This privacy policy (this “Policy”) describes the policies and procedures of the Peter G. Peterson Foundation (“we,” “our,” “us”) with respect to personal data collected, held, used or processed by us when you use our website at StudentDebtSmarter.org (the “Site”), which includes the Student Debt Affordability Calculator (the “Calculator”) and other content available through the website. It also covers the measures taken to protect the confidentiality, integrity and security of that personal data, and your rights regarding such personal data.
By visiting the Site, you acknowledge that you have read this Policy, which may be updated by us at any time. If we update this Policy, we will post the updated version here. Any such changes will be effective as to you when you first access the Site after we post the changes here. If we make any material changes in the way we collect, hold, use, process or share your personal data, we will endeavor to provide you with appropriate notice.
The terms which govern the use of the Site can be found here.
This Policy sets out:
- the types of personal data that we collect from individuals when they use the Site;
- the purposes and legal basis for our processing and use of individuals’ personal data;
- how we may disclose or use personal data;
- how we transfer personal data outside of the European Economic Area (“EEA”) or United Kingdom (“UK”); and
- individuals’ rights with respect to our use or disclosure of their personal data.
Queries regarding how (1) our policies may apply to your personal data; (2) to exercise your right to question or object to our use of your personal data, in accordance with applicable laws; or (3) to access, correct, or delete your personal data, should be sent to us using the contact information set forth below.
Who Controls the Data We Collect
We are a data controller with respect to your personal data. We ‘control’ the data you submit to the Site and make certain decisions as to how to use and protect it, but only to the extent that we have informed you about such use or as otherwise permitted by applicable law.
What Personal Data Do We Collect
We collect personal data from individuals who visit or use the Site.
We provide the opportunity for you to submit your email address and, if you choose, your name, to subscribe to our newsletters.
If you wish to use the Calculator, for the purpose of estimating how much college student debt you can afford, you will need to provide the major you intend to study, the college you plan to attend, the year you plan to start college, the city you plan to live in after college, and how much you expect to borrow in student loans.
We do not store the data that you input in the Calculator after making the applicable calculations and displaying the results to you.
Your search bar will include the data that you entered in the URL. You can adjust your browser settings to modify whether such search history is retained.
If you elect to have your Calculator results emailed to you, we will use the email address that you provide to send your results to you.
Unless you elect otherwise, we will also use the email address that you provide to send you newsletters and other communications from time to time. You will always have the ability to opt out of receiving further such information from us.
In addition, we may record details of visits to the Site, such as traffic data, IP addresses, location data, weblog information about the device you use to interact with the Site, the type of operating system and browser you use, access times, pages viewed, URLs clicked on, and the pages visited before navigating to the Site, using cookies or other technologies, as set forth below.
Cookies are small text files stored by your browser on your computer when you visit websites, which allow for the collection of certain information about your use of the websites. Some of these cookies are essential, but you have the choice to refuse the use of all non-essential cookies through your browser settings or by clicking on the options on the Site. To find out more about cookies please visit: www.allaboutcookies.org or www.youronlinechoices.eu.
Why We Collect and Process Personal Data
We may process the personal data described in this Policy for the following purposes:
- to provide you with newsletters or other information that you request;
- to communicate with you regarding your use of the Site;
- to provide service and support or address complaints relating to the Site;
- to monitor, improve and safeguard use of the Site;
- where you give us consent:
- by means of cookies and similar technologies in accordance with the information above and the information provided to you as to when those technologies are used; or
- for the purposes we explain at the time you give us such consent;
- in connection with legal claims, and to comply with applicable laws, regulations, subpoenas, legal process, governmental investigations, regulatory requests or inquiries, including cooperating with government or law enforcement authorities conducting an investigation; and
- as otherwise described in this Policy.
Social Media
The Site includes social media features, such as the ability to link to our Instagram page. These features may collect information about your IP address and which page you visited on the Site, and they will set cookies to make sure the features function properly and for other purposes disclosed on the social media platforms. Your interactions with such features and platforms are governed by the privacy policies and cookie policies of the companies that provide them.
Marketing
We may use your personal data to disseminate information about our own programs and policies or those of one of our grant recipients, collaborators or affiliates. We will not share your personal data with third parties for their own marketing purposes.
How and With Whom Do We Share Personal Data
We may share your personal data as set forth below:
- among our affiliated organizations;
- with service providers, suppliers and subcontractors (e.g., MailChimp) for the purpose of providing the Site and the services accessible on the Site;
- with analytics and search engine providers, such as Google Analytics, that use such information to help improve and optimize the Site (to learn more about Google Analytics and how Google collects and processes data, see www.google.com/policies/privacy/partners);
- if we sell or buy any businesses or assets or merge any business or operations into or with those of another person or entity, in which case we may disclose your personal data to the prospective counterparty in such transaction and such data may be one of the assets transferred in such transaction;
- to comply with applicable laws, regulations, subpoenas, legal process, governmental investigations, regulatory requests or inquiries, to cooperate with law enforcement, to assert or defend against legal claims, to protect our and others’ rights, property, or safety, and for the purposes of crime and fraud prevention and remediation;
- as required to conduct our business and pursue our legitimate interests; or
- to any other party with your consent.
Transfers of Personal Data Outside the EEA or UK
In some cases, disclosure of personal data to other persons will involve transferring personal data from a country in the EEA or UK to a country which has been held not to provide a level of protection of personal data equivalent to that provided in the EEA or UK. In particular, personal data from the EEA or UK will be transferred to, stored in and processed in the United States. If we transfer your personal information out of the EEA or UK to a country not deemed to provide an adequate level of personal information protection for purposes of applicable data protection laws such that additional safeguards are required, the transfer will be performed only with your consent, to pursue our legitimate business interests, or as otherwise permitted by applicable laws.
Your Rights
You have various rights with respect to our use, processing and sharing of your personal data, as described below. We make these rights available to all users, regardless of whether you reside in a jurisdiction that expressly provides for a particular right. There may be exceptions to these rights under applicable law. If you wish to contact us to exercise any of these rights, please email us at [email protected] or write to us at Peter G. Peterson Foundation, Attention: Legal, 888-C Eighth Avenue, Box 144, New York, NY 10019, USA.
We will not deny you services, charge you a different price, provide a different level or quality of services or otherwise discriminate against you just because you exercised any of these rights; however, if you decline to provide your personal information or ask us to delete it or stop disclosing it, we may be unable to provide you with certain services.
Only you, or a person whom you authorize to act on your behalf, may make a request related to your personal data. The request must:
- provide sufficient information for us to reasonably verify you are the person about whom we collected personal data or an authorized representative of such person; and
- describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal data if you do not take the foregoing actions. Making a request does not require you to create an account with us. We will use personal data provided in a request only to verify your identity or authority to make the request.
- Access: You may request a copy of the personal data that we have collected, used, or shared about you, and why we collected, used or shared that personal data, including the categories of personal data collected, the specific items of personal data collected, the categories of sources from which we collected personal data, the purposes for which we use the personal data, the categories of third parties with whom we share the personal data, and the categories of information that we disclose to third parties.
- Accuracy: We aim to keep your personal data accurate, current, and complete. We encourage you to contact us to let us know if any of your personal data is not accurate or changes.
- Objecting/Deletion: You have the right to object to processing of your personal data and to ask us to block, delete or restrict your personal data, subject to certain exceptions. Once we receive your request and verify your identity, we will delete your personal data from our records and direct our service providers to delete your personal data from their records, unless an exception applies under applicable law.
- Portability: You have the right to request that your personal data be provided to you, or to another data controller, in a commonly used, machine-readable format.
- Complaints: If you believe that your data protection rights may have been breached, you have the right to lodge a complaint with the applicable supervisory authority.
California’s Shine the Light Law
California Civil Code Section 1798.83, known as the “Shine the Light” law, permits users who are California residents to request and obtain from businesses a list of what personal data (if any) they disclosed to third parties for direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. Requests are free of charge. We do not use your personal data for direct marketing purposes, and we do not share your personal data with third parties for their direct marketing purposes.
How Long We Keep Your Personal Data
We will retain personal data for as long as required to provide the services to you.
We do not track visitors to the Site over time or across third party websites to provide targeted advertising and therefore do not respond to Do Not Track (“DNT”) browser settings.
Contact Information
If you have any questions or comments about this Policy, you may email us at [email protected] or write to us at Peter G. Peterson Foundation, Attention: Legal, 888-C Eighth Avenue, Box 144, New York, NY 10019, USA.