Toucann.com Privacy Policy

This privacy policy (“Privacy Policy”) applies to web sites operated by Toucann LLC (“Toucann”), including www.toucann.com (“Toucann Site”).

1. GENERAL STATEMENT

Toucann respects your privacy and is committed to protecting it. Our services require us to collect detailed personal information from you. We want you to have the information you need to make an informed decision about sharing your information with us. This Privacy Policy explains our information collection and sharing practices, as well as the choices you can make to limit our sharing your information.

In general, we may share your personal information with a variety of third parties, including colleges, universities, scholarship administrators, marketing partners, advertisers, counselors, teachers, parents and guardians. However, we only share your personal information with these parties if you have either given your permission or taken an action on a Toucann Site to indicate an interest in a particular college or university (for example, adding the school to your “favorite schools” or calculating your chances of admission to a particular school, etc.). We also share your personal information with vendors (for example, our web hosting provider) as needed to assist Toucann with business operations, but they are contractually required to keep your information confidential.

We may also use information about how you interact with the Toucann Site and the schools in which you show an interest to generate aggregate data analytics that may be shared with our college and university partners.

We have tried to make this privacy policy as simple as possible. You should read the rest of it for more detail on how we treat your personal information.

Within this Privacy Policy, you will find the following:

• Types of Personal Information we collect
• How we use and share the Personal Information we collect
• Your Privacy Choices
• Use Outside of the United States
• Our Data Security Procedures
• California Online Privacy Protection Act Disclosures
• Changes to this Privacy Policy / Questions

2. TYPES OF PERSONAL INFORMATION WE COLLECT

Student Account Creation / Registration - When you create an account on a Toucann Site, you are asked to provide certain information, such as name, address, phone number, e-mail address, password, date of birth and other academic and demographic variables relevant to the college selection/admission process. You may update this information at any time after your initial registration.

Counselor Accounts - Counselors and certain student supporters, such as parents, guardians and teacher (collectively, “Advisors”) have the ability to create accounts on Toucann Site. If you create an Advisor account, we will collect your business contact information, if relevant, and it may be viewable by students, colleges and universities that use Toucann Site. You always have the ability to update your advisor information and can have your account removed by contacting us at legal@toucann.com.

Referrals - You may have received an invitation to register for a Toucann Site because we received your information from a third party that believes you would benefit from using a Toucann Site. Similarly, Toucann registrants can choose to let others know about Toucann through our referral feature by entering in a person&s name and email address. If we received your email address through this channel, you may receive an invitation to register for a Toucann Site.

Cookies and Web Site Information - We use cookies and web server logs to collect information about how you use Toucann Site and to customize advertising that you may see on Toucann Site. Information gathered through cookies and our web server logs may include the date and time of visits, your IP address, the pages viewed, time spent at our Toucann Site, and the web sites visited just before and just after a Toucann Site. This information may be appended to your profile information to provide you with better service and information and may be shared with colleges, universities and other sponsors as provided below. It also may be collected on an aggregate basis, and shared with or collected by third-party web analytics services to help Toucann understand our users& aggregated usage patterns and related trends. If you would like more information about advertising-related data collection practices and to know your choices about not having this information used by these online advertising companies, see: https://www.networkadvertising.org/choices/.

3. HOW WE USE AND SHARE THE INFORMATION WE COLLECT

We use and share the information you supply to Toucann in the following ways:

College Readiness, Colleges, Universities and Sponsors - We use your profile information to help you become college ready, match your background to the preferences of colleges and universities and other variables so we can recommend colleges and universities based on “fit.” Additionally, colleges and universities who work with Toucann may target certain types of students based on non-personally identifiable criteria such as GPA or general geographic regions. If you meet the school&s targeting criteria, or based on other information in your profile, we may ask you whether your profile information may be sent to colleges, universities and/or other sponsors. With your permission, we will release your profile information to such college, university or other sponsor so that they may directly contact you. Toucann will also share your information with colleges and universities when you take certain action or interact with certain functionalities on a Toucann Site indicating an interest in a school. For example, if you add a college to your list, your profile may be shared with that college. Similarly, your readiness score may be shared with that school. Toucann may be compensated for information that is shared with colleges, universities and sponsors.

Contacting You by E-Mail - Toucann may use your contact information to send you e-mail messages regarding updates at a Toucann Site, such as new Toucann opportunities and additional listings which may be of interest to you. The frequency of these messages will vary depending upon your profile, including the types of colleges and other activities you indicated having an interest in. We may also send you various Toucann newsletters and other email marketing messages. You may opt-out of receiving these offers at any time by following this [link] and provided below in the “Your Privacy Preferences” section of this Privacy Policy, or via the unsubscribe link contained in the email message. You may also receive e-mail messages from colleges, universities and other third parties once we have shared your information in accordance with this Privacy Policy. The opt-out provisions of this Privacy Policy do not govern e-mail messages from third parties.

Inviting Counselors, Teachers, Parents and Guardians - You can choose to allow Advisors or other trusted advisors to access your Toucann account. If you use this feature, you will either select a registered counselor or Advisor or provide your counselor&s name and e-mail address so that Toucann can invite them to register on the Toucann Site, both of which will allow the counselor or Advisor to view your account and monitor your progress. By inviting these individuals to monitor your progress, you are granting permission to Toucann to share all information in your profile with them.

Site Customization - Toucann uses your information in order to customize our Toucann Site(s) to your interests and customize the advertisements you see based on your interests and preferences. Toucann uses various methods to recognize you, including cookies and requesting your e-mail address and password before accessing our site.

Aggregate, Non-Personally Identifiable Information - We may use anonymous information about how you use Toucann Site (e.g., the schools in which you are interested in, schools to which you apply, etc.) to improve the functionality of Toucann Site and improve Toucann&s service offerings, including using this data at an aggregate level to create data analytics offerings to analyze trends. Toucann may share this aggregate level data and other non-personally identifiable information with our business partners and university and college users and may be compensated for the same. Toucann attempts to use industry-standard methods to ensure that the data remains anonymous and that individual students cannot be identified through any of this aggregate data.

Third Party Vendors - Toucann uses third party vendors to perform operational functions related to the Toucann Site. Some of these vendors (e.g., email vendors or hosting providers) may have access to your personally identifiable information, but only as necessary to provide services to Toucann. Toucann has agreements in place with these vendors requiring them to keep your information confidential and use reasonable data security measures to protect it.

Web Analytics Services - Toucann Site may use third party analytics services, such as Google Analytics, to help improve usability and the customer experience. These services may record mouse clicks, page views, mouse movements and scrolling activity and are used by Toucann to analyze trends and administer the Toucann Site. In the case of the Google Analytics service, you can disable it by installing the Privacy Badger browser addon.

Other Third Parties - If you permit colleges, universities or other third parties to contact you based on the practices described in this Privacy Policy, those third parties may share your personal information with other marketers, data aggregators or others (possibly in the form of list rentals).

Links to Other Sites - This Privacy Policy applies only to the Toucann Site. While Toucann Site may link to other third party web sites, information you may provide on a linked site once you leave the Toucann Site is not controlled by Toucann and is not controlled by this Privacy Policy. You should consult the privacy policy of any linked sites before providing your information to those sites.

Disclosure to Law Enforcement and Similar Disclosures - Toucann will release your personal information if required by law, for example, if we receive a subpoena or otherwise believe in good faith that the law requires us to release your information.

Sale or Merger - If Toucann sells any part of its business, Toucann may transfer your information to its successor, regardless of your opt-out status.

4. YOUR PRIVACY CHOICES

Modifying Privacy Choices and Opt-outs - You may deactivate your account or opt-out of receiving certain types of communications on the “Profile” page of the Toucann Site. If you deactivate your account, we will retain your information in our active database, but will not use it to contact you or share with colleges or other third parties. Toucann will communicate with you only according to your listed preferences. In order to opt-out of third party communications, you will need to contact the applicable third party. If you have any questions relating to opting-out, please contact us at legal@toucann.com, and we will do our best to answer your questions.

Updating Your Information - You can update your personal information by clicking here, by clicking on the “Update Profile” link on a Toucann Site, or by following the instructions included in any e-mail message you receive from Toucann. Contact us at support@toucann.com if you have any problems updating your information.

Closing your Account - You may close your account on a Toucann Site by sending an email to support@toucann.com and we will remove your personal information from our active database. Once your account is closed, we will discard your personally identifiable data, but we may retain certain data for internal business purposes, such as analysis of non-personally identifiable data or as may be required by applicable law.

5. USE OUTSIDE OF THE UNITED STATES

Toucann Sites are operated in the United States. If you are located outside of the United States, any information you provide to us will be transferred to the United States. By using the Toucann Site or by providing us with your information, you consent to this transfer.

6. OUR DATA SECURITY PROCEDURES

Toucann has reasonable security measures in place to keep the information you provide to us safe from unauthorized access. However, no method of information transfer over the Internet is 100% secure and we cannot guarantee the security of your information during its transmission or storage in our systems. We will assume that anyone who has the required login/password information for your account is you, so please keep this information confidential. Vendors and contractors who perform operational services for Toucann Site and have access to your personally identifiable information are required to keep the information confidential.

If you have any questions about security issues, please e-mail us at legal@toucann.com, and we will try to answer your questions.

7. CALIFORNIA ONLINE PRIVACY PROTECTION ACT (“CALOPPA”) DISCLOSURES REQUIRED BY 2013 AMENDMENT

Information provided in this Section 7 pursuant to CalOPPA is in addition to the disclosures contained in other sections of this Privacy Policy, which also address some CalOPPA requirements.

Do Not Track (“DNT”) Signals - Web browsers offer you an option to send “Do Not Track” signals to web sites you visit. Toucann Site may use third-party ad servers, retargeting services and web analytics systems, such as Google, to provide advertising on our sites, analyze aggregate web usage statistics and provide us the ability to display advertisements to you when you have left our site. Toucann does not respond to DNT Signals as it does not track you when you leave a Toucann Site. Toucann&s third party service providers, who provide ad serving, retargeting services and web analytics services to Toucann, may not respond to DNT signals. If a user comes to a Toucann Site directly with a DNT signal enabled on such user&s browser, Toucann does not look for the DNT signal or respond to it.

Third Party Collection of Personally Identifiable Information - Other than as specified in this Privacy Policy, we generally do not allow third parties to collect your personally identifiable information provided on the Toucann Site. In some cases, however, our third party service providers may collect information through the Toucann Site in order to assist Toucann in operating its web sites and services. Section 3 of this Privacy Policy contains additional information on how we share your information with third party service providers.

8. CHANGES TO THIS PRIVACY POLICY / QUESTIONS

Changes to the Privacy Policy - Toucann may update this Privacy Policy from time to time without notice to users other than posting the new Privacy Policy on this page. After posting such amended Privacy Policy, all information provided to us will be subject to the terms of the amended Privacy Policy. Please visit this page periodically so that you will be apprised of any changes.

Your privacy is important to Toucann. If you have questions about any of the provisions described above, please contact us at legal@toucann.com.