Privacy

This Privacy Policy and Privacy Shield Policy Statements explain the policies of Loan Science, LLC and Student Connections, LLC (altogether, “Loan Science,” “Student Connections,” the “Companies,” “us,” “We,” “we,” “Our,” or “our”), regarding any personally identifying information you might supply to us.

Privacy Policy

The Companies respect the privacy of our customers and visitors to this site, and we are committed to protecting user privacy on the Internet.  We will protect personal information you share with us through this site in the same way that we protect your personal information in all the other ways in which we interact with you.

We may use “cookies” to enhance your online experience.  Cookies are pieces of data that we place on your computer’s hard drive to help us identify you.  The cookies that we place on your hard drive allow us to immediately know who you are when you return to the site.  They are not used to collect any nonpublic personal information.

Our web servers automatically recognize your domain name, but not your e-mail address.  We do not collect nonpublic personal information when you visit our sites, unless you expressly provide it to us.  The information we do collect from this site and other sites owned by the Companies (such as domain name, number of page views, pages visited, and length of user session) may be combined to analyze how the site is used.  This information is then used to improve the usefulness of the site.

The Companies only collect limited “personally identifiable information” on this site and other sites owned by us.  Personally identifiable information is information about you, such as your name, address, telephone number, and e-mail address.  We gather this information so we can deliver the products and services you request and to administer our business.  This information also helps us design and offer new products and services to better service you.  We also collect certain information because federal or state law requirements. Please note that neither this site nor any site owned by the Companies can respond to “do not track” signals or other similar mechanisms.

The types of personally identifiable information and the ways in which we use such information collected on this site and other sites owned by the Companies include the following:

  • Contact information such as your name, address, e-mail address, or telephone number (land-line or cellular).  We may use this information, for example, to send you information that you request or to contact you about your accounts.

The Companies carefully limit and control sharing of personally identifiable information collected on this site and other sites owned by us.  We may share this information with the following types of entities:

  • In general, the Companies do not sell customer lists or individual customer information.  We will, however, exchange personal information about you with your lender, your school, the U.S. Department of Education, or other departments of state and federal government, as permitted by federal law and regulations.

Unless prohibited by law, you have the right, upon reasonable notice, to view any personally identifiable information collected from you through your visits to or use of this site and other sites owned by the Companies, to make corrections to such information, if necessary, or to request that such information be removed from our systems.  You may make this request by contacting us at the address listed at the end of this Privacy Policy Statement.

Our site may also permit you to access non-affiliated sites directly from our site and other sites owned by the Companies to provide you with value-added information, functionality, or services.  If you provide personal information via these sites, your information may be shared with these third-party entities.  It is also important to remember that, if you link to a non-affiliated site from our site, that party’s privacy policy and its terms and conditions will apply to you.  We encourage you to learn about each third party’s privacy policy before sharing personal information with them.

Please remember that this Privacy Policy Statement applies only to sites owned by the Companies.  It does not apply to sites that may be linked to or from our sites to any other company or organization.  If you link to a non-affiliated site from our site, that party’s privacy policy and its terms and conditions may apply to you.  We encourage you to learn about each third party’s privacy policy before giving personal information to them.

The effective date of this Privacy Statement is July 8, 2016.  We reserve the right to change our Privacy Policy Statement.  Any such changes will be reflected in the updated version displayed on this site.

The Companies are subject to the investigatory and enforcement powers of, the Consumer Financial Protection Bureau, Federal Trade Commission, Federal Communication Commission, The Federal Reserve, Securities and Exchange Commission, Federal Deposit Insurance Corporation, Secretaries of State, and all state licensing agencies.

For additional information about this Privacy Policy Statement, please write: Director of Corporate Compliance, 2201 Donley Drive, Suite 110, Austin, TX 78758.

Privacy Shield Policy

Loan Science complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce.  Loan Science has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF.  Loan Science has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF.  If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern.  To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

All Loan Science employees who handle Personal Data from Europe and Switzerland are required to comply with the Principles stated in this Policy.

Capitalized terms are defined in Section 14 of this Policy.

1. SCOPE

This Policy applies to the processing of Individual Customer Personal Data that Loan Science receives in the United States concerning Individual Customers who reside in the European Union and Switzerland. Loan Science provides products and services to businesses and consumers.

This Policy does not cover data from which individual persons cannot be identified or situations in which pseudonyms are used. (The use of pseudonyms involves the replacement of names or other identifiers with substitutes so that identification of individual persons is not possible.)

2. RESPONSIBILITIES AND MANAGEMENT

Loan Science has designated the Legal Department to oversee its information security program, including its compliance with the EU and Swiss Privacy Shield program. The Legal Department shall review and approve any material changes to this program as necessary. Any questions, concerns, or comments regarding this Policy also may be directed to contact@loanscience.com.

Loan Science will maintain, monitor, test, and upgrade information security policies, practices, and systems to assist in protecting the Personal Data that it collects. Loan Science personnel will receive training, as applicable, to effectively implement this Policy. Please refer to Section 7 for a discussion of the steps that Loan Science has undertaken to protect Personal Data.

3. RENEWAL / VERIFICATION

Loan Science will renew its EU-US Privacy Shield and Swiss-US Privacy Shield certifications annually, unless it subsequently determines that it no longer needs such certification or if it employs a different adequacy mechanism.

Prior to the re-certification, Loan Science will conduct an in-house verification to ensure that its attestations and assertions about its treatment of Individual Customer Personal Data are accurate and that the company has appropriately implemented these practices. Specifically, as part of the verification process, Loan Science will undertake the following: (a) Review this Privacy Shield policy and its publicly posted website privacy policy to ensure that these policies accurately describe the practices regarding the collection of Individual Customer Personal Data; (b) Ensure that the publicly posted privacy policy informs Individual Customers of Loan Science’s participation in the EU-US Privacy Shield and Swiss-US Privacy Shield programs and where to obtain a copy of additional information (e.g., a copy of this Policy); (c) Ensure that this Policy continues to comply with the Privacy Shield principles; (d) Confirm that Individual Customers are made aware of the process for addressing complaints and any independent dispute resolution process (Loan Science may do so through its publicly posted website, Individual Customer contract, or both); and (e) Review its processes and procedures for training Employees about Loan Science’s participation in the Privacy Shield programs and the appropriate handling of Individual’s Personal Data

Loan Science will prepare an internal verification statement on an annual basis.

4. COLLECTION AND USE OF PERSONAL DATA

Loan Science provides various solutions to its Individual Customers who purchase its products. Loan Science collects Personal Data from Individual Customers when they use its products, register with our website, log-in to their account, complete surveys, request information or otherwise communicate with us. For example, Loan Science individual customers may choose to seek support.

The Personal Data that we collect may vary based on the Individual Customer’s interaction with our website and request for our services. As a general matter, Loan Science collects the following types of Personal Data from its Individual Customers: contact information, including, a contact person’s name, email address, mailing address, telephone number. Individual customers have the option to log into their accounts online and to request service online, including through a live support option; we will collect information that they choose to provide to us through these portals.

When Individual Customers use our services online, we will collect their IP address and browser type. We may associate IP address and browser type with a specific customer. We also may collect Personal Data from persons who contact us through our website to request additional information; in such a situation, we would collect contact information (as discussed above) and any other information that the person chooses to submit through our website.

The information that we collect from Individual Customers is used for selling the products and services they buy from us, managing transactions, reporting, invoicing, renewals, other operations related to providing services and products to the Individual Customer.

For certain products, Loan Science serves as a service provider. In our capacity as a service provider, we will receive, store, and/or process Personal Data. In such cases, we are acting as a data processor and will process the personal information on behalf of and under the direction of our partners and/or agents. The information that we collect from our Individual Customers in this capacity is used for managing transactions, reporting and related to providing services to the Individual Customer, and as otherwise requested by our partner and/or agent.

Loan Science uses Personal Data that it collects directly from its Individual Customers and for its partners indirectly in its role as a service provider for the following business purposes, without limitation: (a) maintaining and supporting its products, delivering and providing the requested products/services, and complying with its contractual obligations related thereto (including managing transactions, reporting, invoices, renewals, and other operations related to providing services to an Individual Customer); (b) satisfying governmental reporting, tax, and other requirements; (c) storing and processing data, including Personal Data, in computer databases and servers located in the United States; (d) verifying identity (e.g., for online access to accounts); (e) as requested by the Individual Customer; (f) for other business-related purposes permitted or required under applicable local law and regulation; (g) and as otherwise required by law.

Loan Science does not disclose personal information to third parties for purposes that are materially different than what it was originally collected for. Should this change in the future, we will provide individuals with the option to opt-out.

Information collected automatically through your use of  Loan Science websites and services.

Device information.

Like most websites, Loan Science may automatically collect certain information from the device you use to visit our website, which we store in log files. This may include your browser type, device type, IP address, region or general geographical location from which your device is accessing the internet, operating system, unique device identifier, software version, and the domain name from which you accessed the site. We may rely on third-party agents to collect or process this analytic information. This information is used solely for our internal business purposes, including to improve the functionality of our site, diagnose problems, and generate statistical reports.

Aggregated usage information.

We collect information about how visitors use and interact with the site, including the date and time of site visits, device and browser information, the referring site URL, the areas or pages of the site visited, the amount of time spent viewing or using the site, and other click-stream or site usage data. We rely on third-party agents, including Google Analytics to collect and process this analytic and usability information. This information is used solely for our internal business purposes, including to improve the functionality of our site, diagnose errors, generate statistical reports, analyze trends, understand and improve user experience, and identify aggregate user preferences.

To view an overview of the privacy practices of Google Analytics, please go here: https://support.google.com/analytics/answer/6004245. Google Analytics supports an optional browser add-on that—once installed and enabled—disables measurement by Google Analytics for any site a user visits. You can find the browser add-on here: https://tools.google.com/dlpage/gaoptout.

Individual usage information.

With your consent, and if we have a business relationship with you or your organization, we may be able to associate certain usage information with known personal information, including your name, organization, and contact information. Along with this information, we also may associate email usage information, including the links you open in emails that you receive from us.

Please note that personal information about individual consumers (such as complaint information) is never associated with usage information, even if you opt in to cookies on our website.

Information collected by third parties and shared with Loan Science.

In the course of complaint resolution, conciliation, or arbitration.

Loan Science may receive information about you from businesses or organizations with which you have interacted for the purposes of facilitating the resolution of a pending complaint, conciliation, or arbitration proceeding. This may include your name, date of birth, account number, or other information used to verify your identity. This may also include account history information, your previous communications with the business or organization related to the matter in your complaint, or any other relevant information.

Other Ways Information May Be Shared

Loan Science may also share information under the following circumstances:

  • We respond to requests from governmental agencies or where required by law (such as by subpoena, investigative demand, court order, or regulation).
  • We may share information with appropriate governmental or regulatory authorities.
  • We may share information with appropriate persons or governmental authorities, where your communication suggests possible harm to others.
Security

Personal data that you provide to Loan Science is stored by Loan Science on servers located in data centers in the United States with restricted access, that have implemented reasonable procedures to prevent unauthorized access to, and the misuse of, personal data. Loan Science restricts access to your personal data to authorized Loan Science employees, independent contractors and service providers who need to access the data in order to provide services in support of Loan Science operations and program services.

Loan Science has taken steps to ensure the ongoing confidentiality, integrity, availability, and resilience of systems and services processing personal information and will restore the availability and access to information in a timely manner in the event of a physical or technical incident.

International Transfers

If you are visiting our site from outside the United States, be aware that your information will be transferred to, and maintained on, computers located within the United States. The collection, use, retention and any other processing of your information will be governed by U.S. law and further by the specific jurisdictions within the United States where that information is stored, unless otherwise specified. In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Changes to this Privacy Policy

We recognize our ongoing responsibility with regard to the privacy of individuals whose personal data we collect and process. If we embrace new data privacy practices or adopt new policies, we will update this Privacy Policy. In the event that we make material changes to this policy, we will notify affected individuals.

Special Notice to Individuals in the European Union, United Kingdom, and Switzerland

Information we collect about European Complainants

Loan Science collects personal data when you submit a privacy complaint using our online complaint form, and during any subsequent contacts you have with our staff by electronic mail or telephone in relation to your Privacy Shield complaint. Except as otherwise indicated below, Loan Science does not collect personally identifiable information or personal data unless you voluntarily provide it to us, and limits the personal data it collects to information relevant for the purposes of processing.

How Loan Science Uses Your Personal Data

Loan Science may process your Personal Data for the following purposes:

  • Effective request handling, including verifying your identity and location; making eligibility determinations; and facilitating communications.

When Loan Science transmits complaint-related information over the internet, we protect it through the use of data encryption methods.

Bases for Processing

To process the personal data of BBB EUPS complainants as described above, BBB relies on the following independent legal bases: BBB EUPS carries out tasks in the public interest; processing is necessary for BBB EUPS’s legitimate interests; and BBB EUPS receives complainants’ express consent to process their personal data in the United States.

Public Interest. BBB National Programs is a not-for-profit organization that operates numerous widely recognized self-regulatory and alternative dispute resolution (ADR) programs in North America, including BBB EU Privacy Shield. The alternative dispute resolution programs of organizations such as BBB National Programs are sanctioned by the laws of many countries, most of which acknowledge the importance of ADR’s role as an important channel in the administration of justice. The personal data collected by BBB EUPS in processing privacy complaints from EU and EEA individuals is essential to BBB EUPS’s performance of its dispute resolution function under Privacy Shield, which constitutes “a task in the public interest” as a basis for collecting and maintaining such information under the GDPR.

Legitimate interests. Personal data related to complainants is collected only to the extent necessary given BBB EUPS’s legitimate interests as a data controller, in its role as an independent recourse mechanism (IRM) providing dispute resolution services to individuals in the EU/EEA with privacy complaints against U.S. businesses participating in the Privacy Shield Frameworks that have identified BBB EUPS as their IRM.

Consent. Before completing the BBB EUPS online complaint form, BBB EUPS requests your express consent to our processing of your personal data in the United States. If you withdraw your consent to processing before we make an eligibility determination regarding your complaint and open a case, we will discontinue your complaint and delete your information. After a case has been opened, BBB EUPS may proceed with processing on the alternative legal bases set forth above, or where legally obligated to do so.

Sharing Your Personal Data with Third Parties

BBB EUPS may share your Personal Data with (i) a BBB EUPS Participating Business against which you have submitted a complaint, in order to process the complaint; (ii) independent Data Privacy Panelists we may assign to arbitrate your complaint, should you request a Data Privacy Review; and (iii) BBB National Programs’ service providers, including data processors, in order to deliver the services provided by BBB EUPS.

Data Retention

BBB EUPS will store your Personal Data for as long as necessary to perform the purposes of processing, which include handling your complaint to its final resolution; producing required reports pursuant to Privacy Shield and to the BBB EUPS Procedure Rules; and otherwise complying with our legal and regulatory obligations.

If you need further assistance regarding the above rights, please contact us at compliance@loanscience.com and we will consider your request in accordance with applicable law.

European Union and EEA individuals also have the right to lodge a privacy complaint with the appropriate supervisory authority. Contact information for the EU data protection authorities can be found here: https://edpb.europa.eu/about-edpb/board/members_en.

5. DISCLOSURES / ONWARD TRANSFERS OF PERSONAL DATA

Loan Science does not provide Personal Data to Third Parties. Should this change Loan Science will update our policy to identify third parties and provide a process to opt in/out as required.

Please be aware that Loan Science may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements. Loan Science is liable for appropriate onward transfers of personal data to third parties.

6. SENSITIVE DATA

Loan Science does not collect Sensitive Data from its Individual Customers.

7. DATA INTEGRITY AND SECURITY

Loan Science uses reasonable efforts to maintain the accuracy and integrity of Personal Data and to update it as appropriate. Loan Science has implemented physical and technical safeguards to protect Personal Data from loss, misuse, and unauthorized access, disclosure, alternation, or destruction. For example, electronically stored Personal Data is stored on a secure network with firewall protection, and access to Loan Science’s electronic information systems requires user authentication via password or similar means. Loan Science also employs access restrictions, limiting the scope of employees who have access to Individual Customer Personal Data.

Further, Loan Science uses secure encryption technology to protect certain categories of personal data. Despite these precautions, no data security safeguards guarantee 100% security all of the time.

8. NOTIFICATION

Loan Science notifies Individual Customers about its adherence to the EU-US Privacy Shield and Swiss-US Privacy Shield principles through this publicly posted website privacy policy and take Individual customers approval and adherence to the current policy when they provide their information to us in the transactional process.

9. ACCESSING PERSONAL DATA

Loan Science personnel may access and use Personal Data only if they are authorized to do so and only for the purpose for which they are authorized.

10. RIGHT TO ACCESS, CHANGE OR DELETE PERSONAL DATA

(a) Right to Access. Individual Customers have the right to know what Personal Data about them is included in the databases and to ensure that such Personal Data is accurate and relevant for the purposes for which Loan Science collected it. Individual Customers may review their own Personal Data stored in the databases and correct, erase, or block any data that is incorrect, as permitted by applicable law and Loan Science policies. Upon reasonable request and as required by the Privacy Shield principles, Loan Science allows Individual Customers access to their Personal Data, in order to correct or amend such data where inaccurate. Individual Customers may edit their Personal Data by logging into their account profile or by contacting Loan Science by phone or email. In making modifications to their Personal Data, Data Subjects must provide only truthful, complete, and accurate information. To request erasure of Personal Data, Individual Customers should submit a written request to local Loan Science office.

(b) Requests for Personal Data. Loan Science will track each of the following and will provide notice to the appropriate parties under law and contract when either of the following circumstances arise: (a) legally binding request for disclosure of the Personal Data by a law enforcement authority unless prohibited by law or regulation; or (b) requests received from the Data Subject. If Loan Science receives a request for access to his/her Personal Data from an Individual Customer, then, unless otherwise required under law or by contract with such Individual Customer, Loan Science will refer such Data Subject to the Individual Customer.

(c) Satisfying Requests for Access, Modifications, and Corrections. Loan Science will endeavor to respond in a timely manner to all reasonable written requests to view, modify, or inactivate Personal Data.

11. CHANGES TO THIS POLICY

This Policy may be amended from time to time, consistent with the Privacy Shield Principles and applicable data protection and privacy laws and principles. We will make employees available of changes to this policy either by posting to our intranet, through email, or other means. We will notify Customers if we make changes that materially affect the way we handle Personal Data previously collected, and we will allow them to choose whether their Personal Data may be used in any materially different manner.

12. QUESTIONS OR COMPLAINTS

EU and Swiss Individual customers may contact Loan Science with questions or complaints concerning this Policy at the following address:

Privacy Shield Complaints

Loan Science

2201 Donley Drive

Suite 110

Austin, TX 78758

Telephone: 512-501-2400

contact@loanscience.com

In compliance with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, The Companies commit to resolve complaints about our collection or use of your personal information transferred to the U.S. pursuant to the EU-U.S. DPF. EU and UK individuals with inquiries or complaints should first contact The Companies’ Director of Corporate Compliance, 2201 Donley Drive, Suite 110, Austin, TX 78758 or by email at compliance@loanscience.com

The Companies have further committed to refer unresolved DPF Principles-related complaints to a U.S.-based independent dispute resolution mechanism, BBB NATIONAL PROGRAMS. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbbprograms.org/dpf-complaints for more information and to file a complaint. This service is provided free of charge to you.

If your DPF complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See https://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction-dpf

13 .ENFORCEMENT AND DISPUTE RESOLUTION

In compliance with {the EU-U.S. DPF} {and the UK Extension to the EU-U.S. DPF} {and the Swiss-U.S. DPF}, Loan Science commits to refer unresolved complaints concerning our handling of personal data received in reliance on {the EU-U.S. DPF} {and the UK Extension to the EU-U.S. DPF} {and the Swiss-U.S. DPF} to BBB, an alternative dispute resolution provider based in the United States  If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit contact compliance@loanscience.com for more information or to file a complaint.  The services of BBB are provided at no cost to you.

https://www.bbb.org/file-a-complaint

14. DEFINED TERMS

Capitalized terms in this Privacy Policy have the following meanings:

“Individual Customer” means an Individual customer or client of Loan Science from EU or Switzerland. The term also shall include any individual agent, representative, of an individual customer of Loan Science and all employee of Loan Science where Loan Science has obtained his or her Personal Data from such Individual Customer as part of its business relationship with Loan Science.

“Data Subject” means an identified or identifiable natural living person. An identifiable person is one who can be identified, directly or indirectly, by reference to a name, or to one or more factors unique to his or her personal physical, psychological, mental, economic, cultural or social characteristics. For Customers residing in Switzerland, a Data Subject also may include a legal entity.

“Employee” means an employee (whether temporary, permanent, part-time, or contract), former employee, independent contractor, or job applicant of Loan Science or any of its affiliates or subsidiaries, who is also a resident of a country within the European Economic Area.

“Europe” or “European” refers to a country in the European Union.

“Personal Data” as defined under the European Union Directive 95/46/EC means data that personally identifies or may be used to personally identify a person, including an individual’s name in combination with country of birth, marital status, emergency contact, salary information, terms of employment, job qualifications (such as educational degrees earned), address, phone number, e-mail address, user ID, password, and identification numbers. Personal Data does not include data that is de-identified, anonymous, or publicly available. For Switzerland, the term “person” includes both a natural person and a legal entity, regardless of the form of the legal entity.

“Sensitive Data” means Personal Data that discloses a Data Subject’s medical or health condition, race or ethnicity, political, religious or philosophical affiliations or opinions, sexual orientation, or trade union membership.

“Third Party” means any individual or entity that is neither Loan Science nor a Loan Science employee, agent, contractor, or representative.