Policy Effective Date: January 1, 2020
TABLE OF CONTENTS
1.THE INFORMATION WE COLLECT
2.THE WAY WE USE INFORMATION
3.WHEN WE DISCLOSE INFORMATION
4.YOUR CHOICES, RIGHTS AND RESPONSIBILITIES
5.OUR COMMITMENT TO DATA SECURITY
6.OUR COMMITMENT TO CHILDREN’S PRIVACY
8.IN THE EVENT OF MERGER OR SALE
10.YOUR RIGHTS TO ACCESS DATA
11.HOW TO COMPLAIN
- The Information We Collect; Personal Data
User-Provided Information, including Personally Identifiable Information (PII): Due to the nature and scope of our product, you may provide to Poets&Quants what is generally called “personally identifiable” information. Our Site and third parties may collect personally identifiable information from you such as your name, e-mail address, postal address, phone number, educational plans, or information regarding your academic and extracurricular activities and interests; and/or other information that may identify you as an individual or allow online contact with you so that we or other third parties can provide you with the products and services you request or have agreed to receive. We collect personal information from users when they register or create an account on our Site, or through other ways such as through such user’s activities, transactions, inquiries to school(s) or third party, and completion of surveys or other similar types of canvassing and other online forms on our Site.
Our Site may also collect your credit card information when you make a purchase, so that we can process your payment for the product or service you are requesting. During the ordering process, such credit card information is transmitted either to Poets&Quants or to the supplier or service provider who provides the service you are purchasing. In both cases, credit card information is then transmitted to third-party credit card processors and card issuers that use your information to process your order.
Our Site may also collect information that does not identify you by name when you visit Poets&Quants, such as your internet protocol (“IP”) address, geo-location, domain name, browser configuration, device type, unique device identifier, the type of operating system you are using, information about your Internet service provider, the time of your visit, whether you are a returning visitor, and any referring website.
Overall, we may collect, use, store and transfer different kinds of Personal Data about you. We have grouped these into the following categories of “Personal Data”:
Contact Data: such as email addresses, home address, apartment number, city, state, zip code, email address, and telephone numbers.
Education Data: High School name and address, college name and address, number of years of college complete, degrees earned, graduate school name and address, graduate degrees earned, certifications earned and locations (state of issuance), issuance date, expiration date.
Financial Data: such as payment card details including card numbers, security codes, expiration dates, and billing address. However, please note that payment methods (e.g., credit card number and/or PayPal and/or bank account details) are not collected by us directly, but by secure payment service providers.
Marketing and Communications Data: such as your preferences in receiving marketing from us and our third parties and your communication preferences.
Military Service Data: such as branch of military in which you served, military specialty, discharge type, discharge date.
Profile Data: such as your username and password, orders made by you, preferences, user- generated content, job searches, candidate searches, job applications, feedback and survey responses.
Technical Data: such as Device IDs, your login data, access dates and times, browser type and version, device information, cookie data, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the Website.
Transaction Data: such as details about payments to and from you, and details regarding the services that you have subscribed to in relation to this Website.
Usage Data: such as information about how you use our Website, products and services.
IP Address and Clickstream Data. We automatically collect information from your browser when you visit our Site. This information includes your IP address, your browser type and language, access times, the content of any undeleted cookies that your browser previously accepted from us and the referring website address.
Response to Do Not Track Signals: – Certain web browsers may provide an option by which you may have the browser inform websites or internet services you visit that you do not wish to have information (which may or may not contain PII) about your activities tracked by cookies or other persistent identifiers across time and across third-party Internet websites, online or cloud computing services, online applications, or mobile applications. These are commonly called “do not track” signals. Poets&Quants site requires cookies to maintain active user sessions, and therefore Poets&Quants does not act on Do Not Track requests.
Third Party Web Beacons: To bring you the best experience and product set possible, we may also implement and integrate third party content, such as advertising, on the Service that uses “clear gifs,” “web beacons,” or other similar techniques, and which may allow the third party content provider to read and write cookies to your browser, or implement similar tracking mechanisms, in connection with your viewing of that third party content displayed on or through the Service.
Other System Information Automatically Collected: When you access the Service or open one of our HTML emails, we may automatically record certain information from your system by using different types of tracking technology. This “automatically collected” information may include your Internet Protocol address, a unique device or user ID, the version of software installed, system type, the content and pages that you access on the Service, and the dates and times that you visit the Service.
- The Way We Use Information
Poets&Quants uses the information that you provide or that we collect to operate, maintain, enhance, and provide all of the features and services found on the Service as well as to track user-generated content and Users to the extent necessary to comply as a service provider with the Digital Millennium Copyright Act.
We will use your email address and other provided contact information, without further consent, for administrative communications such as notifying you of major Service updates, for customer service
purposes, to address copyright infringement or defamation issues, or to contact you regarding any content, and other materials that you have posted to, transmitted through, or downloaded from the Service.
Poets&Quants uses all of the information that you provide or that we collect to understand the usage trends and preferences of our Users, to improve the way the Service works and looks, and to create new features and functionality.
Poets&Quants may use “Automatically Collected” information and “Cookies” information, alone or in combination with other information we have collected from you, to: (a) personalize the service, such as remembering your information so that you will not have to re-enter it during your visit or the next time you access the Service; (b) provide customized third party advertisements, content, and information, (c) send you email communications and otherwise correspond with you about news, schools, products, services and events that might interest you (d) transact “Connect Me” school inquiries if you opt-in and direct the sharing of your contact information with the chosen school(s) or third party to receive additional information or offers. By doing so, you authorize us to store your information and share it with the school(s) or third party selected. If you do not want to share your personal information with school(s) or third parties, do not opt-in and submit these transaction forms (f) enroll in webinars and events. You may signup for events, and opt-in to share your registration information with school(s) or third parties participating in the event. If you do not wish to become an Event Registered User, do not opt-in to share your information with participating institutions during the event registration process. (g) post commentary in MBA Handicapping Odds, article discussions and forums. You may opt-in and post comments that will be published on the website. If you choose to submit comments or other content for publication, we may publish your name, screen name or such other information that you supply, (h) monitor aggregate site usage metrics such as total number of visitors and pages accessed; (i) provide such metrics to Users as they pertain to such User’s content; and (j) track your entries, submissions, and status in any Job Posting, promotions or other activities, and (k) process transactions requested by you such as “Connect Me” inquiries, webinar and event registration, and brochure and guidebook requests. These transactions include storing and sharing your information with school(s) and third parties.
We receive compensation from schools and third parties for our events, webinars, “Connect Me” inquiries, and advertising.
Poets&Quants may use your email address or other personally identifiable information to send (a) messages about the Service, such as when you receive communications from another User, (b) and promotional messages related to the Service and the activities of third parties we work with. Generally, you have the ability to unsubscribe from further communications from a User of the Service, through links provided in the messages sent on behalf of such User.
We rely on third party vendors to help deliver our products and services on our Site. Some of them use data about your use of our Site. Below is a list of third parties with links to more information on their use of your data. These third parties are not authorized by us to use your Personal Information in any other way.
DoubleClick for Publishers:https://marketingplatform.google.com/about/
Google Firebase: https://firebase.google.com/support/privacy
- When We Disclose Information
Poets&Quants does not share your personally identifiable information with other organizations for their marketing or promotional uses without your prior consent. Please be aware, however, that any personally identifiable information that you voluntarily choose to display on or provide to the Service – such as when you publish contact information in a Marketing Communication or Account profile – becomes publicly available and may be collected and used by others without restriction. For example, if you send a Marketing Communication through the Service that includes personally identifiable information, some of the intended recipients may forward or provide such communication publicly to others without your consent.
The Service enables users to communicate with others in a variety of ways. Any personally identifiable information you voluntarily choose to include in a communication with other Users, or to post on the Service (such as in a resume or a Profile), will be available to such Users and other recipients of the communication. If you voluntarily provide personally identifiable information to the Service, such as by making a resume public or making a Profile public, Poets&Quants may share this information with a relevant employer or other Users of the Service.
When you contribute to a public area or feature of our Site, such as a chat room, bulletin board, list serve, blog, wiki or other open forum, the information that you submit will be made available to the public. Therefore, we recommend that you do not submit any sensitive information to such areas of our Site, including your full name, home address, phone number, financial information or any other information that would enable other users to locate you or contact you.
Users should also take care with how they handle and disclose their Personal Information and should avoid sending Personal Information through insecure email, SMS messaging or similar communications. Please refer to the Federal Trade Commission’s website at http://www.ftc.gov/bcp/menus/consumer/data.shtm for information about how to protect yourself against identity theft.
We use commercially reasonable physical, technical and administrative controls to protect the information we collect online. Please note that there is no method of transmission over the Internet, or method of electronic storage, that is completely secure.
Poets&Quants may disclose your information if required to do so by law or in the good-faith belief that such action is necessary to comply with state and federal laws (such as U.S. Copyright law) or respond to a court order, judicial or other government subpoena, or warrant in the manner required by the requesting entity.
Poets&Quants also reserves the right to disclose User information that we believe, in good faith, is appropriate or necessary: to take precautions against liability; to protect Poets&Quants from fraudulent, abusive, or unlawful uses; to investigate and defend ourselves against third-party claims or allegations; to assist government enforcement agencies; to protect the security or integrity of the Service; or to protect the rights, property, or personal safety of Poets&Quants, our users, or others.
- Your Choices, Rights and Responsibilities
Right Not To Share Information: You may, of course, decline to share your personally identifiable information with Poets&Quants, in which case Poets&Quants will not be able to provide to you some of the features and functionality found on the Service. You may update or correct your user information and preferences at any time by accessing your account preferences page through the Service. Please note that while changes to your Account are reflected promptly in active user databases, we may retain all information that we collect or that you provide for a variety of purposes, including backups and archiving, prevention of fraud and abuse, and analytics. Please note also that once you have publicly shared information, it may be re-shared by other users, and your subsequent modification or removal of that information will not necessarily affect copies previously propagated by others.
To protect your privacy and security, we take reasonable steps to verify your identity before granting you account access or making corrections to your information.
Right to Correct, Update, Delete Personal Information: You have the right to ask us to change, correct, or delete Personal Data. You may also ask us to delete and remove Personal Data where there is no good reason for us to continue to process it (for instructions see below). If you choose to ask us to delete and remove your Personal Data Poets&Quants may not be able to provide to you some or all of the features and functionality found on the Service. Please note, we may not always be able to comply with your request for erasure and in such circumstances, will notify our reasons to you. If you choose to ask us to alter, remove or delete your Personal Information you may contact us in one of the following ways: a) using the messaging functionality in your user account to contact us directly, if available, b) emailing us at: privacy@PoetsandQuants.com, or c) calling us directly at: 800-971-6003. We will respond to you in writing within the time frame required by the relevant law.
You may review and correct basic Personal Information that is accessible to you in your user account on this Site by visiting the “My Profile” area of your account on any Site hosted by C-Change Media, Inc. for which you are a registered user. We offer consumers the following procedure to submit requests to access and delete personal information.
You may request full Personal Information (including personal information that has been collected, transmitted, or disclosed) by submitting your request to access Full Personal Information by email: Privacy@PoetsandQuants.com Please include “California Privacy Rights” in the Subject line of your email. You may also make such a request by writing to us at the mailing address listed below. In order to verify your request, we will ask you to provide your name, email address, and certain other pieces of identifying information. Once you have submitted this information and any necessary supporting documentation, we will confirm the information and then fulfill your request within 45 days.
You have the right to request the deletion of your personal information. You may submit a request to delete this information by email or mail. In order to verify your request, we will ask you to provide your name, email address, and certain other pieces of identifying information. Once you have submitted this information and any necessary supporting documentation, we will confirm the information and then fulfill your request within 45 days.
Marketing Communications: If you no longer wish to receive any marketing communications from us, you may request to be removed from our email list. You may send an email to Privacy@PoetsandQuants.com requesting removal from the Site’s email distribution list to opt-out from our marketing communication and delete your registered user account on the Site. You may also do this by unsubscribing to any email communication you receive from us.
If you no longer wish to receive marketing communications from your selected school(s) or third party, you may do this by unsubscribing to any email communication you receive from them or by notifying such third party.
Please understand that if you opt-out of receiving promotional correspondence from us, we may still contact you in connection with your relationship, activities, transactions and communications with us.
You may opt out of tracking by Google Analytics by clicking here.
Your Responsibilities: You are responsible for maintaining the secrecy of your unique password and account information at all times.
- Our Commitment To Data Security
Poets&Quants uses certain physical, managerial, and technical safeguards designed to preserve the integrity and security of your personal information. We cannot, however, ensure or warrant the security of any information you transmit to Poets&Quants, and you do so at your own risk. Poets&Quants cannot guarantee that information you provide or that we collect may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.
If Poets&Quants learns of a security systems breach, then we may attempt to notify you electronically so that you can take appropriate protective steps. Poets&Quants may post a notice on the Service if a security breach occurs. Depending on where you live, you may have a legal right to receive notice of a security breach in writing. To receive a free written notice of a security breach you should notify us at privacy@PoetsandQuants.com.
Third Party “Linked-To” Websites
- Commitment To Children’s Privacy
If you are under 13 years of age, then you may not use or access the Service at any time or in any manner.
Protecting the privacy of young children is especially important. For that reason, Poets&Quants does not knowingly collect or maintain personally identifiable information from persons under 13 years-of-age. If Poets&Quants learns that personally identifiable information of persons less than 13-years-of-age has been collected on or through the service, then Poets&Quants will take the appropriate steps to delete this information.
If you are the parent or legal guardian of a child under 13 who you believe has registered an Account on the Service, then please contact Poets&Quants at Poets&Quants@PoetsandQuants.com to have that child’s Account terminated and information deleted.
- International Visitors
For users visiting the service from the European Economic Area (EEA) or any other non-U.S. territories, please note that any data you enter into the Service will be transferred outside the European Economic Area or such other non-U.S. territory for use by Poets&Quants and its affiliates for any of the purposes described herein. In addition, because Poets&Quants operates globally, we may make information we gather available to worldwide business units and affiliates. By providing any data on the Service, you hereby expressly consent to such transfers of your data to the United States or other countries.
- In The Event Of Merger Or Sale
In the event that Poets&Quants is acquired by or merged with a third-party entity, we reserve the right, in any of these circumstances, to transfer or assign the information that we have collected from Users as part of that merger, acquisition, sale, or other change of control.
- Your Rights To Access Data (For Data Subjects In The EEA).
Data subjects in the EEA have the following rights with respect to their Personal Data:
Right to Information: The right to know what Personal Data we hold about you and how we use it.
Right to Access: The right to be provided with a copy of your Personal Data (subject to certain restrictions).
Right of Rectification: The right to require us to correct any incomplete or inaccurate Personal Data we hold about you, though we may need to verify the accuracy of the new data you provide to us. If you have a user account with us, you also have the option of correcting your information directly in your account.
Right to erasure/be forgotten: This enables you to ask us to delete or remove Personal Data where there is no good reason for us to continue to process it. Note, however, that we may not always be able to comply with your request for erasure and in such circumstances, will notify our reasons to you.
Right to restrict processing: The right to require us to restrict processing of your Personal Data, i.e., you can request that we suspend the processing of your Personal Data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Right to request data portability: In certain circumstances, you have the right to request the transfer of your Personal Data to you or to a third party in a commonly used machine-readable format. Note, however, that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Right to object to processing: You have the right to object to the processing of your Personal Data in the following circumstances: (i) at any time to your Personal Data being processed for direct marketing (including profiling); or (ii) in certain other situations, to our continued processing of your Personal Data, e.g., our processing of your Personal Data when such processing is based on our legitimate interests. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Right to withdraw consent at any time: You have the right to withdraw your consent at any time where we are relying on consent to process your Personal Data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Right not to be subject to a decision based solely on automated decision-making: The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you. However, your right does not apply if: (i) you gave us your explicit consent to use your personal data to make our decision; (ii) we are allowed by law to make our decision; or (iii) our automated decision was necessary to enable us to enter into a contract with you.
Method for Requesting Information Pursuant to Your Rights
Upon request, Poets&Quants will provide you with information about whether we hold any of your personal information. If you would like to exercise any of the data subject access rights in the table above (each, an “Access Request”) please send an email to privacy@PoetsandQuants.com, and we will send you a Data Subject Access Request Form. We will respond to your request within a reasonable timeframe.
No Fee Usually Required. You will not usually be required to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What We May Need from You. Once we receive your Access Request, we may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time Limit to Respond. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
- How To Complain
All Data Subjects. If you have any complaint about the treatment of your Personal Data, or inquiries regarding our data practices, please contact us as set forth in Section 14 so we may resolve any query or concern you have.
Data Subjects Based in the European Economic Area. The General Data Protection Regulation also gives you the right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) country where you work, normally live or where any alleged infringement of data protection laws occurred.
C-Change Media, Inc.
101 Broadway, Suite 208
Oakland, CA 94607
Email Heather Soderquist: Privacy@PoetsandQuants.com