Last Updated: July 20, 2022
For purposes of this Policy, personal information is any information that relates to an identified person or information which, together with other information, may identify a person. It includes information that qualifies as personal information, personal data, or similar terms under applicable data privacy laws. It does not include data excluded or exempted from those laws or regulations, nor does it apply to aggregated, de-identified, or anonymized information. Nothing in this Policy will constitute an admission or evidence that any particular data privacy or information security law or regulation applies to Clarity generally or in any specific context.
Our Services are used by third parties, especially educational institutions, as a platform for end users to apply for financial aid and grants. When we process personal information on behalf of those third parties, our processing is governed by our contracts with them. This Policy does not apply in those circumstances, and you should consult those third parties’ privacy policies and other terms.
You Consent to This Policy
You should read this Policy carefully. We recommend printing and retaining a copy for your future reference. By accessing, browsing, or otherwise using the Service, you confirm that you have read, understood, and agreed with this Policy. If you do not agree to this Policy, you may not use the Service.
This Policy applies regardless of how the Service is accessed and will cover any technologies or devices by which we make the Service available to you.
We may provide you with additional privacy notices where we believe it is appropriate to do so. It is important that you read this Policy together with any other privacy notice or fair processing notice we may provide on specific occasions, so that you are fully aware of how and why we are using your data. This Policy supplements these other notices and is not intended to override them.
If you have any questions or concerns about our personal information policies or practices, you can contact us in the methods described in the “Contact Us” section below.
The Information We Collect
Information You Provide
- Creating an Account. If you create an account with us, we collect information such as your name, username, gender, date of birth, phone number, email address, physical address, and information regarding your potential financial aid applications.
- When You Use our Service. If you use our Service, we may collect certain analytical information as outlined below. We may also collect certain payment processing information, such as name, credit or debit card number, relevant security codes, or account numbers. Finally, we will collect the information necessary to complete your financial aid applications, which may include guardianship information, financial information, and other information that we clearly request at the time you submit the application.
- When You Contact Us. If you send us an email or otherwise contact us, we may collect your email address, information regarding your school affiliations, and any information that you provide in the contents of the message.
- Job Applications and Employment. If you apply for a job with or are employed or contracted by us, we will collect various pieces of information about you.
Information We Collect as You Navigate Our Service
We automatically collect certain information as you use the Service, such as the following:
- Usage Information. We may collect information automatically through your use of the Service, such as which of the pages on the Service you access, the frequency of access, the duration of your visit and what you click on while on our Service.
- Device Information. We may collect information about the device you are using, such as hardware model, operating system, application version number, browser, and IP addresses.
- Mobile Device Information. When you access our Service via a browser on your mobile device, we may also collect mobile network information, including telephone number, the unique device identifier assigned to that device, mobile carrier, operating system, and other device attributes.
- Location Information. We may collect information about your actual location which may be determined from GPS and other sensors that may reveal information on or nearby devices, Wi-Fi access points, and cell towers.
How Do We Use “Cookies” and Other Tracking Technologies?
We may send one or more Cookies to your computer or other device. We may also use other similar technologies, such as web beacons, when you visit our Service. These technologies can collect data regarding your operating system, browser type, device type, screen resolution, IP address, and other technical information, as well as navigation events and session information as you interact with our Service. This information allows us to operate the Service and understand how you use the Service.
What Are Cookies?
- Estimate our audience size and usage patterns;
- Store information about your preferences, allowing us to customize our Service according to your individual needs;
- Contact you to provide you with information or services that you request from us;
- Advertise new content, events, and services that relate to your interests;
- Provide you with more personalized content that is most relevant to your interest areas; and
- Recognize when you return to our Service.
We set some Cookies ourselves and others are set by third parties. You can learn more and manage your Cookies preference as described in the “Managing Your Cookies” section below.
What Types of Cookies Do We Use and Why?
These are the different types of Cookies that we and our service providers use on the Service:
- Essential Cookies. These Cookies are required for the operation of the Service and enable you to move around the Service and use its features. Disabling these Cookies can negatively impact the performance of the Service.
- Analytics, Performance and Research Cookies. These Cookies allow us to analyze activities on the Service. They can be used to improve the functioning of the Service. For example, these Cookies recognize and count the number of visitors and see how they move around the Service. Analytics Cookies also help us measure the performance of our advertising campaigns to help us improve them and to optimize the content on the Service for those who engage with our advertising.
- Functionality Cookies. These Cookies are used to recognize you when you return to the Site. This enables us to personalize content for you and remember your preferences.
- Social Networking Cookies. These Cookies are used to enable you to share pages and content that you find interesting on our Service through third-party social networking and other websites. These Cookies may also be used for advertising purposes.
How Long Do Cookies Stay on My Device?
Some Cookies operate from the time you visit the Service until the end of that particular browsing session. These Cookies, which are called “Session Cookies,” expire and are automatically deleted when you close your Internet browser.
Some Cookies will stay on your device between browsing sessions and will not expire or automatically delete when you close your Internet browser. These Cookies are called “Persistent Cookies” and the length of time they will remain on your device will vary from Cookie to Cookie. Persistent Cookies are used for a number of purposes, such as storing your preferences so that they are available for your next visit and to keep a more accurate account of how often you visit the Service, how your use of the Service may change over time, and the effectiveness of advertising efforts.
Managing Your Cookies
It may be possible to block Cookies by changing your Internet browser settings to refuse all or some Cookies. If you choose to block all Cookies (including Essential Cookies), you may not be able to access all or parts of the Service.
You can find out more about Cookies and how to manage them by visiting www.AboutCookies.org.
Does the Site Respond to “Do Not Track” Signals?
There is currently no industry agreed-upon response to a Do Not Track signal. At this time, our Site does not respond differently based on a user’s Do Not Track signal.
How We Use the Personal Information
We use personal information we collect about you or that you provide to us in the following ways:
- To present our Service and its contents in a suitable and effective manner for you and your device;
- To contact you to provide you with information or services that you request from us;
- To fulfill requests and complete transactions you make with us online;
- To build manage your account and build profiles of the users of our Service;
- To advertise opportunities, services, or special events that we think may be of interest to you;
- To provide customer support, troubleshoot issues, manage accounts, and respond to requests, questions, or comments;
- To carry out our obligations and enforce our rights arising from any contracts; and
- To notify you about any additions, upgrades, or changes in our services.
How We Share Personal Information
Access and use by third-party service providers:
From time to time, Clarity enters into arrangements with companies whose expertise is essential for our own services to function properly. For example, we use third party payment processors to process any payments you may submit to us to ensure the security and efficiency of the transaction. We disclose to these service providers only such personal information as is reasonably necessary to perform these functions, and any such third parties will be under an obligation to us to maintain the confidentiality of your personal information.
Access and use by subsidiaries or affiliated companies:
We may provide such information to our subsidiaries, affiliated companies or other trusted businesses or persons, solely for the purpose of processing that information on our behalf.
For legal purposes:
We reserve the right to cooperate with local, state, federal, and international officials in any investigation requiring either personal information or reports about lawful of unlawful user activity on this site. We also reserve the right to share your personal information to establish, exercise, or defend our legal and property rights, including providing information to others for the purposes of fraud prevention. We may also share your personal information with any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.
If we are ordered by a legal process or government to provide data about one or more individual users, we will notify those users of our compliance with that order, to the extent permitted by law.
Business transactions or mergers:
We reserve the right to share your personal information to third parties as part of any potential business or asset sale, merger, acquisition, investment, round of funding, or similar type of transaction.
Bankruptcy or insolvency:
In the event of bankruptcy, insolvency, or dissolution proceedings, we may share your personal information with third parties as part of the sale or reorganization process.
Third Party Marketing:
We do not disclose your personal information to third parties for the purpose of allowing those third parties to market to you directly.
Advertising and Marketing Choice
We respect your rights in how your personal information is used and shared. If at any time you would like to unsubscribe from receiving future emails, you can email us at: firstname.lastname@example.org as well as follow the instructions at the bottom of each email and we will promptly remove you from all correspondence. Please note, however, that we may still need to contact you regarding other matters.
How Long Is Your Personal Information Kept
We will retain your personal information until the personal information is no longer necessary to accomplish the purpose for which it was collected. We may retain your personal information for longer periods for specific purposes to the extent that we are obliged to do so in accordance with applicable laws and regulations, to protect you, other people, and us from fraud, abuse, and unauthorized access, as necessary to protect our legal rights, or for certain business requirements.
Our Commitment to Data Security
The security of your personal information is important to us. We take various reasonable organizational, administrative, and technical measures to protect your personal information from unauthorized access, disclosure, alteration, or destruction. However, we cannot—and do not—guarantee complete security, as it does not exist on the Internet. Therefore, you should be careful about what information you choose to provide. If required by law to do so, we will notify you and/or the relevant supervisory authority in the event of a data breach.
Third Party Links
Clarity’s Service may contain links to third-party websites. When we provide links, we do so only as a convenience and we are not responsible for any content of any third-party website or any links contained within. It is important to note that this Policy only applies to Clarity’s Service. We do not control and assume no responsibility for any personal information collected, stored, or used by any third party as a result of you visiting third-party websites. We advise that you read the privacy notice of any third-party websites you choose to visit carefully.
Our Service are not intended for use by children under 13 years of age, and we do not knowingly collect personal information from children under 13. In the event that we learn that we have collected personal information from a child under age 13 without verification or parental consent, we will immediately delete that information. If you believe that we might have collected any information from a child under 13, please contact us using the information provided in the “Contact Us” section below.
European Users’ Rights
You are entitled by law to access, correct, amend, or delete personal information about you that we hold. A summary listing these rights appears below. Please note that these rights are not absolute and certain exemptions may apply to specific requests that you may submit to us.
To exercise these rights, please contact us using the information below in the “Contact Us” section. For your protection, we may need to verify your identity before responding to your request. In the event that we refuse a request, we will provide you a reason as to why.
Asking us to access your personal information
You have the right to obtain from us confirmation as to whether or not we are processing personal information about you, and if so, the right to be provided with the information contained in this notice. You also have the right to ask us for copies of your personal information. When making a request, please provide an accurate description of the personal information to which you want access. Where requests are repetitive or manifestly unfounded or excessive, we may charge a reasonable fee based on administrative cost.
Asking us to rectify your personal information
You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
Asking us to delete your personal information
You have the right to ask us to erase your personal information if:
- We no longer need it for the purposes for which we collected it;
- We have been using it with no valid legal basis;
- We are obligated to erase it to comply with a legal obligation to which we are subject;
- We need your consent to use the information and you withdraw consent; or
- You object to us processing your personal information where our legal basis for doing so is our legitimate interests and there are no overriding legitimate grounds for the processing.
However, this right is not absolute. Even if you make a request for deletion, we may need to retain certain information for legal or administrative purposes, such as record keeping, maintenance of opt-out requirements, defending or making legal claims, or detecting fraudulent activities. We will retain information in accordance with the “How Long Is Your Personal Information Kept” section below.
If you do exercise a valid right to have your personal information deleted, please keep in mind that deletion by third parties to whom the information has been provided might not be immediate and that the deleted information may persist in backup copies for a reasonable period (but will not be available to others).
Asking us to restrict our use of your personal information
You have the risk to ask us to place a restriction on our use of your personal information if one of the following applies to you:
- You contest the accuracy of the information that we hold about you, while we verify its accuracy;
- We have used your information unlawfully, but you request us to restrict its use instead of erasing it;
- We no longer need the information for the purpose for which we collected it, but you need it to deal with a legal claim; or
- You have objected to us using your information, while we check whether our legitimate grounds override your right to object.
The right to transfer your personal information to another service provider
You have the right to ask that we transfer the personal information you gave us from one organization to another, or give it to you (i.e. data portability). This applies to personal information we are processing to service a contract with you and to personal information we are processing based on your consent.
The right to withdraw consent
If we obtain your written consent to collect and process your personal information, you can subsequently withdraw such consent as to any further processing of such information.
The right to lodge a complaint with a supervisory authority
If you believe your rights under the GDPR have been violated, the GDPR gives you the right to file a complaint with your supervisory authority. A list of supervisory authorities is available here: EEA and EU Data Protection Authorities (DPAs); Swiss Federal Data Protection and Information Commissioner (FDPIC); UK Information Commissioner’s Office (ICO).
Rights related to automated decision-making
To the extent that we engage in decision-making based solely on automated processing, including profiling, which produces legal effects concerning you or which significantly affects you, you have the right not to be subject to such decision-making.
Right to object to processing
You have the right to object to the processing of your personal information that is based on legitimate interests or your consent (rather than when the reason for using it is to perform an obligation due to you under a contract with us). If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or we can demonstrate the processing is for the establishment, exercise, or defense of legal claims. You can object to the processing of your personal information by contacting us using the information in the “Contact Us” section below.
Legal Bases for Processing Your Personal Information
Clarity collects your personal information to provide our products and services to you; otherwise, we may not be able to process the transactions you request. We will only process your personal information when we have a lawful basis for doing so. If you are in a country in the EU, EEA, UK, or Switzerland, you are entitled to an explanation of the legal bases we rely on to process your personal information. The legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it, which is discussed below.
- Consent. We may process your personal information based on your consent such as when you purchase a service or ask us to send you certain kinds of marketing communications. You have the right to withdraw your consent at any time without affecting the lawfulness of the processing based on consent before its withdrawal.
- Our Legitimate Interests. We may process your personal information if doing so is necessary for our legitimate interests relating to our business purposes arising from your relationship with us, and your rights as an individual do not override those legitimate interests. For example, our legitimate interests include but are not limited to when we process your personal information to carry out fraud prevention activities and activities to increase network and information security, identify usage trends, determine the effectiveness of promotional campaigns, expand our business activities and improve our services and the content and functionality of our Services. Our legitimate interests also include providing you with the products and services you request, view, engage with, or purchase and communicating with you regarding your account or transactions with us.
- To Perform a Contract. We may process your personal information to administer and fulfill contractual obligations to you. We will also collect and process your personal information as necessary for the performance of a contract to which you are a party
- To Enable Us to Comply With a Legal Obligation. We may process your personal information to comply with legal obligations to which we are subject. This may include any requirement to produce audited accounts, any legal obligation to share information with law enforcement agencies, public or governmental authorities, and to comply with legal process.
- Necessary for the Exercise or Defense of Legal Claims. If you bring a claim against us or we bring a claim against you, we may process your personal information in relation to that claim.
Depending on the situation, Clarity may be the controller or the processor for personal information collected from residents of the EU, EEA, UK or Switzerland. If you have any questions about or need further information concerning the legal basis on which we collect and use your personal information for any specific processing activity, please contact us using the “Contact Us” section below.
Cross-Border Transfers of Personal Information
Personal information about you provide while in the EU, an EEA member state, the UK, or Switzerland may be transferred to the United States. The United States does not have an adequacy decision or adequacy regulation. The GDPR permits such transfers when necessary for the performance of a contract between you and Clarity, if we obtain your explicit consent to such transfer, or if it is in our legitimate interest to transfer the personal information. The laws in the United States may not be as protective as the GDPR or the laws of other jurisdictions where you may be located. If we transfer personal information from the EU, EEA, UK, or Switzerland, or another country with cross-border transfer obligations, we will provide an appropriate safeguard, such as using standard contractual clauses.
To obtain a copy of the safeguard(s), please contact us using the information provided in the “Contact Us” section below.
This Policy may change from time to time. We will post any changes to this Policy on this page, and you should check these terms when you use the Service. Your continued use of the website and Service constitutes acceptance of the most current version of this Policy.