Effective as of: December 1, 2011
Date of Last Revision: December 1, 2011
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).
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.
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.
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.
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.
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.
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 email@example.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.
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 firstname.lastname@example.org.