This Web Privacy Policy (“Web Privacy Policy”) is designed to inform you of our policies and procedures regarding the collection, use and disclosure of personal information we receive from users of products and services (individually and collectively, the “Services”) through our websites (“Website”), as well as from users of FACTS’ Management’s mobile device application(s) via the Services. This Web Privacy Policy applies to users when visiting the Website or receiving the Services.

We are committed to providing you a useful and enjoyable online experience. This Web Privacy 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 Web Privacy 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 Web Privacy 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 Web Privacy 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 Web Privacy Policy.

Certain of our Services are intended to be used by children and teens located in the United States, including children under the age of 13 (“children” or “students”), for educational purposes only. We presume that schools act as agents on behalf of parents and that a school’s authorization for the collection of students’ personal information is based upon the school obtaining all legally-required consents.

When a student uses or interacts with our Services, the student may provide us with personal information. In connection with administering a Student Information System (“SIS”) account, the student may provide us with:

• First and last name
• Home address
• Telephone number
• Birth date
• Email address
• Username and password
• Student Identification number

During a student’s use of our Services, we may collect certain information using various automated technologies, such as cookies, log files, web beacons, and other technologies. This information includes: IP address, identifiers associated with the Student’s devices, web browser characteristics, device characteristics, language preferences, referring/exit pages, clickstream data and dates and times of visits to our website and Services.

We may use information we collect from students for the following purposes:

• To provide our Services;
• To notify and communicate with the school or parents about a child’s use of our Services;

We may disclose information as follows:

• We may disclose information to third-party companies and individuals to facilitate our Services, provide the Services on our behalf, perform website-related services, assist us in analyzing how our website and Services are used, or perform other services.
• We may share information with companies that are affiliated with us, such as our direct or indirect subsidiaries or parent or sister companies.
• We also may share information 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.

Parents can review or have the information collected from their child deleted. Parents may also refuse to permit further collection or use of such information. To do so, please contact us at:

Attention: Customer Service

Nelnet Business Solutions, Inc. (dba FACTS Management Company)

121 South 13th Street

Lincoln, NE 68508

Telephone number: 866-441-4637

[email protected]

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 Web Privacy 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 Web Privacy Policy does not apply to information we collect by other means (including offline) or from other sources other than through the Website and applications.

Last Updated: December 18, 2023

This California Privacy Notice supplements the Web Privacy Policy (“Privacy Policy”) and applies solely to personal information collected about California consumers, such as visitors to the publicly-accessible areas of our Websites, business partners and job applicants. This California Privacy Notice does not apply to personal information collected about FACTS personnel.

This California Privacy Notice uses certain terms that have the meaning given to them in the California Consumer Privacy Act of 2018 (as amended by the California Privacy Rights Act of 2020) and its implementing regulations (collectively, the “CCPA”).

This California Privacy Notice does not apply to information we collect, process or disclose pursuant to the Gramm-Leach-Bliley Act and its implementing regulations or the California Financial Information Privacy Act. Please see contact your educational institution for certain choices with respect to the use and sharing of your personal information.

We may collect (and may have collected during the 12-month period prior to the Last Updated date of this California Consumer Privacy Notice) the following categories of personal information about you:

• Identifiers: identifiers such as a real name, alias, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers, and similar technology; customer number, unique pseudonym, or user alias; telephone number and other forms of persistent or probabilistic identifiers), online identifier, IP address, email address, account name, Social Security number, driver’s license number, passport number, and other similar identifiers
• Additional Data Subject to Cal. Civ. Code § 1798.80: signature, or description, state identification card number, bank account number, credit card number, debit card number, or other financial information, education information, medical information and health insurance information
• Protected Classifications: characteristics of protected classifications under California or federal law, such as race, color, national origin, religion, age, sex, gender, marital status, medical condition, disability, citizenship status, and military and veteran status
• Online Activity: Internet and other electronic network activity information, including, but not limited to, information regarding your interaction with websites, applications or advertisements
• Sensory Information: audio, electronic, visual, and similar information
• Employment Information: professional or employment-related information such as résumé information, occupation details, education details, certifications and professional associations, historical compensation details, previous employment details, emergency contact information, and pre-employment screening and background check information, including criminal records information
• Education Information: education information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99)
• Inferences: inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

We may use (and may have used during the 12-month period prior to the Last Updated date of this California Consumer Privacy Notice) your personal information for the purposes described in the Privacy Policy and for the following business purposes:

• Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytics services, providing storage, or providing similar services;
• Providing advertising and marketing services;
• Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance;
• Short-term, transient use, such as non-personalized advertising shown as part of your current interaction with us;
• Helping to ensure security and integrity;
• Undertaking activities to verify or maintain the quality or safety of our services or devices and to improve, upgrade, or enhance them;
• Debugging to identify and repair errors;
• Undertaking internal research for technological development and demonstration;
• Managing career opportunities with us; and
• Managing our relationships with current or prospective partners, corporate customers and vendors and other business partner personnel.

We do not collect or process sensitive personal information for purposes of inferring characteristics about consumers.

To the extent we process deidentified information, we will maintain and use the information in deidentified form and will not attempt to reidentify the information unless permitted by applicable law.

We will retain your personal information for the time period reasonably necessary to achieve the purposes described in the Privacy Policy and this California Privacy Notice, or any other notice provided at the time of collection, taking into account applicable statutes of limitation and records retention requirements under applicable law.

During the 12-month period prior to the Last Updated date of this California Privacy Notice, we may have obtained personal information about you from the following categories of sources:

• Directly from you, such as when you contact us
• Your devices, such as when you use our online services
• Our affiliates
• Vendors who provide services on our behalf
• Our business partners
• Data analytics providers
• Recruiting and talent agencies
• Job references, such as your employers
• Data brokers, such as background check services

We do not sell your personal information. We do not share your personal information with third parties (such as online advertising services) for cross-context behavioral advertising purposes.

During the 12-month period prior to the Last Updated date of this California Privacy Notice, we may have disclosed the following categories of personal information about you for a business purpose to the following categories of third parties:

In addition to the categories of third parties identified above, during the 12-month period prior to the Last Updated date of this California Privacy Notice, we may have disclosed personal information about you to government entities and third parties in connection with actual or proposed corporate transactions, such as mergers, acquisitions, or divestitures.

You have certain choices regarding your personal information, as described below.

• Access: You have the right to request, twice in a 12-month period, that we disclose to you the categories of personal information collected about you, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling, or sharing personal information, the categories of third parties to whom we disclose personal information, and the specific pieces of personal information collected about you.
• Correction: You have the right to request that we correct the personal information we maintain about you, if that information is inaccurate.
• Deletion: You have the right to request that we delete certain personal information we have collected from you.

To submit an access, correction, or deletion request, please see the “How to Exercise Your Rights” section below.

To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your deletion or correction request. If you have an account with us, we may verify your identity by requiring you to sign in to your account. If you do not have an account with us and you request access to, correction of or deletion of your personal information, we may require you to verify your email address or phone number in our records and/or provide any of the following information:

• Full name & surname
• State of residence
• Physical address
• Telephone number
• Nature of your relationship with our company (Website visitor/Job Applicant/Employee/Former Employee/Contractor/Business Partner Personnel)
• Email address

In addition, if you ask us to provide you with specific pieces of personal information, we may require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request.

Subject to certain rights and limitations under applicable law, individuals may have the right to know and request access to, deletion of, and correction of certain personal information collected from or about them. For California residents, please see our California Privacy Notice section above for more information. To submit an access, correction, or deletion request, or to submit a request as an authorized agent on behalf of someone else, please call 866-441-4637 or email [email protected].

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 employs use servers located outside the United States. FACTS 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.

If you have any questions about this Web Privacy Policy please contact us by email at [email protected] or via our Contact Us portal.