Privacy Policy

Effective as of May 24, 2018

1. Introduction

Your privacy and security are important to QuestBridge ("QB", "us", "our" or "we"). Because we gather certain types of information about our users, we feel you should fully understand the terms and conditions relating to the collection, use and possible disclosure of that information. This privacy policy (the "Privacy Policy") applies to your use of the www.questbridge.org website (the "QB Website"), which is owned and operated on behalf of QB. Questions regarding this privacy policy should be directed to [email protected]. Please note that QB will not knowingly accept information from individuals who are under 13 years of age without first obtaining verifiable parental consent.

2. About this Policy

This Policy sets out the essential details relating to your personal data relationship with QB. The aim of this Policy is to:

Ensure that you understand what personal data we collect about you, the reasons why we collect and use it, and who we share it with;
Explain the way we use the personal data that you share with us in order help you and other talented low-income students access and navigate exceptional educational and life opportunities; and
Explain your rights in relation to the personal data we collect and process about you and how we will protect your privacy.

We hope this helps you to understand our privacy commitments to you.

3. Your rights

You may be aware that a new European Union law, called the General Data Protection Regulation or "GDPR" gives certain rights to individuals in relation to their personal data. As available and except as limited under applicable law, the rights afforded to you are:

Right of Access - the right to be informed of and request access to the personal data we process about you;
Right to Rectification - the right to request that we amend or update your personal data where it is inaccurate or incomplete;
Right to Erasure - the right to request that we delete your personal data;
Right to Restrict - the right to request that we temporarily or permanently stop processing all or some of your personal data;
Right to Object -
- the right, at any time, to object to us processing your personal data on grounds relating to your particular situation;
- the right to object to your personal data being processed for direct marketing purposes;
Right to Data Portability - the right to request a copy of your personal data in electronic format and the right to transmit that personal data for use in another party’s Website; and
Right not to be subject to Automated Decision-making - the right to not be subject to a decision based solely on automated decision making, including profiling, where the decision would have a legal effect on you or produce a similarly significant effect.

If you would like to exercise any of these rights, or have any questions about your privacy, your rights, or how to exercise them, please contact us at [email protected].

4. How do we collect your personal data?

We collect your personal data in the following ways:

1. When you register with us

a. In order to access certain portions of the QB Website and to use certain Websites provided therein, QB may require you to register either directly with QB or through one of its Website providers. These Websites include, but are not limited to, our National College Match program which offers you an opportunity to be matched with one of our partner colleges or universities for early admission and a full scholarship (the "College Match Program"), and our College Prep Scholars program for high school juniors (the "CPS Program"). In order to participate in either our College Match or CPS Program, you must first register and create an online account with QB through our application site.

b. Your use of the QB Website is conditioned on your provision of requested information in an accurate and truthful fashion. If you choose not to provide such information, you may not be able to access, apply for or utilize the College Match Program, the CPS Program, or other Websites and/or opportunities provided on the QB Website. You may cancel your account at any time by contacting [email protected]. Once QB has finished processing your cancellation request, your account will be deactivated.

2. Through your use of the QB Website

a. When you use the QB Website, we collect personal data such as your IP address, cookies, and web interactions data.

3. When you apply to QB programs

a. When you apply to QB programs, including but not limited to the CPS Programs and the College Match, QB will collect data that is necessary for our selection process.

4. From third parties

a. We receive personal data about you and your activity from third parties, including partners we work with in order to communicate with you and share opportunities to help you and other talented low-income students access and navigate exceptional educational and life opportunities. We will use this personal data either where you have provided your consent to the third party or to QB to that data sharing taking place or where QB has a legitimate interest to use the personal data in order to provide you with educational and life opportunities.

5. What personal data do we collect from you?

We have set out in the tables below the categories of personal data we collect and use about you:

Personal data collected when you sign up for the QB Website

Categories of personal data

Description of category

Account Registration Data

To create an account, you will be asked to create a username and password and to provide information such as your name, address, phone number and email address on the registration form. In addition to the uses set forth in Section 6 of this Privacy Policy, your Personal Information may also be used to contact you when necessary for customer Website reasons. Once registered with the QB Website, you will then be able to complete the application process. For more detailed information on what information will be collected during the application process, please refer to the "How to Apply" sections of the QB Website. All Personal Information collected by the QB Website, including without limitation the registration and application information, will be available to QB and subject to this Privacy Policy.

Personal data collected through your use of the QB Website

Categories of personal data

Description of category

QB Website Usage Data

This is the personal data that is collected about you when you are using the QB Website - this may include:

IP Address: Your IP address is a number that is automatically assigned to your computer whenever you begin Website with an Internet Website Provider. Each time you access the QB Website and each time you request one of our pages, our server logs your IP address. Standing alone, your IP address is not necessarily personally identifiable. We may use your IP address to administer our website, to assist in diagnosing problems with our server, to monitor our system performance and/or to make it easier and more convenient for you to navigate and use the QB Website.
Cookies: Generally, cookies work by assigning to your computer a unique number that has no meaning outside of our site. Our cookies do not contain any personally identifying information; we use them to provide features such as personalization, to save your username and to keep track of your application. We may also use cookies to assist us in delivering content specific to your interests, such as informing you of certain third party offerings. Additionally, after you have entered your username and password during a session on the QB Website, that information is saved so you do not have to re-enter it repeatedly during that session. Most Web browsers automatically accept cookies, but you can usually configure your browser to prevent this. Not accepting cookies may make certain features of the QB Website unavailable to you.
Your interaction on the QB Website: QB may use a variety of other technical methods for tracking purposes, including Web beacons. Web beacons are small pieces of data that are embedded in web pages and emails. We use these technical methods in HTML emails that we send our users to determine whether they have opened those emails and/or clicked on links in those emails. The information from use of these technical methods may be collected in a form that is personally identifiable.

Application Data

This is the personal data that is collected when you apply to programs on the QB Website, including but not limited to the CPS Programs and the College Match. Data collected in the application includes biographical, academic information, household income, financial status, citizenship, citizenship status, essays, and other personal details. This includes data considered to be in the “Special Category of Personal Data.”

Personal data collected with your permission that enables us to provide you and other talented low-income students with additional access and navigate exceptional educational and life opportunities

Categories of personal data	Description of category
College admissions and graduation data	This is personal data about where you ultimately enroll in college, whether you have been offered admissions from our college partners. This also includes data related to your graduation from college and beyond.
Communications Data	This is personal data, including but not limited to, email and mailing address, is used to enable QB and our partners / Website providers / Associates to send you communications either: Via email; Whilst using the QB Website; and/or Direct from the third party.
Surveys and Updated Data from you	This is personal data that we collect from surveys that we administer to you, including but not limited to updated data that you submit to keep your data up to date in our records.

6. What do we use your personal data for?

When you use or interact with the QB Website, we use a variety of technologies to process the personal data we collect about you for various reasons. We have set out in the table below the reasons why we process your personal data, the associated legal bases we rely upon to legally permit us to process your personal data, and the categories of personal data (identified in Section 5 ‘What personal data do we collect from you?’) used for these purposes:

Description of why QB processes your personal data (‘processing purpose’)	Legal Basis for the processing purpose	Categories of personal data used by QB for the processing purpose
To provide, personalize, and improve your experience with the QB Website and other Websites and products provided by QB, for example by providing customized, personalized, or localized content, recommendations, features, and personalized guidance on or outside of the QB Website.	Performance of a Contract Legitimate Interest	Account Registration Data Website Usage Data
To understand how you access and use the QB Website to ensure technical functionality of the QB Website, develop new products and Websites, and analyze your use of the QB Website, including your interaction with applications, products, and Websites that are made available, linked to, or offered through the QB Website.	Performance of a Contract Legitimate Interest	Account Registration Data Website Usage Data
To communicate with you for QB Website-related purposes.	Performance of a Contract Legitimate Interest	Account Registration Data Website Usage Data
To communicate with you, either directly or through one of our partners, for: educational and life opportunities surveys via emails, notifications, or other messages, consistent with any permissions you may have communicated to us.	Consent Legitimate Interest	Communications Data
To administer the selection processes related to providing services such as the College Match or CPS Programs to you, as well as to personalize your account and to allow our network of colleges, universities, scholarship providers, internship programs, and others looking for outstanding students ("Associates") to contact you for the purposes of providing our services or responding to requests by you (e.g., responding to applications).	Performance of a Contract Legitimate Interest	Application Data Surveys and updated data from you
To facilitate QB’s partners’ selection processes related to services such as the College Match or CPS programs, as they relate to you.	Consent Performance of a Contract Legitimate Interest	Application Data
To better understand the populations that QB is reaching to devise strategies to further our nonprofit mission of providing talented low-income students with additional access and navigate exceptional educational and life opportunities	Legitimate Interest	Application Data College admissions and graduation data Surveys and updated data from you

If you require further information about the balancing test that QB has undertaken to justify its reliance on the legitimate interest legal basis under the GDPR, please email [email protected].

We have set out the categories of recipients of the personal data collected or generated through your use of the QB Website.

Information we may share with your permission

Categories of Recipients	Reason for sharing
Educators, school administrators, the wider public	If you are selected for QB programs, we ask that you give us your permission to share your biographical and academic information, photograph, and application and award status with educators and school administrators, and to use that information for publicity and promotional purposes if you are selected for QB programs (including, but not limited to, the CPS programs or the College Match). Within this context, QB will never share the confidential specifics of your application, such as household income, citizenship status, or other personal details. If you no longer agree to this data sharing, you can contact QB at [email protected] immediately regarding the exclusion of your information.
QB Partners	If you submit an application for a QB program, including but not limited to the CPS Programs and the College Match, QB may share personal data considered to be in the Special Category of Personal Data defined in the GDPR. Personal data in the special category include data that you may share in your application related to racial and ethnic origin, political opinions, religious and philosophical beliefs, health data, information about person’s sexual orientation, criminal record, etc.). If you share such data in your application, we ask that you give us your permission to share such information with our partners to aid them in their review process of your application.If you no longer agree to this data sharing, you can contact QB at [email protected] immediately regarding the exclusion of your information.

Information we may share

Categories of Recipients	Reason for sharing
Website Providers and Others	We use technical Website providers which may operate the technical infrastructure that we need to provide the QB Website, in particular providers which host, store, manage, and maintain the QB application, its content and the data we process. We also use technical Website providers to help us communicate with you.
QB Partners and Associates	Generally we use the Personal Information we collect about you in order to provide services such as the College Match or CPS Programs to you, as well as to personalize your account and to allow our network of colleges, universities, scholarship providers, internship programs, and others looking for outstanding students ("Associates") to contact you for the purposes of providing our services or responding to requests by you (e.g., responding to applications). We may also provide information to our Associates from time to time so that such Associates can contact you in order to make you aware of any opportunities that may be of interest to you or to respond to a service request by you. It is our policy not to disclose to our Associates any Personal Information without your consent (usually obtained via an "opt-in" option that you may select when filling out your application). QB may disclose your registration information for the purposes set forth above to those of our Associates for which you select the "opt-in" option during registration. QB may also use contact details that you provide to send you information about QB and how to improve your application or to respond to questions you may have. Any Personal Information provided to our Associates, either directly by you or by QB pursuant to your opt-in request, will be subject to our Associates' privacy policies and not this Privacy Policy. As such, we encourage you to review our Associates' privacy policies prior to providing, or opting-in for QB to provide your Personal Information to them.
Academic Researchers	We may share your personal data for activities such as statistical analysis and academic study, but only in a pseudonymised format.
Law Enforcement and Data Protection Authorities	Notwithstanding anything to the contrary, we may release your Personal Information to third parties: (1) in order to comply with valid legal requirements such as a law, regulation, search warrant, subpoena or court order; or (2) in special cases, when we believe it is necessary to share information in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, or situations involving potential threats to the physical safety of you or any other person.

8. Data retention and deletion

We keep your personal data only as long as necessary to provide you with the QB Website and for legitimate and essential business purposes, such as maintaining the performance of the QB Website, making data-driven business decisions about new features and offerings, complying with our legal obligations, and resolving disputes.

If you request, we will delete or anonymize your personal data so that it no longer identifies you, unless, we are legally allowed or required to maintain certain personal data.

9. Keeping your personal data safe

We are committed to protecting our users’ personal data. We implement appropriate technical and organizational measures to help protect the security of your personal data; however, please note that no system is ever completely secure. We have implemented various policies including pseudonymization, encryption, access, and retention policies to guard against unauthorized access and unnecessary retention of personal data in our systems.

Your password protects your user account, so we encourage you to use a unique and strong password, limit access to your computer and browser, and log out after having used the QB Website.

10. Children

The following sets forth the QB Website information gathering and dissemination practices relating to information collected from children. The QB Website is not intended for use by children under age thirteen (13). No one under age 13 is allowed to provide any Personal Information. As a result, we do not knowingly solicit Personal Information from children and do not ask them to disclose such information, other than that information necessary to determine their age.

If a child is between 13 and 16, they may use our website only with a parent's or guardian's consent and only to the extent such parent or guardian has agreed to our Terms of Use and Privacy Policy. We advise parents to discuss with their children restrictions regarding the disclosure of personal information on the Internet. If a child is between 13 and 16 and is located in the European Union, we are required by the General Data Privacy Regulations (“GDPR”) to obtain parental consent if the student is applying to programs which necessitate the sharing of data with our partners, including but not limited to the CPS Programs and the College Match.

Notwithstanding anything to the contrary, we may knowingly collect and use a child's personal information for the sole purpose of responding to a single request by the child.

11. Parental Access

QB is the operator of the QB Website. Please send an email or letter to QB if you would like to do any of the following:

Access Personal Information that has been collected from your child
Correct factual errors in such information
Request to have this information deleted
Request that we no longer collect or maintain such information from your child

Please be sure to include your email address and telephone number where we can reach you.

12. Changes to this Privacy Policy

We may occasionally make changes to this Policy.

When we make material changes to this Policy, we’ll provide you with prominent notice as appropriate under the circumstances, e.g., by displaying a prominent notice within the QB Website or by sending you an email. We may notify you in advance.

Please make sure you read any such notice carefully.

13. Contact us

If you have any questions, comments or concerns regarding our Privacy Policy and/or practices, please send an email to [email protected].