Last updated: May 2, 2013
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.
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.
- 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 paying 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.
Table Of Contents
- What Personal Information do we collect from or about you?
- Under what circumstances and for what purposes do we collect information about you?
- How is the Personal Information used?
- Do we share Personal Information and Website Usage Information with others?
- Right to Opt In and Opt Out
- Text Message Service
- Your Access and Correction Rights
- Your Social Security Number
- Consent to Processing
- “Linked-to” Websites
- Contact Us
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.
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.
Information About You Received From Other Sources
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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 firstname.lastname@example.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.
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 email@example.com.
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.
If you have any questions or comments regarding our privacy practices, you may contact us at: firstname.lastname@example.org.