Privacy Statement and Notice of Privacy Practices
Created: December 1, 2015
Contact and Electronic Communications Opt Out
Description of Products and Services
S2S develops and provides products and services intended to facilitate the transition by members of the United States Armed Forces and veterans to educational institutions.
Information We Collected by From You
We collect two types of information from you when you visit our Sites or register to use our Products and Services: (1) “personally identifiable information” (as defined below) and (2) non-personally identifiable information (as defined below). This information may also be collected by S2S Ambassadors and others who either volunteer to assist S2S or are paid employees of S2S.
Personal Identifiable Information (“PII”)
Personally identifiable information includes, but is not limited to, your name, address, email, phone number, financial, billing or payment information, position, or title. PII also includes transcripts and resumes and other information concerning your academic and personal qualifications for admission to educational institutions and programs to which you are applying and to which we believe you may be qualified. We use your PII mainly to provide you with the Products and Services, administer your inquires and complete your transactions. We also use your PII to contact educational institutions and programs for the purpose of determining whether they may be interested in contacting you and pursuing the possibility of your applying, and their accepting you, into one of their educational programs.
Non-Personally Identifiable Information (“NPII”)
Non-Personally Identifiable Information can be technical information or it can be demographic information, such as your age, gender, or interests. NPII may also mean aggregated, non-identifiable or anonymized information. NPII does not identify you personally. If you do provide us with non-personally identifiable information, we may use it for the purposes described in this statement or where it is collected, or any other legal purpose.
Here are some examples of the ways in which we may collect and store your non-personally identifiable information through our services, and how we use such information:
- Log Information. When you use our services or view content provided by S2S we automatically collect and store certain information in our server logs. This type of information includes details of how you used our service, IP address information described below, web pages which have been viewed by a visitor, data and time, domain type, device event information such as crashes, system activity, hardware, settings, browser type or version, browser language, the date and time of your request and referral URL.
- Internet Protocol (IP) address. Your “IP address” is a number that lets computers attached to the Internet know where to send you data, such as the screens and pages of our services that you view. We use this information to deliver our screens and pages to you upon request, to tailor our services to the interests of you and our other visitors, and to measure traffic to and within our services.
- Demographic Information. “Demographic information” may be your gender, age, zip code, and interests. We may collect such information about you through our services and use it to provide you with personalized services and to analyze trends to ensure that our services and the information on them is targeted to meet your needs. Please note that we also consider aggregated information, which is not personally identifiable, to be non personally identifiable information.
Sharing and Disclosure of PII and NPII
Personally Identifiable Information. Primarily, we may share or disclose your PII in the following instances:
- To fulfill a service to you.
For example, if you email us a question, we may use your email address to process your request and respond to your question.
- To offer you products from our affiliates, strategic partners, agents, or from third-party marketers and other unaffiliated parties that we believe may be of interest to you, or to assist such parties for research, administrative, and/or business purposes.
These parties may contact you with an offer or advertisement related to a product or service, or they may use such information for their own research, administration or business purposes.
- To unaffiliated third-party service providers, agents, or independent contractors who help us maintain our services and us with other administrative services (including, but not limited to, order processing and fulfillment, providing customer service, maintaining and analyzing data, sending customer communications on our behalf, and entry collection, winner selection and prize fulfillment for contests, sweepstakes, and other promotions).
- To complete your purchase.
At the present time, S2S does not charge for its services or otherwise request that you make a purchase. However, in the future, in the event that S2S elects to offer its services for sale, and if you choose to make a purchase of one of our Products or on or through our Services, we may ask you for your credit card number, billing address, and other information in connection with completing such purchase, and we may use such information to fulfill your purchase. We may also provide such information, or other PII provided by you, to unaffiliated third-parties to complete your purchase (for example, to process your credit card).
- To comply with law, or in the good faith belief that such action is necessary to conform to the requirements of law, or comply with legal process served on us, and to protect and defend our rights or property, including our rights and property and our services, or act in urgent circumstances to protect the personal safety of you and our other visitors.
- To third parties as part of a corporate reorganization process including, but not limited to, mergers, acquisitions, and sales of all or substantially all of our assets.
- To track and analyze NPII, i.e. non-identifying, aggregate usage and volume statistical information from our visitors and customers and provide such information to third parties.
- To protect against fraud and potential fraud.
We may verify the information you provide to obtain our Products and Services through third parties. In the course of such verification, we may receive additional PII about you from such services. In particular, if you use a credit card or debit card to purchase services with us, we may use card authorization and fraud screening services to verify that your card information and address match the information you supplied to us, and that the card has not been reported as lost or stolen.
Non-personally identifiable information. We may share and disclose your NPII for the purposes described in this statement or where it is collected, or any other legal purpose, including, when and where applicable, sharing and disclosing non-personally identifiable information combined with PII.
Legal Disclosure. We may disclose information about you and your use of the Services if we believe that such disclosure is reasonably necessary to:
- Comply with the law and/or legal process where a formal request has been made (e.g. request from an administrative oversight agency, civil suit, subpoena, court order or judicial or administrative proceeding);
- Protect or defend our rights and/or property or the rights and property of others;
- Respond to claims that the content(s) of a communication violates the rights of another.
Access and Ability to Correct Your Information
Cookies and Other Technology
We use “cookies” to collect information. A cookie is a small data file that we transfer to your computer’s hard disk for record-keeping purposes. We receive and stores information about how you use our website when you visit the Sites. For example, we receive information that your browser or device sends to our servers whenever you visit the Sites. Your browser or device may tell us your internet protocol (IP) address used to connect your computer to the Internet, computer and connection information such as browser type, version, language and time zone setting, browser plug-in types, operating system, and type of device you are using. When you visit the Sites, your browser may also tell us information such as the actions you take on our Sites, the page that led you to our Sites and, if applicable, the search terms you typed into a search engine that led you to our Sites.
You can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the Sites you visit. If you do not accept cookies, however, you may not be able to use all portions of the Sites or all functionality of the Services.
Third-Party Links and Websites
Children Under 13
Social Media and Community Platforms
Advertisers and Marketing
We may also use third-party advertisers, ad networks, and other advertising, marketing, and promotional companies, to serve advertisements about our Products and Services. Such third parties may gather information about your visit to our services or other sites, monitor your access to or market products or services to you, monitor the ads you view, click-on, or interact with, when they were delivered, and the screens and pages that they are on. If you wish to not have this information used for the purpose of serving you targeted ads, you may opt out by sending us an email at email@example.com. Please note this does not opt you out of being served advertising. You will continue to receive generic ads.
To learn more about these practices, as well as your choices regarding the practices of these third-party advertising companies, you may wish to visit http://www.networkadvertising.org/optout_noNPIIi.asp and/or http://www.aboutads.info/choices/#completed. Both the Network Advertising Initiative (“NAI”) and the Digital Advertising Alliance (“DAA”) websites provide information regarding their respective members practices and your choices regarding having your information used by these companies, including the opt out procedures. Opting out of one or more NAI or DAA members only means that those NAI or DAA members no longer will be allowed under their own rules to deliver advertisements to you based on your visits to this site and other sites, but does not mean you will no longer receive any targeted content and/or ads. Also, if your browsers are configured to reject cookies when you visit this opt out page, or you subsequently erase your cookies, use a different device or change web browsers, your NAI or DAA opt out may not, or may no longer, be effective. We are not responsible for effectiveness of or compliance with any third parties’ opt out options or programs.
How We Protect Your Information
No data transmissions over the Internet are completely secure. Consequently, we cannot ensure or warrant the security of any information you transmit to us or others over the Internet. You transmit such information at your own risk. Once we receive your transmission, we make reasonable efforts to ensure the security of our systems. We use firewalls to protect your information from unauthorized access, disclosure, alteration, or destruction. However, this is not a guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of such firewalls or secure server software.
Contests, Promotions, and Giveaways
We may conduct giveaways, contests and other promotions on the services in which we may ask you for additional information. We use and treat this information in accordance with the terms of this Policy. Participation in such giveaways and contents is not necessary to use the services, and you may choose whether you wish to participate in any particular giveaway or contest, without affecting your general use of the site.
California Residents’ Rights
(As provided by California Civil Code Section 1798.83)
A California resident who has provided personal information to a business with whom he/she has established a business relationship for personal, family, or household purposes (“California customer”) is entitled to request information about whether the business has disclosed personal information to any third parties for the third parties’ direct marketing purposes. In general, if the business has made such a disclosure of personal information, upon receipt of a request by a California customer, the business is required to provide a list of all third parties to whom personal information was disclosed in the preceding calendar year, as well as a list of the categories of personal information that were disclosed.
California Do Not Track Notice
International Transfer of Information
We may transfer information that we collect about you, including PII, to subsidiary and affiliated entities, or to other third parties across borders and from your country or jurisdiction to other countries or jurisdictions around the world. If you are visiting from the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that you are transferring information about you, including PII, to a country and jurisdiction that does not have the same data protection laws as the European Union, and you consent to:
- the transfer of information about you, including PII, to the U.S.; and