Effective Date: March 20, 2024
If you are a resident of California, Colorado, Connecticut, Utah, or Virginia, please see our U.S. State Privacy Notice for additional information about our data activities, the privacy rights available to you, and how to exercise them.
1. INTRODUCTION
At SLM Education Services, LLC and its subsidiaries and affiliates, including any successor entities if we rebrand our business under a different name (collectively, “we”, “our”, or “us”), we care about the privacy and security of your information. This Privacy Policy (this “Privacy Policy”) contains details about how we collect, use, store, disclose and otherwise process certain information, including your personal information. SLM Education Services, LLC may also be referenced as “Education Services”.
This Privacy Policy applies to information we collect and process, including information regarding:
“Services” also include any interactive features, widgets, plug-ins, applications, content, downloads and/or other online or offline services that we own and control (including those made available through a Site), and in each case wherever this Privacy Policy is posted. This Privacy Policy describes the privacy practices of our Services (as defined in our Terms of Use), and anywhere we display or reference this Privacy Policy.
Not Covered by This Privacy Policy
This Privacy Policy does not apply to any third-party websites, services, products or mobile applications maintained by other companies or entities, which may be linked from our Sites or Services. This Privacy Policy generally applies to our processing of the personal information of all other individuals.
Aggregate and Non-identifiable Information
Notwithstanding anything else in this Privacy Policy, we may collect, use, share, disclose, and otherwise process aggregate, anonymous, and in some cases de-identified information for research, marketing, analytics, and other purposes. Where we use, disclose or process de-identified information, we will maintain and use this information in de-identified form and not to attempt to reidentify the information, except in accordance with applicable privacy laws.
2. SOURCES OF PERSONAL INFORMATION
In this Privacy Policy, the term “personal information” refers to information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual, as well as to information defined as “personal information,” “personal data,” “personally identifiable information,” and other similar terms under applicable privacy laws.
You can visit our Sites and use certain Services without registering. However, in certain circumstances (e.g., to create an account or use certain Services), you must provide us with certain personal information. The personal information that we collect varies depending upon your use of our Services and our interactions with you.
We have access to/collect Personal Information:
3. WHAT PERSONAL INFORMATION DO WE COLLECT?
The categories of Personal Information we may collect are outlined below:
Category of Personal Information |
Identifiers and contact information (such as name, user name, alias, phone number, address, email address, social security number, IP address, or cookie ID, BUID, device ID, third-party platform identifiers and other online or unique identifiers). |
Personal Records (such as account and profile information, and customer records that contain personal information, employment, employment history, such as name, address, telephone number, year in school, education). |
Personal Characteristics or Traits (such as age, marital status, sex, sexual orientation, veteran or military status, racial or ethnic origin, religious or philosophical beliefs, union membership or genetics data) |
Transaction / Commercial Information (such as products or services used, purchased, or considered; Third-Party Partners’ or Third-Party Digital Businesses’ products or services considered; and other purchasing or consuming histories or tendencies provided by business and marketing Vendors) |
Biometric Information (such as fingerprints, voice, and facial recognition). |
Usage Data (such as browsing history, clickstream data, search history, access logs, information regarding your interactions with Sites and Services and our marketing emails, newsletters, and online ads, and other usage data related to your use of the Services, such as language and preferences, statistics, click paths, preferences and friends, as well as your comments, posts, and interactions in any forums and communities). |
Geolocation Data (such as when you enable location-based features on your device, when we may infer your rough location (such as zip code) as part of the Sites, and location information about a particular individual or device, such as device location information for mobile Users). |
Audiovisual and Similar Information (such as audio, electronic, visual, or similar information, photographs and images (e.g., that you provide us or post to your profile), call recordings (e.g., of customer support calls), and User photos submitted (such as profile images)). |
Professional or Employment Information (such as your title, affiliated organization, professional expertise and experience, and education related information) |
Non-public Education Records (such as education institution transcripts you may upload yourself into your scholarship search account.) |
Inferences from Personal Information Collected (such as information we collect about you that we combine and use to derive other information and inferences about you. This includes inferences drawn from other personal information that we collect to create a profile based on your account and activities, that reflect your preferences, characteristics, behavior, attitude, and abilities related to the Services and Sites). |
Account information and password (we may store your account log-in in combination with a password in our systems.) |
Sensitive Information (such as government-issued identification numbers, account information and passwords, information regarding race, ethnicity, precise geolocation and religious affiliation that you voluntarily provide when you utilize our education products and services, and information regarding an individual’s health). |
4. HOW DO WE USE YOUR PERSONAL INFORMATION?
We may use your personal information for any of the following purposes:
You may opt out of certain Marketing Communications by visiting this page or by contacting us at info@myscholly.com or help@nitrocollege.com. For additional information regarding additional privacy opt-out rights you may have, please visit our Right To Opt-Out Of Sales/Sharing/Targeted Advertising section in our U.S. State Privacy Notice.
5. TO WHOM DO WE DISCLOSE YOUR PERSONAL INFORMATION?
We may disclose your personal information to the following types of third parties and as noted above in Section 4:
You can limit how we disclose your Personal Information by managing your communications preferences, exercising applicable privacy opt-out rights, or by contacting us at info@myscholly.com or help@nitrocollege.com. You may also opt out of marketing communications by clicking on the unsubscribe link provided in such communications. You may not opt out of transactional communications (e.g., account verification, changes/updates to features of the Sites or services, and technical and security notices).
6. ONLINE TRACKING AND ADVERTISING
We collect certain usage information through a variety of tracking technologies, including cookies, Flash objects, web beacons, file information and other similar technology (collectively, “Tracking Technologies”), and we may use Vendors, including social media platforms, analytics companies, data brokers, third-party advertisers, and other technology companies that offer digital advertising services (“Third-Party Digital Businesses”), to collect information using Tracking Technologies.
Information collected using Tracking Technologies includes personal information described in the table above. We may share, or we may permit Third-Party Digital Businesses to collect personal information about your use of our Sites over time so that they may display ads that may be relevant to your interests on our Sites as well as on other websites or apps, or on other devices you may use. We or the Third-Party Digital Businesses use this information to make the advertisements you see online more relevant to your interests.
Depending on your browser or mobile device, you may be able set your browser to refuse all cookies or notify you of Tracking Technologies by actively managing the settings on your browser or mobile device (as described below). If you delete your cookies or if you set your browser or device to decline these technologies, some services may not function properly. Our Sites do not currently change the way they operate upon detection of a Do Not Track signal, but see “Global Privacy Control” in the U.S. State Privacy Notice.
You can set your browser to transmit a “global privacy control” (“GPC”) signal or another approved “universal opt-out mechanism” to opt out of targeted advertising and sales (as defined under applicable law). If we detect that your browser is transmitting a GPC or other recognized universal opt-out signal when you visit one of our Sites, we will opt that browser on your device out of non-essential cookies and pixel tags on that Site. Please note that if you come back to that Site from a different device or from a different browser on the same device, you will need to apply the signal for that browser and/or device as well.
Clear gifs help us better manage what content is effective. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of web users. In contrast to cookies, which are stored on a user’s computer hard drive, clear gifs are embedded invisibly on web pages or in emails and are about the size of the period at the end of this sentence. We use clear gifs in our HTML-based emails to let us know which emails have been opened by recipients. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns. We tie the information gathered by clear gifs in emails to our users’ personal information.
We and our third-party providers use cookies, clear GIFs/pixel tags, JavaScript, local storage, log files, and other mechanisms to automatically collect and record information about your browsing activities, application activity, and use of the Services. We may combine this "activity information" with other personal information we collect about you. Generally, we use this activity information to understand how our Services are used, track bugs and errors, provide and improve our Services, establish matchmaking, verify account credentials, allow logins, track sessions, prevent fraud, and protect our Services, as well as for targeted marketing and advertising, to personalize content and for analytics purposes.
Online Analytics
We also use various types of online analytics, including Google Analytics, a web analytics service provided by Google, Inc. (“Google”), on our Service. Google Analytics uses cookies or other tracking technologies to help us analyze how users interact with and use our services, compile reports on the related activities, and provide other services related to Site and app activity and usage. The technologies used by Google may collect information such as your IP address, time of visit, whether you are a return visitor, and any referring site or app. The information generated by Google Analytics will be transmitted to and stored by Google and will be subject to Google’s privacy policy. To learn more about Google’s partner services and to learn how to opt-out of tracking of analytics by Google, click here.
Tracking Technologies – Your Additional Choices
Preferences: We make available multiple ways for you to manage your preferences regarding targeting cookies, advertising, and personalization:
You can review or change your preferences for most cookies on our Sites (other than those that are necessary to the proper functioning of our Sites) by adjusting your cookie settings.
Cookie management: You have choices about how cookies are used during your visits to our Sites. You may be presented with a banner where you can opt in to or out of certain cookie categories. You may not opt out of “strictly necessary” cookies, which ensure our Sites work properly. If you do not make any selections by either clicking the “x” to close the banner or by navigating away from the initial web page, your choices will be captured as opted out of all cookies except strictly necessary cookies. You can change your choices at any time within our Sites.
Browser Settings: In addition, you can exercise control over browser-based cookies by adjusting the settings on your browser, and mobile devices may offer ad and data limitation choices. Please note that when you use cookie control tools, you will have to change your settings for each browser and device you use, and your limitation on cookies can limit the functionality of online services you use, including our services.
In addition, third party tools may enable you to search for and opt-out of some of these trackers, such as the Ghostery browser plug-in available here.
In addition, your mobile device settings may allow you to prohibit mobile app platforms (such as Apple and Google) from sharing certain information obtained by automated means with mobile app developers and operators such as us.
Ad Industry Tool: Certain third parties may collect personal information in association with your use of our online services may use such information for advertising, analytics and other purposes, and may also sell that personal information downstream. Such third parties may provide you the opportunity to opt-out of such sales. Please visit here to opt-out of participating third parties’ sale of your personal information. Please note that you must opt out on every device and browser you use in order to effectuate your “Do Not Sell” requests from these parties. However, opting out does not mean you will stop seeing ads and you may continue to still see interest-based ads. To learn more about interest-based advertising and additional opt-out choices related to it, please visit these websites (here and here).
Clearing cookies or changing settings may affect your choices described above and you may have to opt-out separately via each browser and other device you use. Cookie-enabled opt-outs signals may no longer be effective if you delete, block or clear cookies. We do not represent and are not responsible for the completeness, accuracy or effectiveness of any third-party notices, tools, or choices.
Personalized Advertising Choices:
You can opt out of personalized ads from third parties on our Sites through our opt-out tool included in our cookie policy here. However, opting out of participating ad networks does not opt you out of being served advertising. You may continue to receive generic or "contextual" ads on our Services. You may also continue to receive targeted ads on other websites, from companies that do not participate in the above programs.
In addition, if you withdraw consent or otherwise object to our collection, use, and disclosure of your personal information, you may not be able to use the Services or Sites.
7. YOUR PRIVACY RIGHTS
If you are a resident of California, Colorado, Connecticut, Utah, or Virginia please click here to learn about your consumer privacy rights and how to exercise them. We will only use Personal Information provided in a privacy rights request to review and comply with the request.
To opt out of the Sale, Sharing, or processing of your Personal Information for Targeted Advertising or to limit the use and disclosure of your Sensitive Personal Information, visit the opt-out page by following the Link below.
8. LINKS TO AUTHORIZED THIRD PARTY WEBSITES AND SERVICES
Our Sites may permit you to access third party websites directly that we do not own or control. It is important to remember that if you link to a third-party website from our Sites, that third-party’s privacy policy and its terms and conditions of use apply to you. We encourage you to learn about each third-party’s privacy policy before sharing your personal information with them. We are not responsible for the privacy practices or the content of the sites to which we link, including their collection and use of your information by these third-party sites.
In addition, our Services and/or Sites may include or incorporate social media and other third-party features (e.g., widgets, buttons, and plugins), which are operated by third parties, such as educational institutions, Facebook, Steam, Twitch, Twitter, Instagram, YouTube, and others. These features are hosted by the respective third-party operator even though they appear on our Services or Sites, and the third party may collect your IP address, URL, date and time stamp, browser details, and the like, subject to their own privacy policies.
If you provide your Personal Information on a co-branded page, your Personal Information may be shared with the Authorized Third Party. Please review the Authorized Third Parties’ privacy policy and terms of use prior to providing any Personal Information. If you have any questions regarding the privacy policies of our Authorized Third Parties, please contact the Authorized Third Parties directly using the channels provided by the Authorized Third Parties.
9. MESSAGING (SMS) SERVICES
We use a Vendor to provide a text message marketing program (the “Messaging Service”) to you. To review the terms and conditions associated with the Messaging Service, please review our SMS Terms & Conditions.
Choices and Controls
If you do not wish to receive texts (SMS) communications from us, whether on our behalf or on behalf of a third party, you can opt-out of receiving further commercial text messages by responding to any of our text messages with any of the following replies: STOP, END, CANCEL, UNSUBSCRIBE, or QUIT. For additional opt-out information, please review our Terms of Use.
Customer Care
If you are experiencing any problems or have any questions regarding Scholly, please visit https://myscholly.com/contact-us and submit the form with details about your problem or your request for support, or email info@myscholly.com. If you are experiencing any problems or have any questions regarding Nitro, please visit https://www.nitrocollege.com/contact and submit the form with details about your problem or your request for support, or email help@nitrocollege.com.
10. CHILDREN’S PRIVACY AND MINORS
The Services and Sites are not intended for minors under the age of 13. We do not knowingly request or collect personal information from children younger than 13 years of age. If you believe that we have collected personal information from a child under 13, please contact us as set forth below, and we will take action as necessary to securely delete such information. All other minors may only use the Services with the involvement, supervision and approval of a parent or legal guardian.
11. PROTECTION OF INFORMATION
We take a variety of reasonable physical, technical, administrative, and organizational security measures to protect against possible breach of our Services, taking into account the sensitivity of the information we collect to protect your personal information against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access. However, no website or Internet transmission is completely secure. Thus, we cannot and do not guarantee that unauthorized access, hacking, data loss, or other breaches will never occur. While we strive to protect your personal information against unauthorized use or disclosure, we cannot ensure or warrant the security of any information you provide. We urge you to take steps to keep your personal information safe, such as choosing a strong password and keeping it private, enabling multifactor authentication (where available), as well as logging out of your User account and closing your web browser when finished using the Services.
If you have reason to believe that your personal information is no longer secure (for example, if you feel that the security of your account has been compromised), please contact us immediately at please contact us immediately at Help@NitroCollege.com.
12. UPDATES
This Privacy Policy is current as of the Effective Date set forth above. We may change this Privacy Policy from time to time, so please be sure to check back periodically. Occasionally, we may update this Privacy Policy to allow us to accommodate new technologies, industry practices, legal, regulatory or operational requirements or for other purposes.
If we do, we will change the "last updated" date at the top of the Privacy Policy and the revised policy will be posted to this page so that you are aware of the information we collect, how we use it, and under what circumstances we may disclose it. Under certain circumstances (for example with certain material changes or where it is required by applicable privacy laws) we will provide notice to you of these changes and, where required by applicable law, we will obtain your consent. Notice may be by email to you, by posting a notice of such changes on our Services or Sites, or by other means consistent with applicable law. Your continued use of the Services or Sites after any such updates take effect will constitute acknowledgement and (as applicable) acceptance of those changes.
13. CONTACT US
If you have any questions or comments about this Privacy Policy or our privacy practices generally, you are welcome to contact us at:
Customer Privacy
SLM Education Services, LLC
P.O. Box 3010
Wilmington, DE 19804-0010
privacy@salliemae.com
14. Email Marketing Choices
Our marketing emails tell you how to opt out of receiving further marketing emails. If you opt out, we may still send you non-marketing emails, such as emails about your accounts and our business dealings with you, and, as allowed by applicable law, requests for your participation in surveys. You may also contact us here at any time to let us know that you no longer wish to receive further marketing emails from us.
15. Retention of Personal Information
We may retain information as required or permitted by applicable laws and regulations, including to honor your choices, for our records purposes and to fulfill the purposes described in this Privacy Policy. We may retain information for our legitimate interests and essential business purposes, such as operating, maintaining and improving our Services; complying with our legal obligations; and exercising our legal rights and remedies, including enforcing our Terms of Use. Our retention of information is based on many factors, such as your relationship with us (for example, if you are a current customer); the nature of the information; compliance with our legal obligations; and defending or resolving actual or anticipated legal claims.
16. No Expectation of Privacy
You should have no expectation of privacy as to any information you post or display in our Sites.