CUSTOMER PRIVACY POLICY

Last Updated – May 2018

GradSnapp is a comprehensive, could-based student management platform designed to help organizations focused on college completion improve the chances that their students graduate from college. GradSnapp is owned and operated by College Success Tools, LLC

This Privacy Policy (“Policy”) explains how we collect, use and protect your information in GradSnapp.

When this Policy refers to “Customers,” it means the organizations who have licensed the GradSnapp platform to administer their college completion programs. When this Policy refers to “you” or “your,” it means the students that are participating in our Customers’ college completion programs and who have provided consent to our Customers to use GradSnapp to administer data about you. When this Policy refers to “we” or “us,” it means College Success Tools, LLC.

1.  Information Provided by Customers

When Customers decide to use GradSnapp, they submit information to us about you that is necessary to create an account for you so that they can administer their college completion programs. This may include name, address, date of birth, phone number, email address, high school, high school graduation dateand other demographic or academic information.  From time to time, Customers may also import additional demographic, academic and other information about you into GradSnapp,which may include transcripts of texts and emails from you and notes written by our Customers’ staff.GradSnapp requires its Customers to obtain all consents necessary from you for any data about you to be input into the GradSnapp platform by the Customer.

2.  A Special Note About Students Under the Age of 13

As a student management platform for college completion programs, GradSnapp does not accept student information from individuals under the age of 13. Any student information relating to students who are identified as under 13 years of age will not be accepted.

3.  GradSnapp Usage Information and Cookies

When using GradSnapp, our servers automatically collect the Internet Protocol (“IP”) address associated with the user’s computer. We may also collect additional information such as login timestamp, the browser type and version, and the operating system of the computer. This information is logged to help us to diagnose technical problems and to administer GradSnapp

To collect information about the use of GradSnapp, we use cookies. Cookies are small data files sent by a website or application and stored on the computer or device at the request of that site or app. Cookies store information related to the browser to enable us to recognize the browser on return visits to GradSnapp and to remember your preferences. We use third-party service providers to assist us in collecting and understanding the usage information. Most browsers can be set to detect browser cookies and to let you reject them but refusing cookies may make it difficult to use GradSnapp. To learn more about browser cookies, including how to manage or delete them, look in the help section of your web browser.

4.  How We Use and Disclose Information

WE DO NOT SELL DATA AND WE DO NOT USE PERSONALLY IDENTIFIABLE INFORMATION FOR COMMERCIAL PURPOSES. 

In addition, we do not disclose, distribute, access or reference any personal information about you except in the following circumstances:

  • When directed by our Customers pursuant to consents they have obtained
  • To our third-party service partners to permit them to provide features and services on our behalf and as requested by Customers (see Third Party Services section for more details)
  • To resolve a problem or support issue on behalf of you or a Customer
  • To investigate a suspected violation of the terms under which GradSnapp provides its services
  • As may be required by law or as ordered by a court, in which event we shall notify the affected Customer(s) as soon as reasonably practicable
  • In the event of a reorganization, merger, sale, assignment, bankruptcy or other disposition of our business, in which case the transferred information will remain subject to the terms of this Policy

We may use non-personal information, including aggregated and/or de-identified data for a variety of purposes, subject to applicable law, including: 

  • to improve our products, e.g., to upgrade our Customers’ user experience
  • to demonstrate the effectiveness of GradSnapp, including in our marketing materials
  • for academic research or other non-commercial purposes

5.  Third Party Services

GradSnapp provides Customers with access to a variety of features which Customers may choose to use. Some of these features are operated by thirdparty providers and may be turned on or off at the sole discretion and control of CustomersExamples of features that are operated by thirdparty providers included texting and emailing.  GradSnapp maintains contracts with these thirdparty providers that ensure the such providers do not use or share your information except as may be necessary to provide their services to GradSnapp and other limited reasons, such as investigating violations, or as may be required by a court order.

GradSnapp allows Customers to add links to websites that they may then share with you.The decision to send links to you is made solely by the Customer; GradSnapp does not provide links suggested websites. We do not control, and therefore are not responsible for, the content or privacy practices of websites suggested to you by the Customer. Those websites are governed by their own privacy policies, and we encourage Customers and you to read them. 

GradSnapp allows Customers to integrate the GradSnapp platform with Twitter.  If a Customer chooses to integrate, you may see a Twitter newsfeed on your student portal in GradSnapp.  We do not control, and therefore are not responsible for, the content or privacy practices of Twitter. Twitter is governed by its own privacy policy, and we encourage Customers and you to read them.

6.  How Customers Can Modify Information

Customers may edit, update, or delete information about you through the administratorportal of GradSnapp. We also provide Customers with a dashboard that allows them to access, modify and delete information about you, as may be required by law or otherwise deemed necessary from time to time. 

7.  Security

We are committed to protecting the security, integrity and confidentiality of the data through the use of physical and technical safeguards. GradSnapp uses Transport Layer Security (TLS) encryption and server authentication technology to protect data when GradSnapp is accessed using a supported web browser.  

We host data about you in secure server and cloud-based environments that use a firewall and other industry-standard technology in an effort to prevent interference or access from outside intruders. We also require unique account identifiers, user names, and passwords that must be entered each time you or our Customers access GradSnapp. The Internet, however, is not perfectly secure and GradSnapp is not responsible for security breaches not reasonably within its control.  

We require that you and our Customers maintain the confidentiality of their user names and passwords. If you or a Customer become aware of any unauthorized use of an account, loss of account credentials or suspect a security breach, notify us immediately.  

8.  Data Retention 

As a system of record for its Customers, GradSnapp retains data at the sole discretion of Customers, and for as long as they have active agreements for GradSnapp. After termination of an agreement, GradSnapp will retain data for a limited time period in accordance with the terms of our agreements, so that Customers may retain continuity of their experience should they choose to reengage with GradSnapp. At the end of our data retention period, we securely delete and destroy all personal information associated with the terminated Customer’s account.  

Notwithstanding the above, we do retain aggregated, de-identified data for the purposes described in the section titled, “How We Use and Disclose Information.”  

9. International Users

If you are located outside of the United States, please be aware that the information you provide to us is transmitted to and processed in the United States. Data will be protected subject to this Policy and applicable law, which may be different from the laws in your country. By using GradSnapp, you agree to this.  

10. Opt-Out Policy 

We send emails to Customers with information about our products that we believe may be of interest. Customers may opt out of receiving email messages from GradSnapp by contacting us at or by clicking on the “unsubscribe” link found at the bottom of every email that we send.  

If Customers have opted out of receiving communications from us, we may still send essential communications regarding GradSnapp to Customers’ and students’ accounts, such as password change messages.  

We allow Customers to send text messages, email messages and other notifications to you through GradSnapp. You should contact your college completion program if you would like to discuss opting out of those messages.  

11.  Updates to This Policy 

You have the ability to access information about you in the student access portions of the GradSnapp platform via a username and password login.  In certain circumstances, you may update, edit, or delete information about you in GradSnapp directly by using your account to access the student portal on GradSnapp. Certain data fields can only be accessed or modified by the Customer and cannot be accessed or modified by you. If you have any concerns about such data, you must contact the Customer that administers your program and work with them directly.   

12.  Contact

If you have any questions regarding this Policy, please email GradSnapp at privacy@collegesuccesstools.com.