Privacy Policy for FidelisEducation.com

Effective as of: December 1, 2011
Date of Last Revision: December 1, 2011

1.     Introduction.  Fidelis College, Inc. ("Fidelis") is committed to protecting the privacy of visitors to and users of FidelisEducation.com.  This privacy policy ("Privacy Policy") specifies what information Fidelis collects via the Site(s) (defined below), how Fidelis uses that information, and how you can request modifications to that information.  This Privacy Policy applies to your access to and use of FidelisEducation.com, any other sites operated or controlled by or on behalf or for the benefit of Fidelis, and any features, applications, products and/or services accessible through or in connection with any of such sites (any or all of such sites, the "Site(s)", and any or all of such features, applications, products and/or services, the "Service(s)").  Certain Sites or Services may be subject to additional privacy policies ("Additional Policies").  In the event of any direct conflict between any Additional Policies and this Privacy Policy, the Additional Policies shall control.  Fidelis reserves the right to amend or otherwise modify this Privacy Policy, so please re-visit this page periodically to check for updates.  The date of last revision is shown at the top of this document.

2.     Definitions.  As used in this Privacy Policy, the following terms have the following meanings:

a.     "Educational Service Providers" means third-party educational companies or institutions that, under an arrangement with Fidelis, may provide to or receive from Fidelis educational or other related services.

b.     "Financial Information" means financial information specific to an individual (e.g., a credit card number).

c.     "Marketing Information" means Optimization Information and Personal Information, including your name, address, e-mail address and telephone number collected, used and disclosed as set forth in this Privacy Policy.

d.     "Optimization Information" means information collected when you visit the Sites (other than information you affirmatively provide).  When linked with other information identifying you personally, then such information also will be considered Personal Information.

e.     "Personal Information" means Information that may be used, alone or in combination, to identify a specific individual, including Financial Information.

f.      "Technical Service Providers" means third-party vendors that, under an arrangement with Fidelis, may provide services relating to the Site(s) or Services (e.g., in connection with the processing of transactions occurring on the Site(s) or storing information collected via the Site(s)).

3.     Information Fidelis Collects.  Fidelis collects various types of information through the Sites and Services.  Certain elements of this information is Optimization Information collected automatically (e.g., information about the web browsing software that you use to access a Site) through various web and internet technologies.  Other information is Personal Information collected when you provide it, such as when you register or order Services.

a.     Optimization Information.  Each time you visit one of the Sites, Optimization Information is automatically gathered.  In general, this Information does not identify you personally.  Examples of Optimization Information include:  IP address; navigation path; and referring URL.  This and other Optimization Information helps Fidelis understand better users preferences, how visitors and users find and navigate Sites, and which pages are visited most often.  Such Optimization Information may be linked with Personal Information to accomplish the purposes described in this Privacy Policy.

b.     Personal Information.  In addition to the Optimization Information, Fidelis also collects, uses and discloses Personal Information that you affirmatively provide on a voluntary basis (e.g., when you register or order Services).  Personal Information collected varies depending on the type of response or Service requested.

4.     Fidelis' Use of Information.

a.     Marketing Information.  Fidelis uses Marketing Information to develop the Sites and Services to meet your needs; to measure and improve the Sites and Services; to communicate with you, including by email, postal mail, telephone and mobile devices, about products or services that may be of interest to you; to provide you with customer support; to prevent potentially illegal activities; and to enforce Fidelis' Terms of Use and this Privacy Policy.

b.     Personal Information.  Fidelis will not sell, rent or lease your Personal Information to others.  Fidelis may, however, collect, use and disclose Personal Information for the following purposes:

i.     to determine your admissibility and to register you for your selected educational programs; 

 ii.     to provide requested products and services;  

iii.     to respond to your inquiries; 

iv.     to administer promotions for which you have indicated an interest; 

 v.     for Fidelis' internal marketing purposes, e.g., sending you material about products, services, updates, etc. that may be of interest to you; 

vi.     for sharing with Fidelis' Educational Service Providers who may contact you with respect to their educational or marketing services;  

vii.     for sharing with Fidelis' Educational Service Providers or Technical Service Providers who are performing services on Fidelis' behalf;

viii.     to analyze and improve the use, performance and delivery of Sites and Services  

ix.     to analyze academic and learning outcomes and preferences, as well as risk and business results;

 x.     to obtain payment for Services;

 xi.     to maintain business records for reasonable periods; 

 xii.     to provide to any third party, under an obligation of confidentiality, in connection with the contemplated or actual reorganization, merger, acquisition, financing, securitization, insuring, sale or other disposal of all or part of Fidelis' business or assets, including for the purposes of determining whether to proceed with such transaction or fulfilling any records or other reporting requirements to such parties.  In the event of any actual reorganization, merger, or acquisition such information may be transferred as part of the transaction to the acquiror; and/or 

 xiii.     to any third party as may be required or permitted by legal, regulatory, industry self-regulatory, insurance, audit, or security requirements applicable to Fidelis, Educational Service Providers, or Technical Service Providers. 

c.     Financial Information.  Fidelis may use your Financial Information to provide requested Services, to analyze operational and business results, to analyze risk, and for processing your registration or other transactions you have initiated.  Financial Information will not be sold, rented, or otherwise transferred for any other purpose, except as required by law or in the case of a reorganization, merger or acquisition of Fidelis. 

5.     FERPA.  If you provide, or authorize Fidelis to obtain, your educational records, and if those records are provided to an Educational Institution to which you apply for admission or are admitted, those records may be subject to the federal Family Educational Rights and Privacy Act ("FERPA") and state laws and are subject to Fidelis policies.  If your educational records become subject to FERPA you have the right to limit access to such records except as provided by law.

6.     Jurisdictional Matters.  Some Educational Service Providers and Technical Service Providers (and/or their facilities) may be located outside of the jurisdiction in which you reside.  Accordingly, your Personal Information may be collected, used, disclosed, stored and processed in these other jurisdictions for the purposes described in this Privacy Policy, and the data protection and other laws of these jurisdictions might differ from those of your jurisdiction.  Fidelis requires its Educational Service Providers and Technical Service Providers to use your information only to provide the services Fidelis has retained them to provide.  By using the Sites or Services, your information may be transferred across borders and will be subject to the laws of those other jurisdictions.

7.     Opt-Out. 

a.     You may opt-out of Fidelis' collection, use and disclosure of your Personal Information at any time, subject to contractual, academic, legal or technical restrictions and reasonable notice.  Please note that, if you opt-out of certain uses of your Personal Information, Fidelis may no longer be able to provide certain Services.  You may not be permitted to opt-out from certain necessary collection, uses and disclosures.  These uses include, for example, educational announcements, maintaining reasonable academic, business and transaction records and disclosures to government entities as required for Fidelis to comply with applicable laws.

b.     You can choose to no longer receive marketing communications from Fidelis and you may express your choice where indicated on the applicable email or other communication.  Please note, however, that such a request will only remove you from Fidelis' lists; it may not remove you from the list of any Technical Service Provider or Educational Service Provider.  Fidelis is not responsible for the use any other party may make of information once it has been distributed in accordance with this Privacy Policy and you will need to contact such entity to have your information removed from their database.

c.     Students who desire to prevent release of their directory and educational record Information in accordance with FERPA may place a FERPA Hold on their academic file.

8.     Security.  Fidelis takes commercially reasonable and industry standard measures to secure and store your information and to protect against the loss, misuse, and alteration of information under Fidelis' control.  Unfortunately, no data transmission over the internet or fixed storage of transmitted data can be guaranteed to be completely secure.  As such, Fidelis does not guarantee you against the loss, misuse, or alteration of information under Fidelis' control, and you provide information to Fidelis at your own risk.  You should always take care with how you handle and disclose your Personal Information.

9.     Monitoring of Communications.  Fidelis reserves the right, but does not assume the obligation, to monitor and retain all incoming and outgoing communications, including for training of Fidelis' representatives and for quality assurance purposes.

10.  Use of Industry-Standard Web Optimization Technologies.  Cookies, web beacons and other industry-standard web optimization internet technologies are used on the Sites to allow Fidelis to accomplish the uses permitted in this Privacy Policy and to keep track of your Information.  Cookies are small pieces of program code stored within web browsing applications and can generally be removed.  Most commonly-used web browsing software applications allow users to disable features and opt out of cookies or the other internet technologies.  If you desire to remove such technologies, the Services or Sites may be partially or totally unusable to you.

11.  Children's Privacy.  Fidelis takes seriously the issue of children's privacy. The Sites are neither developed for, nor directed at, children under 13.  If you are under 13, please do not use the Sites.  If you believe your child has provided Fidelis with Personal Information or registered at one of the Sites, please contact us at webmaster@fidelis-inc.com.

12.  Site Hosting and Links.  Some of the Sites may be hosted by Technical Service Providers or contain links to external websites hosted by Educational Service Providers and/or other third parties.  When you access these Sites or external websites, your access may be governed by policies maintained by the entities that host these sites.  Please make sure to read carefully the policies of any Sites you visit on the internet.  Fidelis is not responsible for the privacy practices or the content of any sites that Fidelis does not directly control; the collection, use and disclosure of information about you by Educational Service Providers, Technical Service Providers and other third parties will be subject to the policies applicable on those other Sites or external websites.

13.  Revisions.  Fidelis may update this Privacy Policy or revise it from time to time.  Please check this Site periodically to obtain a current copy of this Privacy Policy.  Your continued use of Sites or Services following any changes to this Privacy Policy constitutes your acceptance of such changes.  If Fidelis intends to use Personal Information in a manner materially different from that stated at the time it was collected, Fidelis will use commercially reasonable efforts to notify you reasonably prior to such intended use.

14.  Access; Contacting Fidelis.  If you would like to access or update any of your Personal Information, or if you or have any questions about Fidelis' privacy practices, please contact us at webmaster@fidelis-inc.com.