Introduction

We are an online platform dedicated to helping students reduce debt and connect to jobs, and employers identify, prepare and secure the talent they wish to hire. People use our Services to find and be found for employment opportunities, to connect with others and find information. Our Privacy Policy applies to any Member or Employer. Our registered users ("Members") share their academic and professional identities, engage with each other, exchange knowledge and professional insights, post and view relevant content, learn and develop skills, and find career opportunities. Content and data on some of our Services is viewable to non-members ("Visitors"). We use the term "Designated Countries" to refer to countries in the European Union (EU), European Economic Area (EEA), and Switzerland.

Services

This Privacy Policy, including our Cookie Policy applies to your use of our Services. This Privacy Policy applies to EFFA.io, EFFA-branded apps, and other EFFA-related sites, apps, communications and services ("Services"), but excluding services that state that they are offered under a different privacy policy. For California residents, additional disclosures required by California law may be found in our California Privacy Disclosure.

Data Controllers and Contracting Parties

EFFA Corporation will be the controller of your personal data provided to, or collected by or for, or processed in connection with, our Services. As a Visitor or Member of our Services, the collection, use and sharing of your personal data is subject to this Privacy Policy and other documents referenced in this Privacy Policy, as well as updates.

Change

Changes to the Privacy Policy apply to your use of our Services after the "effective date." EFFA ("we" or "us") can modify this Privacy Policy, and if we make material changes to it, we will provide notice through our Services, or by other means, to provide you the opportunity to review the changes before they become effective. If you object to any changes, you may close your account. You acknowledge that your continued use of our Services after we publish or send a notice about our changes to this Privacy Policy means that the collection, use and sharing of your personal data is subject to the updated Privacy Policy, as of its effective date.

Data We Collect

1.1 Data You Provide To Us

You provide data to create an account with us.

Registration

To create an account you need to provide data including your name, email address and/or mobile number, general location (e.g., city), and a password. You create your EFFA profile (a complete profile is required to get the most from our Services).

Profile

You have choices about the information on your profile, such as your education, work experience, skills, photo, city or area and endorsements. You don't have to provide additional information on your profile; however, profile information helps you to get more from our Services, including helping recruiters find you. It's your choice whether to include sensitive information on your profile and to make that sensitive information public. Please do not post or add personal data to your profile that you would not want to be publicly available.

You give other data to us, such as by contributing videos about your experience or status of training completion.

Posting and Uploading

We collect personal data from you when you provide, post or upload it to our Services, such as when you fill out a form, (e.g., with demographic data or G.P.A.), respond to a survey, or submit a resume or fill out a job application on our Services. You don't have to post or upload personal data; though if you don't, it may limit your ability to grow and engage with employers over our Services.

1.2 Data From Others

You provide data to create an account with us.

Partners

We receive personal data (e.g., your job title and work email address) about you when you use the services of our employer customers and partners, such as employers or prospective employers and applicant tracking systems providing us job application data.

1.3 Service Use

We log your visits and use of our Services, including mobile usage of desktoop app. We log usage data when you visit or otherwise use our Services, including our sites, app and platform technology, such as when you view or click on content (e.g., corporate video), perform a search, install or update one of our desktop apps via mobile, or apply for jobs. We use log-ins, cookies, device information and internet protocol ("IP") addresses to identify you and log your use.

1.4 Cookies and Similar Technologies

We collect data through cookies and similar technologies. W e use cookies and similar technologies (e.g., pixels and ad tags) to collect data (e.g., device IDs) to recognize you and your device(s) on, off and across different services and devices where you have engaged with our Services. We also allow some others to use cookies as described in our Cookie Policy. You can opt out from our use of data from cookies and similar technologies that track your behavior on the sites of others for ad targeting and other ad-related purposes.

1.5 Your Device and Location

We receive data through cookies and similar technologies When you visit or leave our Services (including some plugins and our cookies or similar technology on the sites of others), we receive the URL of both the site you came from and the one you go to and the time of your visit. We also get information about your network and device (e.g., IP address, proxy server, operating system, web browser and add-ons, device identifier and features, cookie IDs and/or ISP, or your mobile carrier). If you use our Services from a mobile device, that device will send us data about your location based on your phone settings. We will ask you to opt-in before we use GPS or other tools to identify your precise location.

1.6 Messages

If you communicate through our Services, we learn about that.

We collect information about you when you send, receive, or engage with messages in connection with our Services. For example, if you get an email about an Employer-Funded Financial Aid opportunity, we track whether you have acted on it and will send you reminders. We also use automatic scanning technology on messages to support and protect our site. For example, we use this technology to suggest possible responses to messages and to manage or block content that violates our User Agreement from our Services.

1.7 Workplace and School Provided Information

We collect data through cookies and similar technologies.

We use cookies and similar technologies (e.g., pixels and ad tags) to collect data (e.g., device IDs) to recognize you and your device(s) on, off and across different services and devices where you have engaged with our Services. We also allow some others to use cookies as described in our Cookie Policy. You can opt out from our use of data from cookies and similar technologies that track your behavior on the sites of others for ad targeting and other ad-related purposes.

1.8 Sites and Services of Others

We get data when you visit sites that include our ads, cookies or some of our plugins or when you log-in to others' services with your EFFA account.

We receive information about your visits and interaction with services provided by others when you log-in with EFFA or visit others' services that include some of our plugins or our ads, cookies or similar technologies.

1.9 Other

We are improving our Services, which means we get new data and create new ways to use data.

Our Services are dynamic, and we often introduce new features, which may require the collection of new information. If we collect materially different personal data or materially change how we collect, use or share your data, we will notify you and may also modify this Privacy Policy.

How We Use Your Data

We use your data to provide, support, personalize and develop our Services.

How we use your personal data will depend on which Services you use, how you use those Services and the choices you make in your settings. We use the data that we have about you to provide and personalize our Services, including with the help of automated systems and inferences we make, so that our Services can be more relevant and useful to you and others.

2.1 Services

Our Services help you connect with others, find and be found for work opportunities, stay informed, get training and be more productive.

We use your data to authorize access to our Services and honor your settings.

Stay Connected

We use data about you (such as your profile, or data provided through uploads or partner integrations) to help others find your profile, and enable you to respond to Employer-Funded Financial Aid opportunities.

Visitors have choices about how we use their data.

Stay Informed

Our Services also allow you to improve your professional skills, or learn new ones. We use the data we have about you (e.g., data you provide, data we collect from your engagement with our Services and inferences we make from the data we have about you), to personalize our Services for you, such as by recommending or ranking relevant content on our Services. We also use the data we have about you to suggest skills you could add to your profile and skills that you might need to pursue your next opportunity. We use your content, activity and other data, including your name and photo, to provide notices to employers.

Career

Our Services allow you to explore Employer-Funded Financial Aid opportunities, evaluate educational opportunities, and seek out, and be found for, career opportunities. Your profile can be found by those looking to hire. We will use your data to recommend Employer-Funded Financial Aid opportunities. You can signal that you are interested in changing jobs and share information with recruiters. We will use your data to recommend jobs to you and you to recruiters. We may use automated systems to provide content and recommendations to help make our Services more relevant to our Members, Visitors and customers. Keeping your profile accurate and up-to-date may help you better connect to others and to opportunities through our Services.

Communications

We contact you and enable communications between you and employers and other partners. We offer settings to control what messages you receive and how often you receive some types of messages.

We will contact you through email, mobile phone, notices posted on our websites or apps, messages to your inbox, and other ways through our Services, including text messages and push notifications. We will send you messages about the availability of our Services, security, or other service-related issues. We also send messages about how to use our Services, reminders, Employer-Funded Financial Aid opportunity suggestions from us and our partners. You may change your communication preferences at any time. Please be aware that you cannot opt out of receiving service messages from us, including security and legal notices.

Marketing

We promote our Services to you and others.

In addition to advertising our Services, we use Members' data and content for invitations and communications promoting membership and Employer-Funded Financial Aid opportunities, engagement and our Services.

2.4 Developing Services and Research

We develop our Services and conduct research

Service Development

We use data, including public feedback, to conduct research and development for our Services in order to provide you and others with a better, more intuitive and personalized experience, drive membership growth and engagement on our Services, and help connect you to Employer-Funded Financial Aid opportunities.

Other Research

We seek to create economic opportunity for Members of the global workforce and to help them be more productive and successful. We use the personal data available to us to research social, economic and workplace trends, such as jobs availability and skills needed for these jobs and policies that help bridge the gap in various industries and geographic areas. In some cases, we work with trusted third parties to perform this research, under controls that are designed to protect your privacy. We publish or allow others to publish economic insights, presented as aggregated data rather than personal data.

Surveys

Polls and surveys are conducted by us and others through our Services. You are not obligated to respond to polls or surveys, and you have choices about the information you provide. You may opt-out of survey invitations.

2.5 Customer Support

We use data to help you and fix problems.

We use data (which can include your communications) to investigate, respond to and resolve complaints and for Service issues (e.g., bugs).

2.6 Insights That Do Not Identify You

We use data to generate insights that do not identify you.

We use your data to produce and share insights that do not identify you. For example, we may use your data to generate statistics about our members, their profession or industry, or to publish visitor demographics for a Service or create demographic workforce insights.

2.7 Security and Investigations

We use data for security, fraud prevention and investigations.

We use your data (including your communications) for security purposes or to prevent or investigate possible fraud or other violations of our User Agreement and/or attempts to harm our Members, Visitors or others.

How We Share Information

3.1 Our Services

Any data that you include on your profile and any content you post on our Services will be seen by others, consistent with your settings.

Profile

Your profile is fully visible to employer customers of our Services. Subject to your settings, it can also be visible to others on or off of our Services (e.g., Visitors to our Services or users of third- party search engines). Your settings impact the availability of your profile and whether they can view certain fields in your profile. Your employer can see how you use Services they provided for your work (e.g. as a recruiter) and related information. We will not show them your Employer-Funded Financial Aid opportunities searches.

3.2 Communication Archival

Regulated Members may need to store communications outside of our Service.

Some Members (or their employers) need, for legal or professional compliance, to archive their communications and media activity, and will use services of others to provide these archival services. We enable archiving of messages by and to those Members outside of our Services.

3.3 Related Services

We share your data across our different Services and EFFA affiliated entities.

We will share your personal data with our affiliates to provide and develop our Services. We may combine information internally across the different Services covered by this Privacy Policy to help our Services be more relevant and useful to you and others.

3.4 Service Providers

We may use others to help us with our Services.

We use others to help us provide our Services (e.g., maintenance, analysis, audit, payments, fraud detection, marketing and development). They will have access to your information as reasonably necessary to perform these tasks on our behalf and are obligated not to disclose or use it for other purposes.

3.5 Legal Disclosures

We may need to share your data when we believe it's required by law or to help protect the rights and safety of you, us or others.

It is possible that we will need to disclose information about you when required by law, subpoena, or other legal process or if we have a good faith belief that disclosure is reasonably necessary to (1) investigate, prevent or take action regarding suspected or actual illegal activities or to assist government enforcement agencies; (2) enforce our agreements with you; (3) investigate and defend ourselves against any third-party claims or allegations; (4) protect the security or integrity of our Services (such as by sharing with companies facing similar threats); or (5) exercise or protect the rights and safety of EFFA, our Members, personnel or others. We attempt to notify Members about legal demands for their personal data when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand.

3.6 Change in Control or Sale

We may share your data when our business is sold to others, but it must continue to be used in accordance with this Privacy Policy.

We can also share your personal data as part of a sale, merger or change in control, or in preparation for any of these events. Any other entity which buys us or part of our business will have the right to continue to use your data, but only in the manner set out in this Privacy Policy unless you agree otherwise.

Your Choices & Obligations

4.1 Data Retention

We keep most of your personal data for as long as your account is open.

We generally retain your personal data as long as you keep your account open or as needed to provide you Services. This includes data you or others provided to us and data generated or inferred from your use of our Services. Even if you only use our Services when looking for new Employer-Funded Financial Aid opportunities every few years, we will retain your information and keep your profile open, unless you close your account. In some cases we choose to retain certain information (e.g., insights about Services use) in a depersonalized or aggregated form.

4.2 Rights to Access and Control Your Personal Data

You can access or delete your personal data. You have many choices about how your data is collected, used and shared.

We provide many choices about the collection, use and sharing of your data, from deleting or correcting data you include in your profile and controlling the visibility of your profile to communication controls. We offer you settings to control and manage the personal data we have about you. For personal data that we have about you, you can:

• Delete Data: You can ask us to erase or delete all or some of your personal data (e.g., if it is no longer necessary to provide Services to you).
• Change or Correct Data: You can edit some of your personal data through your account. You can also ask us to change, update or fix your data in certain cases, particularly if it's inaccurate.
• Object to, or Limit or Restrict, Use of Data: You can ask us to stop using all or some of your personal data (e.g., if we have no legal right to keep using it) or to limit our use of it (e.g., if your personal data is inaccurate or unlawfully held).
• Right to Access and/or Take Your Data: You can ask us for a copy of your personal data and can ask for a copy of personal data you provided in machine readable form.

You may also contact us using the contact information below, and we will consider your request in accordance with applicable laws.

4.3 Account Closure

We keep some of your data even after you close your account.

If you choose to close your EFFA account, your personal data will generally stop being visible to others on our Services within 24 hours. We generally delete closed account information within 30 days of account closure, except as noted below.

We retain your personal data even after you have closed your account if reasonably necessary to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse (e.g., if we have restricted your account for breach of our Professional Community Policies), enforce our User Agreement, or fulfill your request to "unsubscribe" from further messages from us. We will retain de-personalized information after your account has been closed.

Information you have shared with others will remain visible after you close your account or delete the information from your own profile, and we do not control data that other Members have copied out of our Services. Your profile may continue to be displayed in the services of others (e.g., search engine results) until they refresh their cache.

Other Important Information

5.1 Security

We monitor for and try to prevent security breaches. Please use the security features available through our Services.

We implement security safeguards designed to protect your data, such as HTTPS. We regularly monitor our systems for possible vulnerabilities and attacks. However, we cannot warrant the security of any information that you send us. There is no guarantee that data may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.

5.2 Cross-Border Data Transfers

We store and use your data outside your country.

We process data both inside and outside of the United States and rely on legally-provided mechanisms to lawfully transfer data across borders. Countries where we process data may have laws which are different from, and potentially not as protective as, the laws of your own country.

5.3 Lawful Bases for Processing

We have lawful bases to collect, use and share data about you. You have choices about our use of your data. At any time, you can withdraw consent you have provided by going to settings.

We will only collect and process personal data about you where we have lawful bases. Lawful bases include consent(where you have given consent), contract (where processing is necessary for the performance of a contract with you and "legitimate interests").

Where we rely on your consent to process personal data, you have the right to withdraw or decline your consent at any time and where we rely on legitimate interests, you have the right to object.

5.4 Direct Marketing and Do Not Track Signals

Our statements regarding direct marketing and "do not track" signals.

We currently do not share personal data with third parties for their direct marketing purposes without your permission.

5.5 Contact Information

You can contact us or use other options to resolve any complaints.

If you have questions or complaints regarding this Policy, please first contact EFFA online.

Consent

Where we process data based on consent, we will ask for your explicit consent. You may withdraw your consent at any time, but that will not affect the lawfulness of the processing of your personal data prior to such withdrawal. Where we rely on contract, we will ask that you agree to the processing of personal data that is necessary for entering into or performance of your contract with us. We will rely on legitimate interests as a basis for data processing where the processing of your data is not overridden by your interests or fundamental rights and freedoms.