Scope of this Notice

At GreenLight Credentials, LLC (“GLC”) we recognize the importance of protecting the privacy of personally identifying information and believe that use and sharing of it is important to our mission of helping students progress in their education and, ultimately, employment success.

This Notice explains how GLC collects, uses, maintains, shares, and protects your information when you utilize the GLC platform and associated services (the “Site"), as well as when you or one of your education institutions provide your personally identifying information to GLC online and offline when you utilize GLC’s services.

Children's Privacy

The Site is intended for use by education and workforce development professionals, other adults, high school and college/university students engaged in college and career planning, and their parents. The collection of personally identifying information from high school students is intended for students 13 years old or older only. The Site is not intended to be used by children under the age of 13. If you are under the age of 13, please do not use this Site.

Information GLC Collects

Personally identifying information is information that can identify you, such as your name and address. It does not include anonymized, aggregate, or statistical information. Based on your relationship with us, you may be asked to provide certain personally identifying information as described below. Certain information is requested but not mandatory; GLC will identify which information is required.

Site registration and services. When you register with the GLC Site, we may ask you to provide certain information including your name on school record, former/maiden name, home address, email address, telephone number, date of birth, gender, race, ethnicity, citizenship status, year of high school graduation or equivalent, grade in school, high school academic information.

Student records. The confidential collection, storage of student records, transcripts, credentials and other educational attainment information from education institutions and other education providers (“Student Records”) for the purpose of supporting Registered Users use of the Site and associated services.

• International: If you are located outside the United States, some of the information GLC collects and stores could be classified in your home country as sensitive personal data or sensitive information according to your country’s data protection laws. This may include age, gender, biometric data, race, ethnicity, health data such as a physical or learning disability, as well as information related to your background, including, political organizations and religious organizations.

• Website visitors. When you visit the Site, GLC may collect and store your internet protocol address along with other non-personally identifiable information described below. When you are requesting materials or information from GLC, we may ask you to provide your name, job title, address, email address, birth date, and other personally identifying information, and your need for GLC materials. If you are purchasing specific services, GLC may ask for your credit card information in order to facilitate your purchase.

• GLC Marketplace. The Marketplace is a free and optional service to students. The Marketplace is driven and controlled by your consent and opt-in selections. For those users selecting to opt-in and consent to contact from schools, colleges, universities, and employers, GLC may share Student Records with participating schools, colleges, universities, and employers. But, the decision to share personally identifying information to any schools, colleges, universities, and employers is controlled by you through consents and opt-in selections.

• Suppliers of Student Records to GLC. If you are a supplier of Student Records to GLC, such as a high school or college administrator, GLC may request your name, address, email address, telephone number, tax identification number, date of birth, bank account information, and other personally identifying information for identification and verification purposes, among other things.

Non-personally Identifying Information

When you visit the Site, GLC may collect and store general Internet data, including your browser type, date and time of access, which web pages on the Site you visited, the referring Uniform Resource Locator (URL), and how long you spent on each page. This information may be collected to assist us in administering and making improvements to the Site, to enhance security, and for statistical analysis. GLC may employ other companies and individuals to facilitate these services (e.g., maintenance, analysis, audit, development), who will have limited access to this data and only use it to perform those services on our behalf. Although we do not normally use technical data to identify individuals, sometimes individuals can be recognized from it, either alone or when combined or linked with user data. In such situations, technical data can also be considered to be personal data under applicable law and we will treat the combined data as personal data

Non-personally identifying information also includes information collected through the Site, through online assessments, surveys and consents that is maintained by GLC in aggregate or de-identified form(s). This information is collected and may be used for research purposes, to inform public policy and advocacy, and for reporting purposes such as to education institutions, state agencies, and businesses.

How GLC Uses Personally Identifying Information

Personally identifying information collected through the Site may be used to:

• Provide requested services to you, and communicate with you regarding programs and services;

• Process your requests for GLC, programs, services, or information, and to communicate with you regarding such requests;

• Maintain your account, verify your identity, process your requests, and process any payments associated with your use of the Site;

• Administer, review and/or improve the Site, GLC programs or services;

• Conduct research and analysis consistent with GLC’s mission;

• Invite you to participate in surveys consistent with GLC’s mission, including surveys regarding GLC programs and services; and

• Provide you with marketing information about GLC programs, services, or special offers from GLC.

• Match you to employment opportunities and connect you to interested employers; and

• Match you to educational opportunities and connect you to interested educational institutions and providers, scholarship agencies and offers, and any other providers of interest.
  

Information Sharing and Disclosure

Consistent with GLC’s mission, it is important to share information with those who have a legitimate reason to use it, or who can provide educational or career opportunities to you. GLC will not sell personally identifying information we collect through this Site. GLC will not share personally identifying information without your explicit consent, nor disclose personally identifying information except as described in program or service specific terms and conditions, or as set forth below.

 Generally

 GLC may disclose personally identifying information:

• To GLC subsidiaries and affiliates;

• To others providing services to GLC or as necessary to deliver GLC’s programs, and services. This includes information needed to verify an individual’s identity or for security purposes.

• As required by law, for subpoena or other legal processes;

• As necessary to investigate, take action on, or prevent suspected or actual illegal activities, fraud, or potential threats to safety or personal physical safety; and

• To another company that acquires GLC or its assets, which will have responsibility for your personally identifying information, as described in this Privacy Notice.

GLC Site and Services

When you utilize GLC’s Site and services, GLC may disclose personally identifying information upon your request or consent to:

• Schools, school districts, colleges, universities, and employers;

• Schools, school districts, colleges, universities state entities and/or their agents or representatives for educational, research, and reporting purposes;

• Parents or legal guardians of minors under the age of 18;

• Certain state and federal scholarship programs and agencies; and

• In limited situations, researchers conducting research consistent with GLC’s mission. Researchers who receive any personally identifying information are required to protect the confidentiality and security of this information.
  

Communications from Organizations participating in the GLC Marketplace

You will receive communications from organizations participating in the GLC Marketplace subject to your prior consent and opt-in selections. These organizations are required to maintain strict confidentiality. At any time, you may withdraw your consent or opt-out to receive Marketplace communications from participating organizations.

International – Onward Transfer of Personally Identifying Information

If you are utilizing GLC’s Site and services outside the United States, or requesting information about GLC services, note that your personally identifying information may be transferred outside of your home country to the United States to GLC or a third party service provider, and will be subject to use and disclosure under the laws of the United States. It may also be accessible to law enforcement and national security authorities in the United States. When you voluntarily register for GLC Site and services, you provide personally identifying information to us. If you do not provide mandatory personally identifying information, such as name, gender, address and date of birth, you may not be able to complete certain online transactions, or access or benefit from the GLC Site and services.

Marketing by Others

GLC honors your preferences with regard to sharing your personally identifying information with other organizations for their recruiting and marketing purposes. You will be given the choice prior to having your personally identifying information shared with these other organizations for their recruiting and marketing purposes.

Cookies and Web Beacons

When you access the Site, certain non-personally identifying information is automatically logged. This information may include your operating system, screen settings, Web browser software, and referring website, if any. It is used for system improvement and administration, security, statistical analysis purposes, and other internal business purposes.

The Site uses service providers for analytics purposes. These providers collect information about you anonymously and report website trends without identifying individual visitors. These service providers use their own cookies to track visitor interactions. Website owners can view a variety of reports containing aggregate information about how visitors interact with their website so they can improve their website. GLC does not control the cookies and their use may be governed by the privacy policies of the service providers employing these cookies.

Cookies are small text files that a website can send to a user's browser for storage on the hard drive. Cookies can make use of the Web easier by saving and administering status, preferences, and other user information. Cookies used by the Site do not contain your personally identifying information.

The Site also uses Web beacons, which are small strings of code that deliver a graphic image on a Web page or in an email message for the purpose of transferring data. GLC may use cookies and Web beacons to route users through the Site, customize users' experiences on the Site, to help us send you information about programs and services, and to improve the Site.

Most browsers are set to accept cookies but users can change the setting to block cookies. Although disabling cookies will not interfere with your ability to access the Site, users will need to accept cookies to use certain services on the Site, including test registration. Users can disable the ability of Web beacons to capture information by blocking cookies.

Links and Websites

The Site may contain links to non-GLC affiliated websites. GLC does not control the privacy policies or practices of these websites. You should review the privacy policy of the non-GLC affiliated website before providing any information through these websites. GLC is not responsible for the content or practices of any linked non-GLC affiliated websites, and provides these links solely for the convenience and information of visitors to the Site.

Choice, Opt-Out, and How GLC Responds to Do Not Track Signals

GLC strives to provide you with choices about our use of your personally identifying information. As a user of the Site, as well as for offline purposes, you decide whether to proceed with activities that request personally identifying information. However, if you do not provide the requested information you may not be able to complete certain online transactions, have access to, or benefit from certain GLC programs or services.

GLC occasionally uses your personally identifying information to contact you regarding GLC programs and services. You will be provided instructions on how to opt out of receiving further marketing communications by email. If you opt-out of receiving these recruiting and marketing communications, note that you will still receive program-related messages and similar transactional communications by email about your registration for an GLC program or other services and programs in which you participate.

With respect to the Site and Do Not Track Signals, GLC conducts conversion tracking with other websites such as Twitter and Facebook to collect data for purposes of tracking your use of GLC advertisements on those websites. We also target GLC’s advertisements on social media websites, such as Facebook and Twitter. This means that after visiting our Site, if you later log into Facebook or Twitter, an GLC advertisement may appear. To learn more about your choices regarding online tracking, please visit these sites:

• http://www.aboutads.info/choices/

• https://www.usa.gov/optout-instructions
  

Access, Correction, and Deletion of Personally Identifying Information

If you need to update your contact information (address, email address and/or telephone number), please contact GLC Customer Service at (877) 452-0470 or email support@glcredentials.com

Depending on your country, state, or locality of residence you may have additional rights regarding your personal data. These rights may include the right to request deletion of some or all of your personal data, the right to request access to or correction of your personal data, the right to withdrawal your consent to our use of your personal data, the right to request restrictions on how we use or share your personal data, and the right to lodge a complaint with your local supervisory authority. For requests of this type, please contact GLC’s Data Protection Official listed below.

GLC will seek to meet all requests to delete personally identifying information unless it is required to be retained for contractual or legal reasons as described in this Privacy Notice. Please be aware that all Student Records are maintained by GLC indefinitely and closing your account does not delete your Student Records.

GreenLight Credentials, LLC.
Attn: General Counsel
13355 Noel Road, Suite 1100
Dallas, TX 75240

support@glcredentials.com

Retention of Information

GLC will retain your information for as long as is necessary to fulfill any of the uses identified in this Privacy Notice or to comply with applicable legal obligations.

Security and Confidentiality

Protecting the personally identifying information through the use of reasonable administrative, physical and technical safeguards is important to GLC. We use secure sockets layer (SSL) transmission, a protocol for establishing a secure connection for transmitting your personally identifying information. GLC has security protocols and measures in place to protect your personally identifying information from unauthorized access, alteration, and unlawful disclosure. In addition, GLC leverages technical controls such as Encryption of data at rest and transit, Password policies, Firewalls, Intrusion detection, etc. When GLC disposes of personally identifying information, we take reasonable measures to protect against unauthorized access to the information. We audit the application of our security measures and we ask third party experts to review our security controls against international standards to help us to monitor our security level.

Should a security breach occur that is likely to risk the data privacy of Users, we will inform the relevant Users and other affected parties, as well as relevant authorities as required by applicable data protection laws.

Changes to this Notice

GLC reserves the right to modify this Privacy Notice at any time. If GLC makes material changes to this Privacy Notice, the changes will be posted on this Site to alert you.

Last Updated: March 28, 2019

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