STUDENT PRIVACY POLICY

Last Updated – May 2021

GradSnapp is a cloud-based, student management platform designed to help organizations focused on school completion improve the chances that their students graduate from college or other educational institutions. GradSnapp is owned and operated by College Success Tools, LLC (“we” or “us”).

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

When this Policy refers to “Customers,” it means the organizations who have licensed GradSnapp. When this Policy refers to “students” it means the students that are participating in Customers’ school completion programs.

1.  Information Provided by Customers

When Customers use GradSnapp, their authorized users submit student information to facilitate administration of school completion programs. This information may include name, address, date of birth, phone number, email address, high school, high school graduation date, and other demographic or academic information.  This may also include other information relevant to Customers’ education purposes including texts and emails from students and notes written by Customers’ authorized users.   GradSnapp requires each Customer to confirm that it has obtained all necessary consents before submitting related data into GradSnapp.

GradSnapp does not solicit, or knowingly accept, any of the following types of information: religious affiliation, political affiliation, voting history, biometric data, social security number, credit card numbers, credit records, criminal records, or medical records.

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

As a student management platform for school completion programs primarily aimed at college completion, GradSnapp is not designed for individuals under the age of 13, nor does it solicit or knowingly accept any information from individuals under the age of 13.

3.  GradSnapp Usage Information and Cookies

When using GradSnapp, we collect certain usage information including the Internet Protocol address associated with the user’s computer, login timestamp, browser type and version, and computer operating system. GradSnapp also uses cookies which are small data files saved on a user’s device that store browser information and which enable us to recognize users on return visits.   (Information regarding the management and deletion of cookies is available in the help section of most browsers, although changes may impact certain GradSnapp functions).

This usage information helps us to diagnose technical problems and to facilitate and improve GradSnapp services.

4.  How We Use and Disclose Information

We do not knowingly use student data in any of the following ways:

  • To engage in targeted advertising – either on Gradsnapp itself or on any other sites by virtue of information collected on Gradsnapp;
  • To amass a profile about a student – except in furtherance of school purposes, or as otherwise explicitly contractually agreed and subject to applicable law;
  • To sell it – except in a Permitted Company Acquisition (defined below); and
  • To disclose it to third parties – unless in compliance with this Policy and applicable law.

Consistent with the foregoing, we may disclose personally identifiable student data in the following circumstances:

  • In furtherance of Gradsnapp’s school purposes, including its school completion mission;
  • When directed by Customers (subject to their contractual commitments relating to any requisite consents);
  • To our third-party service partners, provided that those providers are contractually required to protect the data, not to misuse the data, and not to disclose it without authorization;
  • To ensure legal and regulatory compliance;
  • To respond to or participate in a judicial process;
  • To protect the safety of others or the security of Gradsnapp;
  • To resolve a problem or support issue;
  • To investigate a suspected violation of the terms under which GradSnapp provides its services;
  • 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 (a “Permitted Company Acquisition”);
  • To maintain, develop, support, improve or diagnose Gradsnapp;
  • To facilitate legitimate research purposes under the authority of state or federal law (and subject to further applicable statutory requirements); and
  • If and as applicable, to a state or local educational agency for statutorily authorized school purposes, as permitted by state or federal law.

Consistent with the foregoing, and subject to applicable law, we may use student data that has been de-identified: to improve our educational products; to demonstrate the effectiveness of our educational products (including in marketing materials); to share aggregated deidentified student information for the development and improvement of educational sites, services or applications; for academic research; and for 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 third–party providers and may be turned on or off at the sole discretion and control of Customers. Examples of features that are operated by third–party providers include texting and emailing functions, Twitter integrations, and, if added by Customer or its users in their sole discretion, links to third–party websites.  As described above, we require our third–party service providers with whom we contract to agree to certain obligations regarding the use of student data.  However, they are also governed by their own privacy policies, and we encourage Customers and users to read them if Customers choose to use these features.  With respect to third–party content providers and third–party websites added by Customers, we do not control, and therefore are not responsible for, their content.

We also use third-party service providers to assist us in collecting and understanding usage information (see GradSnapp Usage Information and Cookies section).

6.  How Customers Can Modify Information

Customers’ authorized users may edit, update, or delete information about students through the Gradsnapp administrator portal or dashboard.  Students and parents are encouraged to work directly with Customers to review and correct student information.  However, if a student or his or her parent nevertheless needs to access, correct, or delete student information, as may be required by applicable law, please email customer.service@collegesuccesstools.com.

7.  Security

We are committed to protecting the security, integrity and confidentiality of the data through the use of reasonable physical and technical safeguards.

For example, GradSnapp uses Transport Layer Security encryption and server authentication technology to protect data when GradSnapp is accessed using a supported web browser.  We host student information in secure servers and cloud-based environments that use firewalls and other industry-standard technology to try to prevent interference or access from outside intruders. We also require unique account identifiers, usernames, and passwords that are required for GradSnapp access, and we require that Customers and their authorized users maintain the confidentiality of this information. The Internet, however, is not perfectly secure, and GradSnapp is not responsible for security breaches that are not reasonably within its control.

Please notify us immediately upon becoming aware of any unauthorized use of an account, loss of account credentials, or any suspected security breach.

8.  Data Retention 

After termination of an agreement, GradSnapp may retain data for a limited time if consistent with appliable law – for example, to facilitate service continuity if a Customer chooses to reactivate its GradSnapp services.  At the end of our data retention period, we delete and destroy all personal information associated with the terminated Customer’s account.  Student data will also be deleted upon Customer request as required by applicable law.

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

9. International Users

Customers located outside of the United States should be aware that provided information is transmitted to and processed in the United States.  Continued Use of GradSnapp represents consent to this use.

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.

In addition, we allow Customers to send text messages, email messages and other notifications to students through GradSnapp. Students that wish to opt out of these communications should reach out to the Customer in whose school completion program they participate or otherwise use the opt-out mechanisms incorporated in these communication tools.

11.  Updates to This Policy 

We may update this policy from time to time.  Such updates will be posted publicly on our website and/or GradSnapp, and via any other methods required by applicable law.

12.  Contact

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