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Privacy Policy: Your Privacy Rights

Last updated: March 14, 2014

SALT™ is a multi-channel educational membership experience created by Massachusetts Higher Education Assistance Corporation dba American Student Assistance, located at 100 Cambridge Street, Suite 1600, Boston, MA 02114 (“ASA”). At American Student Assistance®, we help ensure your financial future—and we know a big part of that involves protecting your personal information. We consider information security to be a priority in our business, and we devote significant resources to protect the security and integrity of sensitive personal information.

This Privacy Policy explains how and why ASA® collects your information, as well as the steps we take to safeguard it. Be sure to return to this page occasionally, as this policy may change as we update and expand our Services for you.

This Privacy Policy refers to ASA as “we,” “us,” “our,” or other similar pronouns.

This Privacy Policy sets forth our policies for our collection, use and disclosure of information about customers of our Services and visitors to our websites located at www.saltmoney.org, blog.saltmoney.org, and http://www.facethered.com (collectively, “Website”). This Privacy Policy is separate from ASA’s Privacy Notice under the federal Gramm-Leach Bliley Act, which ASA sends to individuals whose loans it holds. This Privacy Policy does not govern the website located at schools.saltmoney.org and sponsorship.saltmoney.org.

Through SALT, we educate students and former students and provide them with details about federal financial aid programs, educational materials about how to manage finances, counseling on managing education loans, as well as product offerings, discounts and promotions, sweepstakes and contests, and information on other topics of potential interest (the “Services”). Some of the Services are provided to you on our Website, and some are provided to you offline, such as by phone and through print mail.

Visitors to our Website (“Visitors”) can access some of our Website’s offerings without becoming a member. To access some of the content and features available on our Website, you are required to create a membership account on our Website with a username and password. If you register, you are referred to as a “Member”. In addition, enhanced Services may be available to you if you have a paid or sponsored membership on our Website.

If someone else is arranging for your enhanced membership, such as your school, your parent or other individual or entity, we refer to them in this Privacy Policy as your “Sponsor.” If your Sponsor is your school (or former school) they are your “School Sponsor.” If your Sponsor is your parent, your legal guardian, or another individual they are your “Individual Sponsor.” If your Sponsor is an entity other than a School Sponsor or an Individual Sponsor they are an “Institutional Sponsor.” If you are an Individual Sponsor, this Privacy Policy applies to the information we collect about you too. If you are a School Sponsor or an Institutional Sponsor, our relationship with you is governed by a separate agreement that we have with you (not this Privacy Policy).

The following are some highlights about our Privacy Policy that are particularly important for you to know:

  • We may already have information about you if we are the guarantor of one of your student loans. We may also receive information about you from your current or former school (even if they are not your Sponsor), Individual or Institutional Sponsor, financial institutions with which you have accounts, one or more governmental agencies, and other third parties. In some cases, you have already consented to this when you obtained your federal education loan(s) and signed your loan promissory notes. In any event, you hereby consent to our use of this information in accordance with this Privacy Policy.
  • We may share information about how you use our Services and Website with your School or Institutional Sponsor, if you have one. (Since your School or Institutional Sponsor is arranging for your membership, they would like to know how you use our Services.)
    • This includes, for example, the fact that you have become a Member, or that you have taken one of the financial education courses on our Website, or the fact that you have spoken with one of our counselors and the reason for the call. (However, it does not include the details of what you discussed with our counselor.)
    • This also includes, for example, the scores you received on financial education courses you took on our Website.
  • We may share information about you with our corporate affiliates who provide some of the Services to you.
  • We may share information about you with our corporate affiliates so that they can provide additional services to you in accordance with their own privacy policy. You may opt out of such sharing of information by not using such additional services.

By visiting this Website, and/or using the Services, you agree to the terms of this Privacy Policy as they may be amended from time to time. As we update and expand our Services, this Privacy Policy may change, so check back to this page from time to time. This Privacy Policy is incorporated into, and part of, the Website Terms of Use, which governs your use of the Services and this Website in general.

This Website is intended for users who are located in the United States of America. This Privacy Policy shall be interpreted under the laws of the United States.

Table Of Contents

Please click on a section title below to skip to that section of this Privacy Policy.

What Information Do We Collect From Or About You?

We may collect personal information from or about you (“Personal Information”), and we may collect certain information from your computer or mobile device when you use the Services and visit our Website (“Website Usage Information”). This information may be collected and processed on our behalf by our services providers.

Personal Information includes, for example, your name, address, email address, telephone and/or wireless number, text message address, credit card and other payment information, Social Security number, date of birth, loan and other financial account information, school enrollment information, demographic information, other account identifiers, such as Facebook ID, and/or other information that may identify you as an individual or allow online or offline contact with you as an individual.

Under What Circumstances And For What Purposes Do We Collect Information About You?

User-Provided Information

We collect Personal Information from you, for example, when you complete online forms on our Website (such as when you complete a form to become a Member), when you import your loan data, and when you engage in activities or transactions on our Website. Such information is also collected, for example, when you enter sweepstakes and contests, complete surveys, contribute to a public forum, submit a comment or question to us using a “contact us” or similar feature on our Website, send us an email, or in any other way submit Personal Information to us via our Website or Service. We may also collect Personal Information from you when you interact with one of our counselors or membership agents by phone.

You may be able to send information about our products and services to your friends and family members through our Website by clicking on an “Email to Friend” or similar button on our Website or in an email that we have sent you. In some of these cases (unless you simply forward our email on your own), you may provide the name and email address of your friend or family member to us. Such information will be treated in accordance with this Privacy Policy and applicable law.

Information About You Received From Other Sources

We may already have information about you if we are the guarantor of one or more of your student loans. We may also receive information about you from your current or former school(s) (even if they are not your Sponsor), Individual or Institutional Sponsor, financial institutions with which you have accounts, and one or more government agencies. We may also obtain information about you from other third parties, such as companies that help us supplement our records with up-to-date and complete information. In some cases, you have already consented to this when you obtained your federal education loan(s) and signed your loan promissory notes. In any event, you hereby consent to our use of this information in accordance with this Privacy Policy.

We may also have pages on social networking sites like Facebook, MySpace, and Twitter. This Privacy Policy does not apply to those sites, and those sites use your information in accordance with their own privacy policies. However, if we receive your information from these sites, we will use it in accordance with this Privacy Policy.

Website Usage Information

Cookies and Local Shared Objects

We may use “cookies” and “local shared objects” to keep, and sometimes track, information about you. Cookies are small data files that are sent to your browser or related software from a Web server and stored on your computer’s hard drive or mobile device. Local shared objects are also files saved on your hard drive or mobile device using HTML5, comparable language that your computer or device uses to communicate with our servers, or a media player or other software that you have installed on your computer or device (such as a Flash player).

These technologies may be used to remember your username and other information you have given us before and to enable our Website to display pages the way you prefer them. They also track where you travel on our Website and what activities you engage in. These technologies may enable us to relate your use of our Website to other information about you, including your Personal Information. All of these purposes serve to improve and personalize your experience on our Website.

Most Web browsers can be set to inform you when a cookie has been sent to you and provide you with the opportunity to refuse that cookie. Additionally, some media players enable you to manage local shared objects. However, refusing these technologies may, in some cases, preclude you from using, or negatively impact the display or function of, the Website or certain areas or features of the Website.

By using our Website, you consent to our use of cookies and local shared objects as described above.

Other Technologies And Web Metrics

We may use other technologies such as clear GIFs, pixel tags, or similar tools in the Website and/or in our communications with you to enable us to know whether you have visited a webpage or received and viewed a message. These technologies may enable us to relate your viewing or receipt of a webpage or message to other information about you, including your Personal Information.

Our server automatically collects your Internet Protocol address (aka your IP Address) when you visit our Website. Our server may also record the webpage from which you linked to this Website (e.g., another website or a search engine), the pages you visit on this Website, the website you visit after this Website, the ads and content you see and/or click on our Website, any search terms you have entered on this Website or a referral site, other Web usage activity and data logged by our Web servers, and other information about the type of Web browser, computer, platform, related software, and settings you are using. We use this information for internal system administration, to improve your experience on the Website, to help diagnose problems with our server, and to administer our Website. Such information may also be used to gather broad demographic information, such as country of origin and Internet Service Provider. We may also link this information with your Personal Information.

How Is The Personal Information Used?

We will use your information, for example, to provide you with the Services we offer on our Website and offline, such as by phone or through print mail, to respond to your requests and process your orders or transactions, and to provide you with our product and service offerings. If you are an Individual Sponsor, we use your Personal Information (such as your contact information and your payment information) to open and maintain the Member account you are sponsoring and to contact you. We will also use your Personal Information to maintain our internal record keeping. We may match information collected from you through different means or at different times, including both Personal Information and Website Usage Information, and use such information along with information obtained from other sources, including third parties.

In addition, we may send you notices (for example, in the form of emails, mailings, and the like), and otherwise correspond with you, about products, services, companies, and events, sponsored by us and others, that we think might interest you. You may opt out of receiving such notices from us by following the instructions in the Right to Opt In and Opt Out section below.

We may also send you messages through your account on our Website. Your School Sponsor may do so too.

We may analyze user behavior as a measure of interest in, and use of, our Website and other forms of interaction, both on an individual basis and in the aggregate.

Do We Share Personal Information And Website Usage Information With Others?

We will never sell your Personal Information. However, to create a holistic experience for you online and off, we may for example share your Personal Information with your School Sponsor, our affiliates, and other entities as outlined below.

Your School Or Institutional Sponsor

We may disclose your Personal Information and Website Usage Information with your School or Institutional Sponsor so they can understand your engagement and progress with our Services.

Our Affiliates

We may share your Personal Information and Website Usage Information with our corporate affiliates who use it to help provide Services to you. Additionally, we may share your Personal Information and Website Usage Information with our corporate affiliates to provide additional services to you. These additional services will be provided in accordance with their own privacy policy. You may opt out of such sharing by not using these additional services.

Public Forums

When you contribute to a public area or feature of our Website, such as a chat room or comment area, the information that you submit or post will be made available to other visitors and Members of our Website, as well as representatives of School Sponsors (of yours and of other Members) who also have access to our Website. For example, when you post a comment on an article on our Website, other users of our Website will be able to see your comment and your user name. For this reason, we recommend that you do not disclose or submit any sensitive information on such public areas of the Website, including your full name, home address, phone number, other information that would enable other users to locate you, or financial information.

Service Providers

We may use third-party partners to help operate our Website and deliver our products and services, and we may share your information with our service providers and other third parties that provide products or services for or through this Website or for our business (such as online curriculum partners, vendors who manage our loyalty programs, vendors who host our online chat platform, Website or database hosting companies, address list hosting companies, email service providers, analytics companies, distribution companies, fulfillment companies, sweepstakes and contest administration companies, and other similar service providers that use such information on our behalf). We contractually obligate these service providers to use and access Personal Information only as needed to perform their functions for us and for no other purposes.

Website Usage Information And Other Non-Personally Identifiable Information

We may disclose Website Usage Information and other non-personally identifiable information regarding our users and user behavior as a measure of interest in, and use of, our Services, our Website, and emails to third parties, including, for example, aggregate data, such as overall patterns or demographic reports that do not describe or identify any individual user.

Legal Disclosures

We may disclose user information to government authorities, and to other third parties when compelled to do so by government authorities, at our discretion or otherwise as required or permitted by law, including but not limited to in response to court orders and subpoenas. We also may disclose user information when we have reason to believe that someone is causing injury to or interference with our rights or property, other users of the Website, or anyone else that could be harmed by such activities.

Business Transfer

In the event that ASA, its affiliate, or substantially all of its or its affiliate’s assets related to the Services that we provide pursuant to this Website are acquired by one or more third parties as a result of an acquisition, merger, sale, reorganization, consolidation, dissolution, or liquidation, Personal Information and Website Usage Information may be one of the transferred assets.

Right To Opt In And Opt Out

You may have the right to “opt in” and “opt out” of certain uses of your Personal Information. You may make this request by visiting the “Manage Your Profile” area of your account on this Website. You may also opt out of our promotional emails by clicking on an unsubscribe link within the email you receive.

Please understand that if you opt out of receiving promotional correspondence from us, we may still contact you in connection with your relationship, activities, transactions, and communications with us. Also, to stop receiving promotional messages from third parties who already have your contact information, please contact them directly.

Do Not Track Requests

We do not respond to “do not track” requests because we do not track you over time and across third party websites to provide targeted advertising. We track Website Usage Information across our Websites because Website Usage Information helps us to improve the user experience and maintain a Website that is useful, accessible, and informative. We also track users who come to our Website from one of our paid media or sponsorship partners. Third parties, including paid media or sponsorship partners, cannot collect any other personally identifiable information from our Websites unless you provide it to them directly.

Text Message Service

We may make available a service through which you can receive messages on your wireless device via short message service, otherwise known as “text messages” (“Text Message Service”). If you subscribe to one of our Text Message Services, you agree to receive text messages from us at the address you provide for such purposes. You understand that your wireless carrier’s standard rates apply to these messages and that you may change your mind at any time by following the instructions in the Right to Opt In and Opt Out section above. Your opt-out will become effective upon your receipt of a text message from us confirming your opt-out. You represent that you are the owner or authorized user of the wireless device you use to sign up for the Text Message Service and that you are authorized to approve the applicable charges. To use the Text Message Service, you must be 18 years of age or older and reside in the United States.

Your Access And Correction Rights

You may review, update or modify the Personal Information that is stored in your user account on this Website by visiting the “Manage Your Profile” area of your account on this Website or by contacting us at our Contact Information set forth below. Before we are able to provide you with any information or correct any inaccuracies, however, we may ask you to verify your identity and to provide other details to help us to respond to your request.

Your Social Security Number

We collect your Social Security number to identify who you are, since there may be other people with your name. In some cases, we ask you to provide your Social Security number, and in some cases your School Sponsor provides it to us or we may already have it in connection with a separate relationship that we have with you (for example, if we are the guarantor of your loans). When you become a Member, we use your Social Security number to associate you with your loan information.

We have a policy to treat your Social Security number as confidential information and to not disclose it to third parties except as allowed by applicable laws. We also have limited-access policies in place to protect it. We may disclose your Social Security number to your School Sponsor and to other entities that have legal rights to receive it pursuant to applicable laws and the terms of your loans. When we dispose of your Social Security number, we have a policy to either shred it or degauss it from electronic media. ASA personnel who violate our policies to protect Social Security numbers are subject to discipline, including possible termination.

Survival

We shall continue to have the rights set forth in this Privacy Policy to use and disclose your Personal Information and Website Usage Information unless and until you are no longer a Member and you contact us using the contact information set forth below and notify us that you would like to opt out of our further use of your Personal Information. If you do so, we will still have the continuing right to maintain, use and disclose non-personally identifying information about you as well as any information that we maintain about you as a present or former guarantor of a student loan or as a service provider to your school.

Security

We consider information security to be a priority in our business, and we devote significant resources to protect the security and integrity of sensitive Personal Information. However, due to the inherent nature of the Internet as an open global communications vehicle, we cannot guarantee that any information, during transmission through the Internet or while stored on our system or otherwise in our care, will be absolutely safe from intrusion by others, such as hackers.

If you contact us by email or a “contact us” or similar feature on our Website, you should be aware that your transmission might not be secure. A third party could view information you send by these methods in transit.

If you are a Member of our Website, you have a username and password to access the non-public areas of our Website. You are responsible for maintaining the strict confidentiality of your account password, and you shall be responsible for any access to or use of the Website by you or any person or entity using your password, whether or not such access or use has been authorized by or on behalf of you, and whether or not such person or entity is your employee or agent. Please notify us of any unauthorized use of your password or account or any other breach of security at websupport@saltmoney.org.

We will have no liability for disclosure of your information due to errors or unauthorized acts of third parties during or after transmission.

In the unlikely event that we believe that the security of your Personal Information in our possession or control may have been compromised, we may seek to notify you of that development. If a notification is appropriate, we would endeavor to do so as promptly as possible under the circumstances, and, to the extent we have your email address, we may notify you by email. You consent to our use of email as a means of such notification. If you prefer for us to use a different form of communication to notify you in this situation, please contact us at our Contact Information set forth below.

Phishing

With identity theft a continuing problem, it has become increasingly common for unauthorized individuals to send email messages to consumers purporting to represent a legitimate company such as a bank or online merchant and requesting that the consumer provide personal, often sensitive information. Sometimes, the domain name of the email address from which the email appears to have been sent, and the domain name of the website requesting such information, appears to be the domain name of a legitimate, trusted company. In reality, such sensitive information is received by an unauthorized individual to be used for purposes of identity theft. This illegal activity has come to be known as “phishing.”

If you receive an email or other correspondence requesting that you provide any sensitive information (including your Website password, Social Security number, or credit card information) via email or to a website that does not seem to be affiliated with our Website, or that otherwise seems suspicious to you, please do not provide such information and report such requests to us at websupport@saltmoney.org.

Consent To Processing

By providing Personal Information to this Website, you consent to the collection, maintenance, processing, and transfer of such information in and to the United States and other countries and territories, pursuant to the laws of the United States, which may provide lesser privacy protections than the laws of other countries.

Linked-To” Websites

When you are on our Website you may have the opportunity to click-through to other websites, including websites operated by our affiliates or by unaffiliated third parties. These sites may collect Personal Information about you. We do not control sites operated by these entities and are not responsible for the information practices of these sites. This Privacy Policy does not address the information practices of other websites. The privacy policies of websites operated by our affiliates and other third parties are located on those sites. Some of the tools offered on the Website are hosted on third party websites such as for example the job-search and internship-search areas of the Website which are powered by www.tweetmyjobs.com and www.internships.com. Information entered through the use of these tools will be passed on to the host website for their use in accordance with their own privacy policy. Also, some of the data offered on our Website is provided by third parties, such as for example the employment and compensation data provided by Job Search Intelligence, LLC All rights reserved.

Changes To This Privacy Policy

We reserve the right to change this Privacy Policy from time to time, and such changes will be effective immediately upon posting to this Website. Under certain circumstances (for example, in connection with certain material changes), we may also elect to notify you of changes or updates to our Privacy Policy, or to request your consent for such changes, by additional means, such as posting a notice on the front page of our Website to sending you an email.

If you have any questions or comments regarding our privacy practices, you may contact us at: websupport@saltmoney.org.

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