Last Updated: June 6, 2023
Important Information About This Policy
By providing us with personal information or using the Services, you expressly consent to the information-handling practices described in this Policy. If you do not agree with this Policy, please do not use the Services or provide us with your information.
While we always aim to provide complete and transparent information about how we process your personal information, we reserve the right to amend or update this Policy from time to time or to create additional policies in order to accurately reflect changed circumstances or new legal requirements. To assist us in ensuring that we can provide the most accurate information possible, we ask that you check this Policy for updates.
As a software and professional services provider, we may collect information from applicants when they apply to specific awards that is required by and specific to the award sponsor. When we collect award-specific application information, we are acting as a service provider on the award sponsor’s behalf. As such, we recommend you review the award sponsor’s privacy policies to learn more about their data collection, use, and disclosure practices.
We also ask that where we have an ongoing relationship with you, and any of the data you have provided is no longer accurate, that you keep us informed of this so we can amend our records accordingly.
Information We Collect and Receive
A. Personal Information
For the purposes of this Policy, “personal information” is any information that identifies, relates to, or can be used to contact a particular individual. The types of personal information we may collect through the Services can be grouped as follows:
- – First name, last name, email address (business or personal), position, name and mailing address of your organization, billing address, and telephone number (business or personal).
- – If you are an applicant, your academic year, school information, graduation year, GPA, areas of studies, athletics information, transcripts, or other education records you may submit in connection with an application.
- – If you are an applicant, your employment history, resume, or employment-related references.
- – If you are an applicant, gender, ethnic, religious or spiritual identity, citizenship information, self-identified disability, or veteran status or affiliation.
- – If you are an applicant, letters of personal reference, essays, artwork, creative materials or works, or other documents and personal materials an award sponsor may request from you in connection with your application.
- – Details regarding informational and promotional materials you may have requested or received from us, the services in which you are interested, your receipt of promotional communications, and information on your marketing or communication preferences.
- – Details regarding your preferred methods for distributing or receiving scholarship awards or funds, the details of any awards received or distributed, including dates of distribution or award, amounts, and designated applicants and schools.
- – If you are an applicant, your bank account information for the purposes of receiving any applicable award deposits.
- – Copies of communications and inquiries you have submitted to us, including through email, calls, and features available in connection with the Services.
- – Details about any issues you are experiencing that require technical support that you submit to us through our contact portals or provide in response to us following up on your request for assistance.
- –Details regarding how and when you use the Services, including the device used to connect to the Services, your IP address and device identifier, the frequency and duration of your usage, the pages you view, what websites or search terms referred you to the Services, and information about your interaction with the Services.
We collect this information when you visit or navigate the Services, fill in forms on the Services, fill out an application for an award via the Services, register as a contributor and submit information via the Services, request information on the Services, communicate with us (including by phone, email, or otherwise), visit or engage with our social media pages, participate in surveys or sponsored activities, or otherwise provide us with personal information.
Please note that we may aggregate or anonymize the foregoing types of information such that they are no longer capable of identifying you, in which case they are no longer considered “personal information.” We may also collect information about you from third-party sources and information about you that is publicly available.
B. Automatically Collected Usage and Device Information
Like most websites, the Services uses various technologies to automatically collect information about visitors. Those technologies include:
- Analytics cookies. We may use analytics cookies to track information how the Services is used so that we can make improvements. We may also use analytics cookies to test new advertisements, pages, features or new functionality of the Services to see how our users react to them.
- Log Files and Device Identifiers. We use log files to track actions occurring on the Services and collect data about visitors, including IP address, browser type, Internet service provider, referring/exit pages, date/time stamps, and device identifiers.
- Web beacons and other technologies. The Services may use other tracking tools, including web beacons (also known as clear gifs, pixel tags, and single-pixel gifs), which are small electronic images embedded in content and email messages that are not ordinarily visible to users. Web beacons allow us to track pages and content accessed and viewed by users, as well as to monitor email readership.
The information collected through these technologies may be combined with personal information or aggregated with other information from Website visits. We may share information about your use of the Services with our advertising and analytics partners, who may combine it with other information that you previously provided to them.
C. Information from Other Sources
We may obtain both personal and non-personal information about you from other users of the Services, business partners, vendor partners, contractors, suppliers, and other third parties and add it to other information we have collected. We, and the third parties we engage, may combine information we collect from you over time, and across the Services, with information obtained from other sources. This helps us improve the information’s overall accuracy and completeness, and also helps us better tailor our interactions with you.
D. Social Media
If you interact with us on any social media platform: (i) depending on your social media privacy settings, the personal information that you submit on the social media platform may be read, collected, or used by us as described in this Policy, and (ii) where we respond to any interaction with you on social media, your account name/handle may be viewable by any and all members or users of our social media accounts. Social media platforms operate independently from Kaleidoscope and we are not responsible for the personal information that you choose to submit or link on any social media platform. We encourage you to review the privacy policies and settings of any social media platform with which you interact to help you understand their privacy practices.
How We Use Personal Information
We (or service providers acting on our behalf) may use the personal information identified above for the following purposes:
- Providing the Services, including facilitating the connection of applicants and award providers in connection with facilitating applications and awards.
- Negotiating, entering into, and managing our relationship and agreements with you or your organization, including providing our services to you or your organization.
- Providing and optimizing your experience accessing or using the Services and ensuring that our content is presented to you in the most effective manner.
- Responding to your inquiries and communicating with you, including regarding our services, our agreements with you or your organization, and other issues.
- Sending you promotional or informational communications and solicitations, tracking your marketing preferences, and for our internal marketing purposes.
- Managing customer service issues, including issues relating to the performance of the Services, technical concerns, and related feedback.
- Developing, updating, and improving our Services, customer service, and customer experience, and otherwise improving our knowledge and insights regarding potential education services or those who partner with us for our services.
- Preventing and detecting fraud, financial crime, hacking activities, security breaches, and other unlawful activities in connection with the Services or the use of our services.
- Enforcing our agreements, complying with our legal or regulatory obligations, and defending or advancing legal claims.
- Notifying you about changes to the Services, our business, or material changes to this Policy.
- Providing you with surveys or otherwise soliciting feedback from you.
- Performing other functions as otherwise described to you at the time of collection or to which you otherwise consent.
For more information about your options relating to your personal information and your communication preferences, see “Your Choices About Personal Information” below.
Our Marketing Efforts
We may send you direct marketing communications from time to time including news, updates, offers, and other announcements relating to our services and activities. We will only send marketing messages where the law allows us to do so and, in the event that you no longer wish to receive marketing communications from us, then you can always unsubscribe from our marketing communications using the functionality in the communication you have received or by contacting us at the information below.
Disclosure of Personal Information
When the information we collect about you is aggregated, anonymized, or otherwise does not identify you, we may use that information for any purpose or share it with third parties, to the extent permitted by applicable law.
In addition, we may share your information with the following types of entities:
- Business partners, service providers, and third-party vendors necessary for the performance of any contract we enter into with you. For example, we may share your personal information with our IT and system administration providers, cloud hosting providers, customer service software providers, and payment processors.
- Other users of the Services who have access to personal information you have posted or shared in a public forum or user-accessible means via the Services or expressly requested that we provide to other users, such as award providers receiving applications or contributors asked to submit applicant information.
- Marketing and advertising vendors that may assist with lead generation, hosting information relating to potential scholarship providers and potential users of our services, marketing automation, advertisement placement and targeting, and marketing campaigns and communications.
- Analytics vendors in order to understand the Services traffic and usage patterns, optimize the Services, and identify potential new partners or users of our services.
- Regulatory and governmental authorities, law enforcement agencies, and courts, as necessary to comply with applicable laws and regulations, respond to a subpoena, search warrant, or other lawful request for information, or to otherwise protect our rights.
- Our professional advisors, such as lawyers, accountants, and other similar advisors, or investors who have a need to know the information.
- Buyers or other successors prior to or in the event of a merger, acquisition, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as a part of bankruptcy, liquidation, or similar proceeding, where the information is among the assets being transferred.
- Other parties for any purpose we disclose at the time you provide the information.
Protection of Personal Information
We use appropriate administrative, technical, and physical measures to protect your personal information from loss, theft, and unauthorized use, disclosure, or modification. Please be aware that no data transmission over the Internet is 100% secure. While we strive to protect your personal information, we cannot ensure or warranty the security of any information you transmit to us and you do so at your own risk.
Your Choices About Personal Information
We respect your right to make choices about the ways we collect, use, and disclose your information. We try to offer you meaningful choices regarding your personal information. Some choices you have regarding personal information include the following.
- Marketing Emails – As required by applicable laws, you can opt-out of receiving promotional emails from us by clicking the “unsubscribe” or similar link in any such promotional emails and following the instructions provided.
- Cookies – Depending on your browser or device, you may have the option to set the browser to accept all cookies, reject all cookies, notify you when a cookie is set, or delete cookies. Each browser and device are different, so we recommend you evaluate the tools and settings available in your browser or device, as well as any available instructions for the same. Please note that if you disable or delete cookies, you may not be able to access or use certain features of the Services.
- Google Analytics and Google Ads – As discussed above, we use Google Analytics and other Google tools in connection with the Services. If you would like to refrain from having your data collected by Google Analytics, Google has developed an opt-out browser that you can use. You can find more information on how Google uses information it collects here.
- Declining to Provide Information – You can choose not to provide us with information we may request through the Services, but that may result in you being unable to use certain features of the Services, request information about our Services, or initiate other transactions with us.
- Do Not Track Mechanisms – Please note thatthe Services does not honor “Do Not Track” signals, and such signals will not impact the operation of the Services.
- Jurisdiction-Specific Choices—Please review the “Rights Afforded to Certain Individuals” section below to learn more about the choices that may be available to you based on where you reside.
In addition to the above, you may contact us using the details provided at the end of this Policy with any questions about the choices relating to your personal information.
Rights Afforded to Certain Individuals
- California Residents
California Civil Code § 1798.83 (California’s Shine the Light Act) permits California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. If you are a California resident, you may ask us to refrain from sharing your personal information with certain of our affiliates and other third parties for their marketing purposes. Please tell us your preference by contacting us at the contact information below.
- Notice for Nevada Residents
Under Nevada law, Nevada “consumers” may request that “operators” of internet sites and online services refrain from the “sale” of their “covered information” to third parties (as such terms are defined under Nevada law). “Covered information” includes first and last name, address, email address, and phone number, or an identifier that allows a specific person to be contacted either physically or online. As discussed above, we share your information with certain third parties that we believe can provide you with offers and promotions for products and service of interest to you and in the other ways described above. We do not believe that our sharing in this regard would qualify as a sale under Nevada law.
- Canadian Residents
If you reside in Canada, various Canadian laws, including Canada’s Personal Information Protection and Electronic Documents Act (“PIPEDA”), may provide you certain rights with respect to your personal information, including the right to request information about the collection, use, or disclosure of your personal information, to request access to your personal information, and to challenge the accuracy and completeness of your personal information and have it amended as appropriate.
If you are a Canadian resident and would like to make a request regarding your personal information, please send a request to email@example.com with the subject line, “Canada Resident Request,” or otherwise contact us using the information in the “How to Contact Us” section below. We will attempt to respond to your request as quickly as possible but may ask you to provide additional information to enable us to locate the personal information or determine how it has been used or disclosed. We will provide you access, as appropriate, at minimal or no cost to you.
- EU/UK Residents
- Rights under GDPR
The European Union’s General Data Protection Regulation and the United Kingdom’s version of the same (collectively, the “GDPR”) afford certain rights to individuals in the European Economic Area (“EEA”). If you are in the EEA, United Kingdom, or Switzerland you have the following rights. Note, however, that not all rights apply in all circumstances.
- Right of access: subject to certain exceptions, you have the right of access to your personal information that we hold. If you are requesting access to your data in order to protect the rights of others, we may require you to validate your identity before we can release that information to you
- Right to rectify your personal information: if you discover that the information, we hold about you is inaccurate or incomplete, you have the right to have this information rectified (i.e., corrected).
- Right to be forgotten: you may ask us to delete information we hold about you in certain circumstances. This right is not absolute, and it may not be possible for us to delete the information we hold about you, for example, if we have an ongoing contractual relationship or are required to retain information to comply with our legal obligations.
- Right to restriction of processing: in some cases, you may have the right to have the processing of your personal information restricted. For example, where you contest the accuracy of your personal information, its use may be restricted until the accuracy is verified.
- Right to object to processing: you may object to the processing of your personal information (including profiling) when it is based upon our legitimate interests. You may also object to the processing of your personal information for the purposes of direct marketing and for the purposes of statistical analysis.
- Right to data portability: you have the right to receive, move, copy, or transfer your personal information to another controller when we are processing your personal information based on consent or on a contract and the processing is carried out by automated means.
With regard to the personal information discussed in this Policy, we are typically the “data controller” for such information under the GDPR. As a result, if you wish to exercise one of the rights discussed above, you may do so by submitting a written request to firstname.lastname@example.org with the subject line, “GDPR Request.” This is normally free, unless this process is unduly difficult or is clearly unfounded, repetitive, or excessive, in which case we may charge a reasonable fee or decline to respond. Once we have received your request, we will review it and contact you within thirty (30) days of receipt of your request, will notify you of any delay in processing your request and, in any event, will respond to the request within three (3) months. Please note that we may need to request specific information from you to help us confirm your identity. If you are located in the EEA, UK, or Switzerland and have a concern about our processing of your data, you may have the right to make a complaint to the appropriate data protection authority in the EEA, UK, or Switzerland.
- Lawful Basis under GDPR
We will process different types of information under different lawful bases under the GDPR depending on the nature of the information and your relationship with us. The following table describes how we plan to use your personal information and our lawful basis for doing so. We may process your personal information on more than one basis depending on the specific purpose for which we have collected or are otherwise using your information.
|Purpose/Activity||Type of Information||Basis of Processing|
|To enter into and subsequently to manage our business relationship with you or your company, including: Negotiating, entering into, and performing agreements with your company Responding to inquiries and providing customer support and serviceManaging and processing transactions for our servicesNotifying you about changes to our website, business terms, or this PolicyCommunicating with you and responding to your inquiries regarding our services, agreements with you or your company, and other issues||Contact Information Award InformationCommunications InformationFinancial InformationTechnical Support Information||Necessary for our legitimate interests (to manage our business relationships and administer our operations including through the keeping of appropriate records)Performance of a contract with youNecessary to comply with legal obligations|
|To administer our business of providing scholarship related software and services: Processing applications for various awardsFacilitating the process of an award, including depositing awards into recipients’ financial accounts||Contact InformationAcademic InformationEmployment History or InformationDemographic InformationApplication-Related InformationAward InformationFinancial Information||Necessary for our legitimate interests (to manage our business relationships and administer and facilitate our operations including our professional and software services)Performance of a contract with you|
|To administer and protect our business and website including: Maintaining business records for legal purposes and to comply with tax requirements Defending and advancing legal claims Enforcing our rights under any agreements Ensuring effective security for our services and website Conducting website maintenance Identify and address security risks and unlawful activity||Contact Information Award InformationFinancial InformationTechnical Support InformationCommunications InformationDevice and Usage Information||Necessary for our legitimate interests (running our business, facilitating administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise)Necessary to comply with legal obligations|
|To make decisions about how best to deliver relevant website content and advertisements to you, and otherwise market to you, and to better understand the effectiveness of our marketing efforts||Marketing InformationAward InformationCommunications InformationDevice and Usage Information||Necessary for our legitimate interests (better understanding website functionality and how website users navigate and interact with the site)|
|To advance and promote our business interests including contacting you regarding products, services, or promotions that may be of interest to your company, conducting surveys or soliciting feedback on our services, and updating, developing, and improving our products/services, customer service, and marketing efforts||Contact InformationMarketing InformationAward InformationDevice and Usage Information||Necessary for our legitimate interests (to enhance our services, improve our marketing strategies and develop our business)|
- Transfers from EEA, Switzerland, or UK
If we transfer personal information from the EEA, United Kingdom, or Switzerland to the United States or any other country, we will implement appropriate legal mechanisms to ensure an adequate level of personal data protection consistent with the GDPR’s requirements. For example, if the recipient country has not received an Adequacy Decision from the European Commission (such as the United States), we will rely on Standard Contractual Clauses (SCC) that have been approved by the European Commission as the lawful mechanisms for such transfers. Further, we will enter into appropriate data processing agreements with all non-EU (sub)processors that contain SCCs and define data protection standards to be employed by each (sub)processor.
Kaleidoscope is headquartered in the United States and, as a result, the information you provide to us may reside on servers or workstations located the United States. You understand and consent that information you provide may be transferred to the United States. You also understand that the data protection laws in the United States may be different from those of the country where you reside. When we transfer personal information to the United States, we will implement appropriate and suitable safeguards to protect such information as may be required by applicable data protection laws.
Links to Third-Party Websites
The Services may contain links to third-party websites. For example, the Services may link out to an article on a third-party news source or publisher website. Such websites have separate privacy policies that you should review. We do not control these third-party websites and are not responsible for the content of linked websites or those companies’ data-handling practices.
Changes to this Policy
Please note that we may change this Policy from time to time. If there are changes to our Policy, we will post them here and update the “Last Updated” date at the top of this document. Continued use of the Services after any changes is deemed to be acceptance of those changes. Accordingly, we encourage you to check the Policy periodically for updates.
How to Contact Us
For questions or more information about our privacy practices, please contact us by e-mail at email@example.com or by using the contact information provided below:
Kaleidoscope Group, PBC
212 3rd Ave N
Minneapolis, MN 55401