Specifically, this Policy describes:
• The Information That We Collect;
• How We Use the Information We Collect;
• How We Share the Information With Third Parties;
• Security of Information;
• Choices and Rights;
• Children Under the Age of 13; and
• How to Contact Us.
By visiting, accessing and/or using any of the VisitDays Services and/or providing any information toVisitDays, you (the “User”) are consenting to Our use and disclosure of the information We collect or receive as set forth in this Policy, and the User also is agreeing to be bound by this Policy, as well as the Terms andConditions for the VisitDays Services, which are hereby incorporated by reference.
Who is responsible for your Personal Information? For purposes of the European Union General Data Protection Regulation, 2016/679 (the “GDPR”), if the User is in the European Union or EuropeanEconomic Area (“EEA”), VisitDays acts as a data controller with respect to the personal information described in the “The information that We collect” section of this Policy. In this role, VisitDays is responsible for implementing the applicable data protection principles and for safeguarding personal information. Asset forth below, VisitDay is not the data controller for the information collected through Customer Websites (as defined below).
Customer Websites. This Policy may be posted on one of the websites that We power for Our customers (“Customer Website”). In this regard and in connection with aCustomer Website, VisitDays is collecting, using and sharing the personal information of the user of theCustomer Website, on behalf of the VisitDays’ customer (“Customer”), rather than VisitDays. For more information on how the Customer collects, uses and shares their users’ personal information, please contact the Customer. In this case, the Customer is in control of the Customer Website, but is being operated or powered by VisitDays pursuant to the terms of an agreement between VisitDays and the Customer. Subject to the foregoing, this Policy also describes generally how VisitDays uses information in connection with the typical Customer Website.
2. The Information that We Collect
For purposes of this PrivacyPolicy, the term “Student Personal Information” shall mean information that may, alone or in combination with other available information, be reasonably used to identify a current or former student. Student Personal Information may include, but is not limited to, education records covered by the Family Education Rights and Privacy Act (“FERPA”),20 U.S.C. § 1232g.
For purposes of this Policy, the term “User Content” shall mean any content uploaded, submitted, disclosed, stored, sent and/or received while using any of the VisitDays’ Services by anyUser.
A. Information Provided by Schools, Educators andAuthorized
The primary and secondary public and private schools, school districts and other organizations(collectively, the “Schools,” each a “School”) that use the VisitDays Services may provide certain information about their students (“Students”), parents or guardians of Students, and teachers, counselors and/or authorized administrators(“School Authorized Administrator”) (collectively, “Educators”) to create accounts with VisitDays.
In order for the Schools to create accounts, on behalf of their Students, in connection with the VisitDaysMembership, the Schools must provide the following Student PersonalInformation: the Students’ first names, last names, email addresses and telephone/cellphone numbers. Schools, in their discretion, may provide additional Student Personal Information as it determines in its discretion including, without limitation, the Student’s gender, date of birth, current grade, current school and next year school. By providing the Student Personal Information on behalf of its the Students, the School is warranting and representing that it has obtained the requisite consent from the Student and/or parents or guardians of the Student, to the extent required by applicable law including, without limitation, FERPA.
The School may provide information about a Student’s parent or guardian, including, without limitation, the full name, email address and telephone/cellphone number, in order to enable VisitDays to invite such parent or guardian to create an account and review their Student’s information including the Student Personal Information in the VisitDays Services. The Schools may provide the Educators’ first and last names and email address, or Educators, when creating their own accounts, will be required to provide an email address as well as their first and last name. Educators may submit support requests or User Content.
VisitDays collects information from a School or School Authorized Administrator to set up and administer a School account including, without limitation, the following: (A)the School Authorized Administrator’s contact information as well as information about their School relevant to purchasing and setting up accounts such as School’s name, address, billing address, and number of students; and (B) support requests and any other information submitted by a School or School Authorized Administrator.
B. Information Provided by Students
In connection with using any of the VisitDays Services including participating in the VisitDays CollegeAccess Program, the Students may provide a variety of information, which may include certain Student Personal Information as follows: email addresses, telephone/cell phone numbers, mailing addresses, telephone numbers, education/career goals, favorite clusters, interests, skills, test scores, work experiences, volunteer experiences, internship experiences, high school course plan, future readiness plans, and any other information or User Content that the Student chooses, in their discretion, to provide.
C. Information Provided by Colleges, Universities and/or Institutions of Higher Education
VisitDays collects information from colleges, universities and other institutions of higher education (collectively, the “Institution”) that access and/or use theVisitDays Services including those Institutions who have a paid subscription to the VisitDays Membership. VisitDays collects information from Institutions and/or their authorized administrators (“InstitutionAuthorized Administrators”) to set up and administer an Institution account including, without limitation, the following: (A) the Institution AuthorizedAdministrator’s contact information as well as information about theirInstitution relevant to setting up accounts such as the Institution’s name and address; and (B) support requests and any other information submitted by anInstitution or Institution Authorized Administrator.
D. Additional Information Provided by Users
VisitDays may collect the following information directly from the Users:
• Requests for Information. If the User submits a request for information or otherwise contact Us, We collect the User’s request and their identifying contact information (including, without limitation, your name, email address, telephone number and address);
• Support Requests. If a User submits a support request or question, We receive the User’s request/question and their associated identifying contact information;
• Content Submission. If a User submits information on VisitDays’ forms, blogs, social media pages, through file uploads, or via online chats as part of an Event (as defined below), We receive such information and the User’s associated identifying contact information;
• Social Media Profile. We collect information stored on a User’s social media profile that the User authorizes us to access when they use their social media profile to execute features in connection with theVisitDays Services, such as the ability to log into the VisitDays Services using their social media profile credentials;
• Preference Information. We collect information such as preferred time zone or whether to show a dialog on your next visit. We do this to personalize your experience with the VisitDays Services; and
• Event Participation. We may collect information about a User when they participate in an Event including, without limitation, personal information or demographic information provided by the User. As used herein, the term “Event” shall mean an online gathering that includes registration before the event begins, activities between the event’s start and end time, and after the event’s end time.
D. Automatically Collected Information
3. How We Use the Information We Collect
VisitDays may use the information We collect including, without limitation, the Student Personal Information and User Content, to:
• Provide, improve and analyze the VisitDays Services;
• Engage in activity in relation to the VisitDays Services including, without limitation, sending newsletters, updates and/or event invitations;
• Respond to questions, comments, and requests for information and/or provide customer support;
• Provide administrative notices or communications applicable to the User’s use of the VisitDays Services;
• Manage the User’s participation in Events, VisitDays Membership and/or the VisitDays CollegeAccess Program, where the User has signed up for same;
• Maintain a record of theEvents, VisitDays Membership and/or VisitDays College Access Program in which theUser participates including, without limitation, the chat and webinar history and download activity;
• Enable the User to interact with other Users of the Events, VisitDays Membership and/or VisitDays CollegeAccess Program;
• Comply with applicable law and/or regulations;
• Establish, exercise or defend Our rights, or for the purposes of legal proceedings;
• Detect, investigate and prevent activities that may violate the Terms and Conditions or applicable law;
• Administer, troubleshoot and/or secure the VisitDays Services;
• As directed by a School that has licensed the VisitDays Services;
• Log the User’s use of theVisitDays Services for Our own legitimate business purposes, which may include, without limitation, the analysis of usage, measurement of site performance and generation of reports; and
• In connection with, conducting a sale of all or substantially all of Our business or assets, which includes the sale, assignment or other transfer of the User’s information which may include Personal Information and Student Personal Information in connection with such transaction.
VisitDays does not sell or rent Student Personal Information or the User Content provided in the VisitDays Services, including for advertising purposes. In addition,VisitDays does not disclose or provide any of the Student Personal Information or User Content to third parties for any purpose except as set forth in thisPolicy or as directed by a School pursuant to an agreement between VisitDays and the School. To the extent permitted bylaw, VisitDays uses and shares de-identified and/or aggregated information for various purposes including, without limitation, improving the design, features and functionality of the VisitDays Services, for marketing purposes, for general business purposes, and for administrative purposes.
VisitDays also uses School, SchoolAuthorized Administrator, Institution and/or Institution AuthorizedAdministrator information to send information about features on the VisitDaysServices and/or changes to VisitDays’ policies and communicate with Schools about the VisitDays Services including, without limitation, the account, transactions with VisitDays and security alerts.
The Customers may use theVisitDays Services and a Customer Website to process data, and this data may contain personal information of the user of the Customer Website including Student Personal Information. The data that We process in this event is processed on behalf of the Customers, and Our privacy practices are governed by the agreements that We have in place with the specific Customer. If you have any questions or concerns about how your personal information in such data is handled or would like to exercise your rights, you should contact the Customer directly. In this situation, it is the Customer, and sometimes a Third Party, as described above, that controls the personal information including the StudentPersonal Information. We will provide assistance to the Customers to address your concerns in accordance with the terms of Our agreements with the Customers.
VisitDays would like to sendUsers information of Our products or services that may be of interest. If a User has agreed to receive marketing communications from Us, a User may always opt out a later date. The User has the right, at any time, to stop VisitDays from contacting the User for marketing purposes. If the User no longer wishes to be contacted for marketing purposes, you may unsubscribe asset forth in the marketing communications, or please contact Us as set forth in the “Contact Us” section below. If a User opts out of receiving Our marketing communications, you may still receive transactional or administrative emails from VisitDays in connection with the User’s use of the VisitDays Services. You will also continue to receiving marketing communications in connection with aCustomer Website until the User specifically opt out of receiving such marketing communications as well.
Grounds for Using the User’s Personal Information
VisitDays relies on the following legal grounds to process the User’s personal information including the StudentPersonal Information:
• Performance of a Contract. We may need to collect and use the User’s personal information to enter into a contract with the User or to perform Our obligations under a contract with the User;
• Legitimate Interests. We may use the User’s personal information for Our legitimate interests, some examples of which are given above;
• Compliance With Law or Regulation. We may use the User’s personal information as necessary to comply with applicable laws/regulations; and,
• Consent. We may (but usually do not) need the User’s consent to use the User’s personal information including the Student Personal Information. The User can withdraw their consent by contacting us, as set forth below under the “Contact Us” section. In addition, in connection with Users whom are Students participating in an Event and/or theVisitDays College AccessProgram (“Student User”), where the Student User Actively Interacts (as defined below) with another User of the Event and/or the VisitDays College Access Program including an Institution, the StudentUser is consenting to the disclosure of the Student User’s personal information including the Student Personal Information to such other User.
4. How We Share the Information With Third Parties
When a User creates an account for any of the VisitDays Services, VisitDays will collect and retain information about the User, some of which is personal information including theStudent Personal Information.
Institutions pays a fee for the VisitDays Membership, which provides them access to the VisitDays CollegeAccess Program. In addition,Institutions may pay a fee to participate in another Event.In connection with the Student User participating in an Event and/or the VisitDays College AccessProgram, VisitDays only shares the information that the Student User provides through the the VisitDays Services including, without limitation, any StudentPersonal Information if the Student User has Actively Interacted with anInstitution participating in the VisitDays College Access Program and/orEvent. As used herein, the term “ActivelyInteracted” (and variations thereof) shall mean where the Student User actively interacts with the Institution’s profile through the VisitDays Services including, without limitation, by viewing the Institution’s pages, scheduling meetings with the Institution, attending live sessions with the Institution, watching videos provided by the Institution, chatting with the institution and/or downloading any of attachments from the Institution’s pages. In that regard, the Student User has control over which Institutions receive information from the Student User including, without limitation, any Student Personal Information. If the Student User does not want a particular Institution to receive any of the Student’s information, the StudentUser shall not Actively Interact with such Institution.
Where a Student User has Actively Interacted with an Institution through the VisitDays Services, VisitDays will provide the Institution with the following information of theStudent User: (A) the Student User’s first and last names, email address and telephone/cellphone number; (B) any other information provided by the StudentUser in connection with the VisitDays Services, as the School directed theStudent User to provide; and (C) the Engagement Data in connection with theStudent User.
By Actively Interacting with an Institution, the information provided by the Student User through the VisitDay Services may become subject to the policies of the respective Institution after it has been shared, as VisitDays is not responsible for their data privacy standards and practices. Providing additional information beyond what is required at registration is entirely optional, but enables the Student User to better identify themself.
VisitDays may permit certain third party contractors and service providers to analyze usage of the VisitDaysServices, as well as analyze information such as the source address that a page request is coming from, the User's IP address or domain name, the date and time of the page request, the referring website (if any) and other parameters in theURL. VisitDays collects this information in order to better understand the usage of the VisitDays Services, enhance the performance of the VisitDays Services and operate the VisitDays Services. VisitDays may allow third party contractors and service providers to host portions of theVisitDays Services infrastructure, operate various of features of the VisitDaysServices, store content, send emails and store data on VisitDays’ behalf.
Under certain circumstances,VisitDays may disclose personal information including the following:
• To provide technical support or secure the VisitDays Services;
• To detect, investigate and prevent activities that may violate VisitDays’ Terms and Conditions or law;
• As directed by a School that has licensed the VisitDays Services pursuant to an agreement between VisitDays and the School.
VisitDays may also disclose personal information including Student Personal Information or User Content when VisitDays determines, in good faith, that such disclosure is necessary to comply with the law, to cooperate with or seek assistance from law enforcement, to prevent a crime or protect national security, or to protect the interests or safety of VisitDays, Our customers or other Users.
In addition, VisitDays may also share personal information including Student Personal Information or UserContent in connection with a merger, financing, acquisition, bankruptcy, dissolution, transaction, or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of Our business or assets to another company(or in connection with related due diligence). In these circumstances, We will only share such information with a company that has agreed to data privacy standards no less stringent than Our own and after providing advanced notice to the User.
5. Security of Information
VisitDays recognizes the importance of protecting personal information including Student PersonalInformation and User Content submitted through the VisitDays Services. VisitDays has various precautions and safeguards in place to protect the information that Users share with Us from loss, destruction and unauthorized access, use, alteration, and disclosure. These measures including, without limitation, backups, employee restriction to personal information and a security breach policy.
Unfortunately, no security system is perfect, and no data transmission over the Internet can be guaranteed to be completely private or secure. As a result, We cannot guarantee or warrant the security of any information a User transmits to or from the VisitDays’ website and/or any of theVisitDays Services. We are not responsible for circumvention of any privacy settings or security measures We provide. We cannot promise that the User’s personal information will remain absolutely secure in all circumstances.
In addition, the safety and security of the User’s information also depends on the User. Where the User uses a password for access to certain parts of the VisitDays Services, the User is responsible for keeping this password confidential. Users are prohibited from sharing their username and password with anyone. TheUser should provide notice immediately to Us if they believe their account information has been compromised. If a security breach compromises the User’s data, We will provide notifications of the event as required by applicable law.
How long We hold a User’s personal information for will vary and will depend principally on:
• The Purpose for Which We areUsing Your Personal Information: We will need to keep the information for as long as is necessary for the relevant purpose; and
• Legal Obligations: Laws or regulations may set a minimum period for which We have to keep the User personal information.
VisitDays does not safe guard the User’s personal information collected by the Customer when the Customer is acting as the controller of the User’s personal information, including when held by the Customer outside of the VisitDays Services, or a Third Party authorized to join a Customer Website. They are responsible for handling personal information in accordance with their privacy policies and applicable laws.
The personal information in connection with the Customer Website is retained pursuant to the agreement between VisitDays and the Customer, and ordinarily retained while this agreement is in full force. When such agreement ends, VisitDays may be obligated to delete the data from Our database and all the backups.
6. User’s Choices and Rights
The User may have a number of legal rights in relation to your personal information including Student Personal Information that We hold about a User. Depending on the User’s location, the User may have the right to exercise certain privacy rights under applicable laws including:
• Right to Access. The User may have the right to access VisitDays for copies of their personal information. Please note that there may be circumstances in which We are entitled to refuse requests for access to copies of personal information. In particular, information that is subject to legal professional privilege will not be disclosed to the User;
• Right to Rectification. The User may have the right to request thatVisitDays corrects any information that the User believes is incorrect. The User may also have the right to request that VisitDays complete information that the User believes is incomplete;
• Right to Erasure. The User may have the right to request thatVisitDays erase their personal information under certain conditions. Please note that there may be circumstances where the User asks Us to erase your personal information, but We are legally entitled to retain it;
• Right to Restrict Processing. The User may have the right to request thatVisitDays restricts the processing of their personal information under certain conditions. There may be circumstances where the User asks Us to restrict Our processing of the User’s personal information, but We are legally entitled to refuse that request;
• Right to Object to Processing. The User may have the right to object toVisitDays’ processing of their personal information under certain conditions. Again, there may be circumstances where the User objects to Our processing of the User’s personal information, but We are legally entitled to refuse that request;
• Right to Data Portability. In some circumstances, theUser may have the right to receive some personal information in a structured, commonly used and machine-readable format and/or request that We transmit such information to a third party where this is technically feasible. Please note that this right only applies to personal information which the User has provided toUs;
• Right to Withdraw Consent. The User may have the right to withdraw their consent, although in certain circumstances it may be lawful for Us to continue processing the personal information without the User’s consent if We have another legitimate reason (other than consent) for doing so; and/or
• Right to Make a Complaint: The User also has the right to make a complaint to the relevant authorities in the User’s jurisdiction. The User can submit a complaint by contactingUs as set forth in the “Contact Us” section below and include the detailed factual and legal basis supporting the User’s complaint. VisitDays will endeavor to respond to theUser’s complaint within thirty (30) days from the date of the User’s submission.
VisitDays may need to verify the User’s identity prior to complying with any requests hereunder. Please submit the request to VisitDays as set forth in the “Contact Us” section below.
In addition, the User may access, update and amend their personal information including the Student Personal Information included in the User’s online account at any time by logging into their account and making the necessary changes. TheUser may also choose to deactivate their account by contacting Us as set for thin the “Contact Us” section below. WhenWe deactivate the User’s account, the User will be logged out of the VisitDaysServices and the User will no longer be able to log into the VisitDays Services to access information in connection with, without limitation, the User’s communications and other interactions with other Users of the VisitDay Services. Certain information in connection with theUser’s account may be retained after deactivation by VisitDays or by the Institutions who it has already been shared with pursuant to this Policy.
VisitDays, like many other websites, may passively collect information about the User's browsing activities using cookies and similar technologies (internet tags, web beacons, and navigational data collection), as further described in VisitDays “Cookies and Similar Technologies Policy”. VisitDays collects this information about the User’s browsing activities to (A) present and improve the content and functionality of the VisitDays Services; (B) deliver theVisitDays Services to the User; (C) analyze use of the VisitDays Services; and(D) provide the User with a more personal and interactive experience with theVisitDays Services.
We rely on the User’s express opt-in consent for the use of analytic and marketing cookies and similar technologies. The legal basis for processing of strictly necessary cookies is Our legitimate interests in the proper administration of the VisitDays Services and Our business.
8. Children Under the Age of 13
The VisitDays Services are not intended for children including, without limitation, students under thirteen(13) years of age. No one under the age of thirteen (13) may provide any information, personal or otherwise, to or through the VisitDays Services. VisitDays does not knowingly collect personal information from children under the age of thirteen (13) in accordance with the Children’sOnline Privacy Protection Act (“COPPA”). If you are under the age of thirteen (13),do not use or provide any information through the VisitDays Services or on or through any of its features or provide any information about yourself to Us, including your name, address, telephone number, email address, or any screen name or user name you may use. If We learn we have collected or received personal information from a child under the age of thirteen (13) without verification of parental consent, We will delete that information. If you believe We might have any information from or about a child under the age of thirteen (13), please contact Us as set forth in the “Contact Us” section below.
9. Third-Party Services.
Certain third-party products or services may be available for Customers and/or Users to choose to integrate within or use within the VisitDays Services. A Customer and/or User is not required to use such additional products in the VisitDays Services. Before electing to use such third-party services, the Customer and/or User should review the terms, policies and practices of the third-party products and services to understand their terms and policies with respect to any personal information, including StudentPersonal Information, they may collect. We strive to make available third-party services that will be useful to Customers and/or Users, but We are not responsible for their data and privacy practices, including with respect to personal information.
10. Changes to this Policy
11. How to Contact Us
For more information aboutVisitDays’ privacy practices, if you have questions about this Policy, or ifyou wish to exercise your rights or make a complaint about how We handled personal information about you, please contact Us using the contact details below for further assistance:
228 Park Avenue S
NewYork, New York 10003
TelephoneNumber: (888) 508-1115