PRIVACY NOTICE

 

Last Updated: December 27, 2023

 

Educational Computer Systems, Inc., a Global Payments company,  ("ECSI," "us", "we" or "our") respects your rights and preferences regarding data privacy. In this Privacy Notice ("Notice"), we describe how we collect, use, disclose, and dispose of the personal information that we collect from users of our U.S. websites, forums and blogs ("Sites") that link to this Notice, as well as from our U.S. prospects and customers and their personnel.

 

Please note that this Notice does not describe our processing of borrower personal information in connection with our provision of student loan processing services. If you are a borrower, and your loan is serviced by ECSI, you should refer to the separate privacy notice available here. That separate notice describes the personal information that we collect and process about you as a borrower, as well as whether and when we disclose that personal information, and what rights you may have with respect to such disclosure.

 

ECSI also maintains specific privacy notices for job applicants, employees, and contractors through Global Payments, Inc.  If you are a job applicant, employee, or contractor and need a copy of the applicable privacy notice, please contact us at privacy@globalpay.com

 

In this Notice, we provide the following information about our collection and processing of personal information from and about users of our Sites, as well as our U.S. prospects and customers and their personnel:

 

     PERSONAL INFORMATION WE COLLECT AND HOW WE USE IT

     HOW WE DISCLOSE PERSONAL INFORMATION

     TRANSFERRING PERSONAL INFORMATION GLOBALLY

     DATA SECURITY AND DATA RETENTION

     COOKIES AND OTHER TRACKING TECHNOLOGIES

     EXTERNAL LINKS

     CHILDREN

     YOUR LEGAL RIGHTS

     OTHER INFORMATION

     CONTACT US

     REGION-SPECIFIC INFORMATION

 

PERSONAL INFORMATION WE COLLECT AND HOW WE USE IT

 

“Personal information” is information that identifies you as an individual or relates to an identifiable individual. Subject to your consent if required by law, we may collect the following types of personal information about you:

 

     Basic Identifying Information, including your full name, postal address, e-mail address, phone number, username or other account credentials, or other similar identifiers.

     Device Information and Other Unique Identifiers, including device identifier, internet protocol (IP) address, cookies, pixel tags, or similar unique identifiers.

     Internet or Other Network Activity, including browsing or search history and information regarding your interactions with our Sites.

     Commercial Information, including information about the products and services we provide to you, your access and purchase history, and other information about your commercial activity.

     Professional and Employment-Related Information, including your role or status with the school or other organization with which you are affiliated. 

     Information You Provide, including your communications with us and any other content you provide (such as if you report a problem or otherwise engage with our Sites).

     Audio and Visual Information, including videos and recordings of your voice (such as when we record calls or videos for quality assurance or other business activities).

 

How we use the personal information we collect. Subject to your consent where required by law, we may use personal information about you to:

 

     Create, maintain or provide service for your account

     Process or fulfill requests from you

     Respond to customer service requests from you

     Verify your information

     Process payments

     Undertake activities to maintain the quality, safety or integrity of the Sites or our services, including to repair, improve, upgrade, or enhance the Sites or our services

     To conduct our operations and for other general business purposes

     To conduct audits and enable internal record keeping and administration of records

     Maintain data security, including detecting and responding to security incidents, protecting you and us from fraud or other illegal activity, and prosecute individuals responsible for that activity

     Monitor our Sites and track information about our interactions with you, including gathering usage data and other analytic information

     To personalize your experience when you use the Sites

     Other uses that are required for us to meet our legal, contractual or regulatory requirements

Sources of personal information. We collect information from various sources, including the following:

 

     Information that you provide to us: We collect personal information that you provide to us when you set up an account with us, visit our Sites, use our services, or communicate with us. For example, if you register for an account with us, we may request your name, contact information and other information.

     Information collected from third parties: We may collect information about you from third parties in the course of providing our services. For example, we may collect personal information like your name, contact information and employment status from your college or university in order to provide you with access to our services as an authorized user.

     Information collected through technology: When you visit our Sites or interact with an email we send to you, we may collect certain information automatically, such as your account or device identifier, and usage information such as pages that you visit, information about links you click, the types of content you interact with, the frequency and duration of your activities, and other information about how you use our services.  You have the ability to express your preference regarding some of the ways we collect information through technology in some of our services (see “Cookies and Other Tracking Technologies” for more information).

The business purpose for our processing of personal information. Our primary business purpose for processing personal information about you is to perform the services outlined in our contracts with our customers. We may also use personal information about you to enable the following additional business purposes: (1) detecting and managing security incidents or fraudulent activity, (2) providing customer service, fulfilling requests, and other functions directly related to the services, (3) maintaining our software including debugging and repairing errors, and (4) maintaining the quality of the services and developing enhancements and improvements to meet our customer needs.

 

Data anonymization and aggregation. Subject to your consent if required by law, we may anonymize or aggregate personal information about you so that you are not identified or identifiable from it, in order to use the anonymized or aggregated data. For example, we may use anonymized or aggregated data for statistical analysis including to analyze trends, for product development, and for risk assessments and cost analysis. We may disclose anonymized or aggregated data to our parents, subsidiaries, affiliates or with other third parties.  This Notice does not restrict ECSI's use or disclosure of any anonymized or aggregated information.

 

HOW WE DISCLOSE PERSONAL INFORMATION

 

We disclose personal information as necessary to operate our Sites and provide the services. Except as otherwise specified, we may disclose any of the categories of personal information about you in the manner and for the purposes described below:

 

     With ECSI affiliates where such disclosure is necessary to provide you with our services or to manage our business.

     With third-party service providers. For example, we disclose personal information to information technology (IT) service providers who help manage our back office systems or administer our Sites and services. Third-party service providers may also include (without limitation) legal, accounting, auditing, consulting, or other professional service providers.

     With our customer on whose behalf we interact with you in the provision of the services. For example, ECSI may disclose the personal information relating to customer personnel to the relevant customer, consistent with the terms of our contractual agreement(s) with that customer.

     With banks and payment providers to authorize and complete card payments.

     With logistics service providers to enable the delivery of packages to individuals.

     With other third parties to whom you direct us to disclose defined categories of personal information about you.

     With regulators including state and federal agencies, and other parties required to enable compliance with laws, regulations and industry standards related to our services;

     In response to a court order or a request for cooperation from a regulatory, law enforcement, or other government agency; to establish or exercise our legal rights; to defend legal claims; or as otherwise required or permitted by applicable laws and/or regulations;

     When we believe that disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing; to protect and defend the rights, property or safety of ECSI, its customers, staff, suppliers or others; and

     To third parties in connection with any proposed or actual reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our assets or stock (including in connection with any bankruptcy or similar proceedings).

 

TRANSFERRING PERSONAL INFORMATION GLOBALLY

 

Subject to your consent if required by applicable law, we may appoint an affiliate company to process personal information in a service provider role. Our affiliates are located around the globe.  This means that personal information about you may be transferred to and stored in the United States or in another country outside of the country in which you reside, which may be subject to different standards of data protection than your country of residence.  Where applicable, we will take appropriate steps to transfer personal information in accordance with applicable law.

 

DATA SECURITY AND DATA RETENTION

 

We take the security and privacy of personal information seriously. We maintain administrative, technical and physical safeguards designed to protect the personal information you provide against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.

 

Any suspected attempt to breach our policies and procedures, or to engage in any type of unauthorized action involving our information systems, is regarded as potential criminal activity. Suspected computer mischief may be reported to the appropriate authorities.

 

Please remember that communications over the internet such as emails are not secure. We seek to keep secure personal information submitted to us through the Sites in accordance with our obligations under applicable laws and regulations. However, like all website operators, we cannot guarantee the security of any data transmitted through the internet, including the Sites.

 

 

We retain the personal information we collect for different periods of time depending on what it is and how we use it. In some contexts, we will provide additional information about retention as you use the services.  When we collect personal information, we will retain it only for as long as is necessary to complete the legitimate business or legal purposes for which we collected it. The criteria used to determine our retention periods include:

 

     The length of time we have an ongoing relationship with you and provide services to you, for example, for as long as you have an account with us or continue to use our services, and the length of time thereafter during which we may have a legitimate need to reference personal information to address issues that may arise;

     Whether there is a contractual obligation to which we are subject, for example, our contracts with our customers may specify a certain period of time during which we are required to maintain the information on behalf of our customers;

     Whether there is a legal obligation to which we are subject, for example, certain laws require us to keep records for a certain period of time before we can delete them; and

     Whether retention is advisable in light of our legal position, such as in regard to applicable statutes of limitations, litigation, or regulatory investigations.

 

COOKIES AND OTHER TRACKING TECHNOLOGIES

 

A "cookie" is a text file that is stored to your browser when you visit a website.

 

Unique device identifiers like IP address or UDID recognize a visitor's computer or other device used to access the internet. Unique device identifiers are used alone and in conjunction with cookies and other tracking technologies for the purpose of "remembering" computers or other devices used to access the Sites.

 

We may also use other technologies like pixels or tags that allow us to measure responses to our email communications.

 

Cookies and similar tracking technologies are used to help us retain information about your use of our Sites.  Using cookies, we collect information like country location, language preference and other settings. Cookies can also help us to operate our services more efficiently and securely, remember you for future visits and enhance your user experience by providing real-time tools including user guides and chatbots.  We also gather statistical information about the use of our services in order to continually improve their design and functionality, understand how they are used, and assist us with resolving questions regarding them.

 

Cookies can be classified by duration and by source:

 

     Duration. The Sites use both "session" and "persistent" cookies. Session cookies are temporary - they terminate when you close your browser or otherwise end your "active" browsing session. Persistent cookies remember you on subsequent visits. Persistent cookies are not deleted when you close your browser, and they will remain on your computer or other device unless you choose to delete them (see below for "How to Delete or Block Cookies and Other Tracking Technologies").

     Source. Cookies can be "first-party" or "third-party" cookies, which means that they are either issued by or on behalf of ECSI or by a third-party operator of another website.  The Sites use both first-party and third-party cookies.

The cookies that we may use on the Sites fall into the following categories:

 

     Strictly Necessary Cookies. These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions taken by you such as logging in or filling in forms. You can set your browser to block or alert you about these cookies, but blocking them may impede the functionality of the Sites.

     Performance Cookies. These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site. All information these cookies collect is aggregated. If you do not allow these cookies we will not know when you have visited our site, and will not be able to monitor its performance.

     Functionality Cookies. These cookies enable the Sites to provide enhanced functionality and personalization. They may be set by us or by third-party providers whose services we have added to our pages. If you do not allow these cookies then some of these services may not function properly.

How to Delete or Block Cookies and Other Tracking Technologies

We do not currently respond to browser Do-Not-Track signals.  If you do not want information collected through the use of cookies, you can use the Cookie Settings banner or icon on the Site to make selections about the use of cookies, where applicable on some Sites.  Additionally, most browsers allow you to automatically decline cookies or be given the choice of declining or accepting a particular cookie (or cookies) from a particular website.  You may also refer to http://www.allaboutcookies.org/manage-cookies/index.html. If, however, you do not accept cookies, you may experience some inconvenience in your use of our services.  You also may not receive advertising from us that are relevant to your interests and needs.

 

EXTERNAL LINKS

 

ECSI may provide links on our Sites to other third-party websites or services that are not under our control. We do not endorse or make any warranty of any type regarding the content contained on such third-party websites or services or regarding the products and services they offer. Please be aware that we are not responsible for the privacy practices of the operators of other websites or services.  We encourage our users to be aware when they leave our Sites You should read any other applicable privacy and cookies notices carefully before accessing and using third-party websites or services.

 

CHILDREN

 

The Sites and our services are not intended for use by children. We do not solicit or knowingly accept any personal information from persons under the age of 18. Please do not use the Sites or our services if you are under the age of 18.

 

YOUR LEGAL RIGHTS

 

If you interact with our Sites or services for the purpose of engaging in a direct relationship with us, subject to certain exceptions, and in some cases dependent on how you interact with our Sites or services, you may have the right to:

     Know whether we process personal information about you;

     Know how the personal information is used;

     Access, request and receive the personal information we have collected in a portable manner;

     Opt out of having your personal information sold, “shared”;

     Request that we correct inaccuracies in the personal information; and

     Request that we delete personal information about you.

 

You may contact us using the information in the “Contact Us” section of this Notice for additional information about how to exercise your rights. In addition, if you are a resident of California or another jurisdiction with similar laws, please see the “Region-Specific Information” section below for further details on how to exercise your privacy rights.

 

OTHER INFORMATION

 

Privacy Act Notice. The Privacy Act of 1974 requires that the following notice be provided to you: The authorities for collecting the requested information from and about you are §421 et seq., §451 et seq., or §461 of the Higher Education Act of 1965, as amended (20 U.S.C. 1071 et seq., 20 U.S.C. 1087a et seq., or 20 U.S.C. 1087aa et seq.) and the authorities for collecting and using your Social Security Number (SSN) are §§428B(f) and 484(a)(4) of the HEA (20 U.S.C. 1078-2(f) and 1091(a)(4)) and 31 U.S.C. 7701(b). Participating in the Federal Perkins Loan (Perkins Loan) or Health Profession Loan Program and giving us your SSN are voluntary, but you must provide the requested information, including your SSN, to participate. The principal purposes for collecting the information, including your SSN, are to verify your identity, to determine your eligibility to receive a loan or a benefit on a loan (such as a deferment, forbearance, discharge, or forgiveness) under the Perkins Loan and Health Profession Loan Program, to permit the servicing of your loans, and, if it becomes necessary, to locate you and to collect and report on your loans if your loans become delinquent or default. We also use your SSN as an account identifier and to permit you to access your account information electronically. The information in your file may be disclosed, on a case-by-case basis or under a computer matching program, to third parties as authorized under routine uses in the appropriate systems of records notices. The routine uses of this information include, but are not limited to, its disclosure to federal, state, or local agencies, to private parties such as relatives, present and former employers, business and personal associates, to consumer reporting agencies, to financial and educational institutions, and to guaranty agencies in order to verify your identity, to determine your eligibility to receive a loan or a benefit on a loan, to permit the servicing or collection of your loans, to enforce the terms of the loans, to investigate possible fraud and to verify compliance with federal student financial aid program regulations, or to locate you if you become delinquent in your loan payments or if you default. To provide default rate calculations, disclosures may be made to guaranty agencies, to financial and educational institutions, or to state agencies. To provide financial aid history information, disclosures may be made to educational institutions. To assist program administrators with tracking refunds and cancellations, disclosures may be made to guaranty agencies, to financial and educational institutions, or to federal or state agencies. To provide a standardized method for educational institutions to efficiently submit student enrollment statuses, disclosures may be made to guaranty agencies or to financial and educational institutions. To counsel you in repayment efforts, disclosures may be made to guaranty agencies, to financial and educational institutions, or to federal, state, or local agencies. In the event of litigation, we may send records to the Department of Justice, a court, adjudicative body, counsel, party, or witness if the disclosure is relevant and necessary to the litigation. If this information, either alone or with other information, indicates a potential violation of law, we may send it to the appropriate authority for action. We may send information to members of Congress if you ask them to help you with federal student aid questions. In circumstances involving employment complaints, grievances, or disciplinary actions, we may disclose relevant records to adjudicate or investigate the issues. If provided for by a collective bargaining agreement, we may disclose records to a labor organization recognized under 5 U.S.C. Chapter 71. Disclosures may be made to our contractors for the purpose of performing any programmatic function that requires disclosure of records. Before making any such disclosure, we will require the contractor to maintain Privacy Act safeguards. Disclosures may also be made to qualified researchers under Privacy Act safeguards.

 

Changes and Updates. We reserve the right, in our sole discretion, to modify, update, or otherwise change this Notice. The “Last Updated” legend at the top of this Notice indicates when this Notice was last revised.  Any changes will become effective when we post the revised Notice on our services, including our Sites.

 

CONTACT US

 

If you have questions about this Notice, or if you want to exercise your rights as described in this Notice, you can submit a request by completing this form or may contact us as follows:

 

ECSI

1200 Cherrington Pkwy, Suite 200

Moon Township, PA 15108

privacy@globalpay.com

888-549-3274

 

If you make a request to exercise a privacy right, we will verify and respond to your request consistent with applicable law, taking into account the type and sensitivity of the personal information subject to the request.  We may decline to honor your request where an exception applies.  In order to honor any access, deletion, or similar request, we will require you to provide enough information for us to verify your identity. For example, we may ask you for information associated with your account, including your contact information or other identifying information. If you would like your agent to make a request on your behalf, if permitted under applicable law, the agent may exercise those rights as noted above.  We will process the agent’s request consistent with applicable law.  As part of our verification process, we may request that the agent provide, as applicable, proof concerning their status as an authorized agent.  In addition, we may require that you verify your identity as described in this section or confirm that you provided the agent permission to submit the request.

REGION-SPECIFIC INFORMATION

Information for Residents of California and Other Similar Jurisdictions  

This section supplements the above Notice and further describes how we collect, use, and disclose the personal information we collect about residents of California and other similar jurisdictions.

Categories of Personal Information We Collect and Our Purposes for Collection, and Use, and DisclosureThe following chart details which categories of personal information we collect and process, as well as which categories of personal information we disclose to third parties for our operational business purposes, including within the preceding 12 months.

Categories of Personal Information (See the “Personal Information We Collect and How We Use It” section for a description of each category of Personal Information)

 

Disclosed to Which Categories of Third Parties for Operational Business Purposes

Processing Purposes

Basic Identifying Information; Device Information and Other Unique Identifiers; Internet or Other Network Activity; Commercial Information; Professional and Employment-Related Information; Information You Provide

Please see the “How We Disclose Personal Information” section for a list of the categories of third parties to whom we may disclose these categories of personal information. 

Please see the “How We Use the Personal Information We Collect” section for a list and description of the applicable processing purposes for these categories of personal information.

Audio and Visual Information

Affiliates; distributors of our products and services; service providers; regulators; legal authorities and other third parties in order to comply with laws, regulations, and standards; other parties in litigation

       Provide our services and customer support

       Operations and general business purposes

       Improve and develop new products and services

       Fraud prevention and security

       Legal and compliance

 

Do Not Sell or Share My Personal Information.  Unless otherwise disclosed in a specific notice, and subject to your consent where required by applicable law, we do not sell your personal information to third parties for monetary compensation.  We do not knowingly sell or “share” (for purposes of cross-context behavioral advertising) the personal information, including the sensitive personal information, of minors under 16 years of age.

The non-borrower-facing Sites may use cookies, including some cookies that are created by other companies and placed on your browser when you visit our website. We use those cookies to improve your experience and to gather information about our customers and the performance of our website. However, the companies who provide those cookies to us also have access to the data collected through them, and they may use that data for targeted advertising purposes. Our use of those third-party cookies could therefore be considered a “share” of your personal information under California law or processing for targeted advertising under other privacy laws. If you are a resident of California or another jurisdiction with similar laws, that means you have the right to opt out. If you have not done so already, you can opt out of the placement of all non-necessary cookies by adjusting your Cookie Settings. 

Collection, Use, and Disclosure of Sensitive Personal Information.  Subject to your consent where required by applicable law, we collect, process, and disclose sensitive personal information for purposes of: providing goods or services as requested; ensuring safety, security, and integrity; countering wrongful or unlawful actions; short term transient use such as displaying first party, non-personalized advertising; performing services for our business, including maintaining and servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of our business; activities relating to quality and safety control or product improvement; and other collection and processing that is not for the purpose of inferring characteristics about an individual. We do not use sensitive personal information beyond these purposes.

Rights and Requests

Right to know about personal information collected, used, disclosed, sold, and “shared”

You have the right to know whether we process personal information about you, and to access such personal information.  If you are a California resident, you may also request that we disclose to you:

●     the categories of personal information we have collected about you and the categories of sources from which we collected such personal information;

●     the business or commercial purpose for which we collected, “shared,” or sold the personal information about you;

●     the categories of personal information about you that we “shared” or sold and the categories of third parties with whom we “shared” or to whom we sold the personal information about you; and

●     the categories of personal information about you that we disclosed for a business purpose, and the categories of third parties to whom we disclosed that information for a business purpose.

Right to receive a copy of personal information

You have the right to request that we provide the specific pieces of personal information, including a copy of such personal information in a portable format.

Right to opt-out of the sale of personal information

You may request that we do not sell personal information about you to third parties.

Right to opt-out of targeted advertising, including the “sharing” of personal information for cross-context behavioral advertising

You may request that we opt you out of targeted advertising, including that we stop “sharing” personal information about you for purposes of cross-context behavioral advertising.  See the “Do Not Sell or Share My Personal Information” section for more information on opting out of certain cookies on the Sites.

Right to request deletion

In some circumstances, you have the right to have personal information about you deleted.

Right to equal service and prices (“non-discrimination”)

Your choice to exercise your privacy rights will not be used as a basis to discriminate against you in services offered or pricing.

Right to request correction

You have the right to request that we correct inaccuracies in your personal information.

Right to limit the use and disclosure of sensitive personal information

In some circumstances, you may request that we limit the use and disclosure of your sensitive personal information.

Right to appeal

Depending on your state of residence, if we refuse to take action on your request, you may appeal this refusal within a reasonable period after you have received notice of the refusal.   To appeal, you can contact us at privacy@globalpay.com or complete this form and select “Appeal a decision about a previous request” under “Type of Request.”

You can submit a request for any of the above rights by using the contact information in the “Contact Us” section of this Notice.

California Shine the Light

If you are a resident of California, you may request information concerning the categories of personal information (if any) we share with third parties or affiliates for their direct marketing purposes. If you would like more information, please submit a written request to us using the information provided in the above “Contact Us” section of this Notice.