Last modified: July 31, 2018
About this Policy
We’ve broken this policy down into the following sections, so you can find the details you need easily as possible.
- How to Use this Policy
- Who We Are
- How this Policy Applies
- Who Collects Information
- How we Collect your Information
- What we Collect
- How we Use your Information
- How we Share your Information
- Keeping your Personal Information Secure
- Your Rights and User Restrictions
- How to Contact Us
- International Users
- How to Use this Policy
- Who we Are
Equez LLC (or “eQuez”) is an organization established to assist students in finding personalized post-secondary educational program options. eQuez helps students learn about careers and get connected to schools and opportunities that align with their interests.
- “we/us/our” means “eQuez”;
- “third party” means someone who is not you or us; and,
Our registered office is Equez LLC, registered in Virginia as a Limited Liability Corporation, located at Virginia Professional Services, LLC, 3850 Gaskins Rd. Ste 120, Richmond, VA, 23233. We may also be reached at www.eQuez.com.
- How this Policy Applies
- When you visit the Website, including by tracking technologies.
- Through email, text, other electronic messages, paper registrations, telephone inquiries or communications between you and the Website or eQuez. Note that “Website” is further defined in Section 13, Glossary.
- Who Collects Information
eQuez Pages and Content Managed by Third Parties
Although this is not currently an eQuez practice, the Website may ultimately contain Third Party Managed Pages hosted, operated, or managed on eQuez’s behalf. Our contracted third-party service providers, if any, may directly collect PII and other information from you as necessary for completing authorized transactions or other engagements you undertake with eQuez on these pages.
The Website also makes use of third-party Cookies, Web Beacons, Pixels, and dynamic tags, which may allow third parties to collect information about you and your activities on the Website and provide you, or enable others to provide you, with functionality within our Website, additional personalization, or with advertising. For additional information concerning Cookies, Web Beacons and Pixels, see Section 13, Glossary.
Links to External Sites
- How we Collect your Information
We will collect your personal information when you, for example:
- Use the Website for any purpose;
- Register for an eQuez account;
- Submit a resume, biography or application or proposal through our Website;
- Complete forms made available on our Website;
- Apply to become a Registered User;
- Update your registration or profile information;
- Subscribe or unsubscribe to any of our services (including email);
- Post material, comments or feedback:
- NOTE: we cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed or used by unauthorized persons.
- Submit content for eQuez use;
- Participate in surveys or questionnaires geared towards personalizing content;
- Report a problem with our Website;
- When you contact us or submit correspondence to us (including email);
- Participate in eQuez social media accounts or blogs; or
- When you respond to our event emails;
- When you participate in our eRank, a personalized ranked list of schools that are specific to your unique preferences;
- Submit your profile to share with well-aligned schools and/or associations so they may discover and connect with you.
- What do we Collect?
The types of information we may have depend on the ways in which you engage with eQuez as well as the products and services you elect to receive from eQuez.
This may include, where applicable:
- Your name, address, phone and/or mobile number, your date of birth, gender and email address;
- Your location data. For example, a location is derived from your IP address or data such as a postcode or name of a town or city;
- Your contact with us, such as a note or recording of a call you make to our customer service center, an email or letter sent, or other records of any contact with us;
- Your Registered User and/or account information, such as student profile information and/or image, or other information related to your account.
- Credential information – we will collect passwords, hints and similar security information used for authentication and access to accounts and services;
- Your preferences for networking opportunities, products, services and lifestyle activities based on how you use our website, products and services (personalization); See the “Cookies” section for details on what we collect using cookies, web beacons and other technologies, including digital advertising.
- Your browsing history. We do NOT have a history of the sites you browse. If you have given permission, eQuez may collect the categories of website you have browsed on your device(s), e.g., About Us, Blog, and use these interests to send you personalized marketing or advertising. You may limit or opt-out of marketing or advertising, including via Cookies. See, Section 10, “Your Rights and User Restrictions”.
- Legally-related information we obtain from other sources, such as fraud-prevention agencies and from other data providers. This includes demographic data, interest-based data, and internet browsing behavior.
- How we use your Information
- Providing you with products, services, or opportunities you select, including associated benefits.
- Responding to your questions or providing information that you request.
- Account notifications.
- Managing submission or Registered User functions.
- Providing features on the Website may require you to register as a Registered User and to receive our authorization before you can use those particular features, including mailing lists, peer to peer networking participation, and other services. This PII and other information may include titles, names, addresses, e-mail addresses, telephone numbers, fax numbers, educational history, birth date, related affiliations, research involvement, social media handles, primary professional role, proof of US Citizenship or Residency (for any International Student Rotation that you may be interested in), and other forms of PII.
NOTE: Once we have authorized you as a Registered User, we may provide you with an eQuez customer identification number and you may be required to select a unique Username and Password. Generally, you will be able to change your Password and update any PII you have given us. See, Section 10, “Your rights and User Restrictions.”
B. eQuez’s Legitimate Business Interests, for example, fraud prevention, maintaining the security of our network and services, direct marketing, business intelligence, personalization, and improvement of our Website, products and services. This also includes use of your NPI and PII (see also, Section 13, Glossary). The data we automatically collect from you is generally used to render, administer, and improve the Website, our services, and our business. It helps us to improve our Website and to deliver a better and more personalized service. Purposes for which we may use such information include, but are not limited to, the following:
- Presenting our Website and its contents to you.
- Helping dynamically generate content on web pages or in newsletters.
- Statistically monitoring how many people are using the Website or opening our Emails.
- Tracking generic user behavior.
- Helping us evaluate the purpose for which our users undertake certain activities, including those listed immediately above.
- Determining the popularity of certain content and advertisements.
- Restricting underage (under 13 years) use of our services.
- Speeding up your searches and facilitating log-in and navigation, and as session timers.
- Enabling us and our advertisers and social media partners to display advertisements to appropriate target audiences, including Online Behavioral Advertising.
- Storing information about your preferences, allowing us to personalize your content.
- To search for campaigns in our Search for a Participant, and to search for potential higher education matching opportunities.
- For other commercially reasonable purposes, including measuring advertising and promotional effectiveness and assessing which areas of the Website to remarket to you after you leave our site.
- To advise you of products or services that may be available through eQuez.
- To notify you about Website maintenance, updates, changes, and new features, including products or services we offer or provide through the Website.
- To allow you to participate in interactive features on our Website.
- To solicit user feedback to assess user-satisfaction or other needs and interests.
- To help us in creating new tools, features, and services.
Whenever we rely on this lawful basis to process your data, we assess our business interests to make sure they are legitimate, our use is necessary for the applicable purpose, and does not override your rights. Additionally, in some cases you have the right to object to this processing. See also, Section 10, “Your rights and User Restrictions”.
NOTE: eQuez complies with applicable Federal civil rights laws and does not discriminate on the basis of race, color, national origin, age, disability, or sex. eQuez does not exclude people or treat them differently because of race, color, national origin, age, disability, or sex. Data sharing agreements include a prohibition against the use of data in any discriminatory manner.
If you believe that eQuez has failed to provide these services or discriminated in another way on the basis of race, color, national origin, age, disability, or sex, you can file a grievance with: Jennifer G. Smith, Esq. at 3869 Eisenhower Avenue, Alexandria, VA 22304 or by contacting Equez’s registered agent: Equez LLC, located at Virginia Professional Services, LLC, 3850 Gaskins Rd. Ste 120, Richmond, VA, 23233. You can also file a civil rights complaint with the U.S. Department of Health and Human Services, Office for Civil Rights, electronically through the Office for Civil Rights Complaint Portal, available at https://ocrportal.hhs.gov/ocr/portal/lobby.jsf, or by mail or phone at: U.S. Department of Health and Human Services 200 Independence Avenue, SW Room 509F, HHH Building Washington, D.C. 20201 1-800-368-1019, 800-537-7697 (TDD) Complaint forms are available at http://www.hhs.gov/ocr/office/file/index.html.
C. Compliance with a mandatory legal obligation, including for example accounting and tax requirements, which are subject to strict internal policies (such as retention periods), procedures, and your right to restrict usage of your data, which control the scope of legal assistance to be provided.
D. Consent. When you give your consent for the processing of your personal information, you will be given details on how to change your mind at any time. Consent may be withdrawn or modified at any time. Visit the “Your rights” section of this policy for more information.
E. Other potential uses for your personal information
In addition to the above use cases, we may lawfully process your personal information for the following purposes:
Use of Third Party Cookies and Other Tracking Technologies
The Website makes use of automatic data collection technologies including first and third-party Cookies, log files, Web Beacons, Pixels, dynamic tags, and/or other technical means (we refer to these collectively as “Cookies”). We may use these technologies to collect information about your online activities over time and across third-party websites or other online services to deliver content and advertising tailored to your interests, both on the Website and on third-party websites (including but not limited to search engines and social media websites). This practice is commonly known as “Online Behavioral Advertising.”
The third parties who provide us with third-party Cookies, may use these technologies to collect information about you when you use the Website to provide you with advertising based on your visit to the Website or to collect impressions data regarding the efficacy of advertising placed with us. Third parties may have the ability to link the information they collect about you when you use the Website with other information they collect about you elsewhere on the Internet or information about the device you are using. Third parties may also collect information about your online activities over time and across different websites and other online services or mobile devices and may use this information to provide you with Online Behavioral Advertising or other targeted content.
Disclosure of Information to Third-Party Vendors and Service Providers
As we indicate above, eQuez may engage third-party vendors and service providers to provide services in connection with the Website, outreach for our matching-programs and services, and to help us manage our web presence and improve performance. We may share PII or other information with these third-party vendors and service providers as necessary so that they may provide the services for which they have been engaged. PII and other information submitted to eQuez or through Third Party Managed Pages are also shared with the relevant third-party vendor as necessary for completing authorized transactions. For additional information on “PII” see Section 13, Glossary.
In addition, some of the content and services on the Website are served by third parties, including Universities or related institutions.
Research and Analytics
We use a variety of analytics methods including what is commonly referred to as “big data analytics”. Big data analytics are mathematically driven analysis techniques on large and varied data sets to uncover hidden patterns and trends. We may create de-identified or anonymous data from PII by removing data components (e.g., name, email address, or linkable tracking ID) that makes the data personally identifiable to you or through obfuscation or through other means. Our use of de-identified or anonymized data is not subject to GDPR or this Privacy Notice.
Analytics are used to, for example:
- Conduct market research and carry out research and statistical analysis including to monitor how visitors use our networks, products, and services and how visitors may participate in certain activities;
- Frame our marketing campaigns and personalization efforts; and
- Provide reports to third parties (such reports do not contain information which may identify you as an individual).
- How We Share Your Personal Information
Where applicable, we may share information about you with:
- Partners, suppliers, and agents involved in delivering the products and services you’ve ordered or used, or the benefits attendant to those products and services;
- Companies who are engaged to perform services for, or on behalf of, eQuez;
- Law enforcement agencies, government bodies, regulatory organizations, courts or other public authorities if we must, or are authorized to by law;
- A third party or body where such disclosure is required to satisfy any applicable law, or other legal or regulatory requirement;
- If you elect to participate in any directories. You may also elect to make your information private or cease participation in the database at any time by contacting the eQuez Customer Services at firstname.lastname@example.org;
- For any other purpose(s) disclosed by us when you provide the information with your consent or a legitimate business interest, as defined above; and
- In the event of a change of control of eQuez (or the Website or any portion thereof), such as through a merger, sale, consolidation, transfer of substantial assets, reorganization or liquidation, or other similar transaction, eQuez reserves the right to transfer, sell, or assign to third parties any information we have collected.
NOTE: When you register for any of these actions, you may be asked whether you want to receive special announcements and future communications by email. If you check “yes” but change your mind at any time in the future and no longer wish to receive correspondence by email, you will be able to opt-out of these services. See Section 10, “Your rights and user restrictions”, below.
We occasionally survey visitors to our Website. Survey responses are used in aggregated, de-identified form to help us understand the needs of our visitors so that we can improve our site. The information may be shared on a de-identified and/or aggregated basis with third parties with whom we have a business relationship. While you may always decline to share personal information, if survey respondents provide personal information (e.g., personal email) in a survey, it is shared only with those people who need to see it to respond to the question or request, or with third parties who perform data management services for our Website, product or service. Those third parties have agreed to keep all data from surveys confidential.
The Web server automatically collects the Internet Protocol (IP) address of the computers that access our site. By itself, an IP address merely indicates which computer sent a query, which is not PII. Only when correlated with information like user logs, query patterns, and other contextual information do IP addresses convert to PII. Typically, we use this information in aggregate form to understand how our Website or advertisements are being used and to analyze how we can better serve visitors. See Section 13, Glossary, for additional information on PII.
- Keeping your Personal Information Secure
Access to data and technology relating to user information is password-protected and limited to authorized personnel and those vendors that require access to the information in order to furnish services to eQuez and our customers. In addition, eQuez uses industry standard technology to keep users’ information secure while residing on our servers.
Communications over the internet (such as e-mails) are not secure unless they have been encrypted. Your communications may go through several countries before being delivered, as this is the nature of the Internet. We cannot accept responsibility for any unauthorized access or loss of personal information that is beyond our control.
We will never ask for your secure personal or account information by an unsolicited means of communication. You are responsible for keeping your personal and account information secure and not sharing it with others.
Our Website may provide links to third-party websites. We cannot be responsible for the security and content of such third-party websites. Please be sure to read that company’s privacy and cookies policies before using or putting your personal information on their site. The same applies to any third-party websites or content you connect to using our products and services.
If you are a Registered User of the Website, you can review, correct and change your PII (and any preferences) by logging into the Website and visiting your account profile page.
- Your Rights and User Restrictions
A. Your California Privacy Rights
California Civil Code Section 1798.83 permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send us an email to email@example.com or write us at: 5810 Kingstowne Center Ste 120-179, Alexandria, VA, 22315, Attention: Legal.
B. Right to Correct Personal Data
You have the right to have information held about you corrected if it is not accurate. If what we hold on you needs updating, or you think it may be inaccurate, please contact our Customer Services team:
Monday – Friday, 9:00 AM – 6:00 PM (ET)
Right to Access Personal Data
You have the right to make a request for a copy of the personal data that eQuez holds about you. To make this request as an individual or an authorized third party, you can contact our Customer Services Team at the above-referenced contact information.
Right to Object to Use of Personal Data
You have the right, in certain circumstances, to object to eQuez processing your personal information. If you have questions about this right, please contact our Customer Services Team.
To Opt-Out of Marketing Messages
If you no longer want to receive marketing messages from eQuez, you can elect to opt out of all marketing communications or only selected methods (e.g., email, phone or post).
If you wish to modify other preferences, please reach out to: firstname.lastname@example.org.
Opting out does not mean that you will not receive future service-related messages or other communications from us regarding transactions you undertake with us. You may continue to receive those (unless we have indicated otherwise). If you do not wish to receive personalized marketing, or you subsequently change your mind, email email@example.com.
Please recognize that Third-Party Managed Pages (and their products and services) may have their own preference centers for communications with you relating to those specific products and services. If any questions arise, contact us at firstname.lastname@example.org so that we can discuss your preferences.
How to Lodge a Complaint
If you want to contact us about any of your rights or complain about how we use your information, contact our Customer Services team or email us at email@example.com.
Right to restrict use of your data
If you feel data we hold on you is inaccurate, or you believe we shouldn’t be processing your data, please contact our Customer Services team to discuss your rights. In certain circumstances, you will have the right to ask us to restrict processing.
Right to erasure
eQuez strives to only process and retain your data for as long as we need to. In certain circumstances, you have the right to request that we erase personal data of yours that we hold. If you feel that we are retaining your data longer than we need, please reach out to Customer Services with your concerns. Even if your relationship with eQuez has ended, we may still have lawful grounds to process your personal data.
Restrictions: Children Under the Age of 13
Our Website is not intended for children under 13 years of age. No one under age 13 may provide any personal information to or on our Website. We do not knowingly collect PII from children under the age of 13. If we learn we have collected or received personal information from a child under 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 13, please contact us at firstname.lastname@example.org.
- How to contact us
Monday – Friday, 9:00 AM – 6:00 PM (ET)
Please note, some of the rights covered by this policy such as the right to data portability and right to restriction, apply from May 25, 2018.
- International users
EQuez and the Website is based in the United States and, regardless of where you access the Website, the information collected as part of that use will be transferred to and maintained on servers located in the United States. Any information we obtain about you will be stored in accordance with U.S. privacy laws, regulations, and standards, which may not be equivalent to the laws in your country of residence. By using the Website, you consent to this collection, transfer, storage, and processing of information to and in the United States in accordance with the foregoing.
If you are an International User, the GDPR (and related International regulations) requires eQuez to inform you of its use of automated decision-making tools. EQuez may use various tools, such as Google Analytics® and Adobe Analytics Cloud, to track your online activities to provide you with tailored advertising. You have the right to decline decisions based solely on automated processing, including profiling.
Non-Personal Information (“NPI”). Information that may relate to an individual but does not by itself identify that individual. For example, browser information is Non-Personal Information, as is information such as gender, age, city, and physical location, when not linked with other PII. NPI may be “re-identified” through certain processes by linking it to PII relating to the same individual
Personally Identifiable Information (“PII”). Any representation of information that permits the identity of an individual to whom the information applies to be reasonably inferred by either direct or indirect means. Further, PII is defined as information: (i) that directly identifies an individual (e.g., name, address, SSN or other identifying number or code, telephone number, email address, etc.); or, (ii) by which an organization intends to identify specific individuals in conjunction with other data elements, i.e., indirect identification. (These data elements may include a combination of gender, race, birth date, geographic indicator, eQuez Student Member ID and/or other descriptors). Additionally, information permitting the physical or online contacting of a specific individual is the same as PII. This information can be maintained in any form.
Third Party Managed Pages. Certain pages of the websites, such as registration, searches, matches may be managed by third parties, and from which third-party vendors may directly collect PII and other information as necessary for completing authorized transactions.
Web Beacons or Pixels (also often referred to as “clear GIFs,” “pixel tags,” “1-by-1 GIFs,” “Single-Pixel GIFs,” “1 x 1 Pixels” or “clear Pixels”). Pages of the website and our e-mails may contain small electronic files known as web beacons that permit us and/or third parties to collect Web Information during your visit to the Website. For example, Web Beacons may be used to count the number of users who have visited a page or opened an e-mail and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity). Web Beacons send information back to their home server (which can belong to the host site, a network advertiser, or some other third party) from the users’ Browser, such as the IP address, the URL of the page on which the beacon is located, the type of Browser that is accessing the site, and information stored in any Cookies on the users’ computer previously placed by that server. Web Beacons can also be used to place a Cookie on the users’ Browser. Third parties who provide us with web beacons or pixels may have the ability to link the information they collect about you when you use the Website with other information they collect about you elsewhere on the Internet, including but not limited to your PII or information about the device you are using.
Website. Collectively, the www.equez.com the Third Party Managed pages and any other online functionalities or services included in the websites operated by eQuez.