We may share your information with companies that are affiliated with us, such as our direct or indirect subsidiaries or parent or sister companies. As we continue to develop our business, we may buy or sell companies, subsidiaries, or business units. Your Personally Identifiable Information may be included as an asset in connection with mergers, acquisitions, reorganizations, or sales of assets including in the event of bankruptcy.
Sometimes the law or other circumstances also require that we disclose Nonpublic Personal Information and/or Personally Identifiable Information about you to nonaffiliated third parties. Some examples are: when you ask or permit us to do so; in response to subpoenas or court orders; when we suspect fraud or criminal activity; to protect our property and rights or those of a third party; to protect the safety of the public or any person; or to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, unethical, or legally actionable activity.
VERMONT RESIDENTS: We will not disclose nonpublic personal financial information about you other than as permitted by law unless you authorize us to make that disclosure. Your authorization must be in writing or, if you agree, in electronic form. If you wish to authorize us to disclose your nonpublic personal financial information to nonaffiliated third parties, you may notify us at the address found under the “How to Contact Us” section below.
If you become an inactive User, we will continue to adhere to the privacy policies and practices described in this Policy.
Our Security Procedures
We are committed to providing you a useful and enjoyable online experience. We implement reasonable and appropriate physical, procedural, and electronic safeguards to protect your information.
To access information and send e-mail via the Website, you will need a browser that supports the use of Transport Layer Security protocols. This encryption technology helps ensure the authenticity of your online sessions and secures data being transmitted over the public Internet.
We take careful steps to safeguard customer information. We restrict access to your personal and account information to those employees who need to know that information to provide Services to you, and we regularly train our employees on privacy, information security, and their obligation to protect your information. We maintain reasonable and appropriate physical, electronic, and procedural safeguards to guard your Nonpublic Personal Information and Personally Identifiable Information and we regularly test those safeguards to maintain the appropriate levels of protection.
You can help safeguard your Nonpublic Personal Information and Personally Identifiable Information by taking a few simple precautions. Protect your account numbers, passwords, and customer access numbers. Never disclose confidential information to unknown callers. You should always use a secure browser and current virus detection software, and never open email from unknown sources.
The Website is not directed to children under 13. We do not knowingly collect, maintain, or use personally identifiable information from children under age 13. If a parent or guardian becomes aware that his or her child has provided us Personally Identifiable Information without their consent, he or she should contact us using the information in the “How to Contact Us” section, below. If we confirm collected such information, we will take all reasonable measures to delete that information from our system as soon as possible. For users of our learning management system and related products, we may collect and store certain information as required to provide learning management tools to schools, teachers, and students who use such tools.
Links to Other Websites and Services
We are not responsible for the collection and use of information by companies or individuals unaffiliated with us whose websites may contain links to the Website, including vendors where you may shop. Please remember that when you use a link to go from our Website to another website, our Policy does not apply to third party websites or services. Your browsing and interaction on any third party website or service are subject to that third party’s own rules and policies. Please note that when you shop with a vendor who is linked to the Website, even though you may have started your visit with us, and even though our pages may still appear, your transactions are completed with a separate organization, not with us. In addition, you agree that we are not responsible and we do not have control over any third parties that you authorize to access your user content. If you are using a third party website or service, and you allow such a third party access to your user content, you do so at your own risk. This Policy does not apply to information we collect by other means (including offline) or from other sources other than through the Website and applications.
California Resident Disclosure
The California Consumer Protection Act provides California Residents with specific rights regarding their personal information. This section describes how we treat your personal information in light of the CCPA. As stated above we do not disclose nonpublic personal information about you to nonaffiliated third parties. We do not sell your personal information, and only use your personal information for the following reasons:
- Provide consumer services.
- Comply with the law.
- Carry out internal functions.
Right of Access, Correction, Deletion
Consumers have the right to access, correct, and have their information deleted if the information is no longer needed to provide the services they’ve requested. To submit a request to exercise any of these rights please email [email protected].
Privacy Information for the People’s Republic of China Residents
Striving to provide superior customer service, FACTS Management (“FACTS”, “we”, “our”, or “us”) places great emphasis on its customers and their privacy rights. In doing so, FACTS Management will comply with The People’s Republic of China’s Personal Information Protection Law (PIPL).
This notice applies to a person or Data Subject, meaning a natural person, not a corporation, partnership, or other legal entity that FACTS Management either handles your information from within the borders of the PRC, or you are physically present within the borders of the PRC and FACTS Management processes your information outside of the borders of the PRC to provide you with goods or services or to analyze or assess your activities.
How We Use Your Information
Categories of Information
By providing our services, we may from time to time collect, store, use or process your personal information for legitimate business purposes, such as improving our products and services. FACTS Management collects the following categories of personal information:
– Your first and last name
– Your home address
– Your home or work telephone number
– Your birth date
– Your email address
“Personal information” is defined as information related to identified or identifiable natural persons recorded by electronic or other means, excluding the information processed anonymously.
“Sensitive Personal Information” is defined as personal information that, once leaked, or illegally used, may easily infringe the dignity of a natural person or cause harm to personal safety and property security, such as biometric identification information, religious beliefs, specifically-designated status, medical health information, financial accounts, information on individuals’ whereabouts, as well as personal information of minors under the age of 14.
Uses of Information
With your consent, we may use your personal information and aggregate it with information collected from other users to attempt to provide you with a better experience, to improve the quality and value of the services and to analyze and understand how our website and services are used. We may also use the combined information without aggregating it to serve you specifically, for instance to deliver a product to you according to your preferences or restrictions.
If you supply us with your e-mail address, we may let you know by e-mail about other products and services and product enhancements that may be of interest to you. You will have the opportunity to tell us you do not want to receive future messages with each message you receive. If you e-mail a question
or comment to us, we will use your e-mail address to reply to you and we will temporarily store your e-mail address, your message, and our reply for quality assurance or to satisfy applicable laws and regulations. When we collect your e-mail address this way, we will not use it for marketing our products and services unless you have given us permission.
FACTS Management will only use your personal information for the purpose for which it was collected and will only use the information when necessary in accordance with that purpose. FACTS Management will only use your personal information on the following legal bases:
– With your consent.
– Where it is necessary to conclude or perform a contract.
– Where it is necessary to perform statutory responsibilities or statutory obligations.
If FACTS Management is required to process your Sensitive Personal Information, FACTS Management will request your separate consent unless another legal basis for processing exists.
What We Share
We do not sell personal information to third parties. All personal information collected is used by us or our affiliates to perform services, comply with laws or carry out internal functions.
We may share your information with companies that are affiliated with us, such as our direct or indirect subsidiaries or parent or sister companies. As we continue to develop our business, we may buy or sell companies, subsidiaries, or business units. Your Personal Information may be included as an asset in connection with mergers, acquisitions, reorganizations, or sales of assets including in the event of bankruptcy.
Sometimes the law or other circumstances also require that we disclose Personal Information about you to nonaffiliated third parties. Some examples are: when you ask or permit us to do so; in response to subpoenas or court orders; when we suspect fraud or criminal activity; to protect our property and rights or those of a third party; to protect the safety of the public or any person; or to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, unethical, or legally actionable activity.
How to Exercise Your Rights
To exercise your rights with FACTS Management, except the right to file a lawsuit in a court of competent jurisdiction, you may submit your request to the following to Customer Service, either through email, mail, or telephone; or by contacting your Educational Institution. You may request access to or deletion of your information by contacting [email protected].
121 South 13th Street, Suite 301
Lincoln, NE 68508
You will be asked to identify yourself and authenticate your identity, what information you are concerned about, and what right(s) you are exercising.
FACTS Management will respond to your request in accordance with applicable laws and regulations and existing policies and procedures.
Although your data is generally stored within the United States, an international data transfer may occur if third party, cloud-based storage companies that FACTS Management employs use servers located outside the United States. FACTS Management uses appropriate technical and organizational security measures including encryption of personal data and follows various industry standards and best practices to protect your personal data. Additionally, FACTS Management requires its vendors and processors to abide by PIPL and to apply adequate security and technical safeguards.
How to Contact Us
If you have any questions about this Policy, please contact us by email or regular mail at the following address:
121 South 13th Street, Suite 301
Lincoln, NE 68508
Email: [email protected]
Effective Date: May 25, 2018
PRIVACY NOTICE FOR EUROPEAN UNION RESIDENTS:
Striving to provide superior customer service, FACTS Management (“FACTS”, “we”, “our”, or “us”) places great emphasis on its customers and their privacy rights. In doing so, FACTS Management will comply with European Union Privacy Directives, most notably the EU General Data Protection Regulation. By providing our services, we may from time to time collect, store, use or process your personal data for legitimate business purposes, such as improving our products and services. FACTS Management’s processing of your data is necessary for compliance with its contractual and legal obligations. Personal data means any identifier information, such as your name, social security number, identification number, location data, or other online identifiers and factors.
Although your data is generally stored within the United States, an international data transfer may occur if third party, cloud-based storage companies that FACTS Management employs use servers located outside the United States. FACTS Management uses appropriate technical and organizational security measures including encryption of personal data and follows various industry standards and best practices to protect your personal data. Additionally, FACTS Management requires its vendors and processors to abide by the European Union General Data Protection Regulation and to apply adequate security and technical safeguards. We will not transfer your data to or store your data in countries that have not been awarded an adequacy decision by the European Commission.
For general processing purposes, FACTS Management will store your personal data for a period of seven years. However, FACTS Management may retain such information for shorter or longer periods where legally required to do so based on industry rules, contractual requirements, or other legal obligations.
You have the right to withdraw consent for processing at any time. Further, you have the right to request access to and rectification, restriction or erasure of your personal data. FACTS Management will afford you these rights, but it may not be able to do so where the processing is based on its contractual obligations, based on other legitimate interests, or carried out in the public interest. Along with these rights, if you believe that your data has been mishandled in violation of a privacy directive, you have the right to lodge a complaint with the relevant supervisory authority. If you have questions or concerns about our data processing practices, please address such inquiries to our Data Protection Officer.
Contact Details for Privacy and Data-related Inquiries
Contact Your Educational Institution
Chief Compliance Officer