SCHOLAR SNAPP
APPLICATION PRIVACY POLICY

INTRODUCTION

Welcome to Scholar Snapp. We provide a secure, free service to help students apply for scholarships and college admissions. We are committed to protecting your privacy. This page outlines our policies and describes the methods we use to protect your privacy.

See the Glossary at the end of this policy for the definition of terms used throughout this page.

THE DATA WE COLLECT

To provide our core service we do collect personal information. Personal information means any information about an individual from which that person can be identified. It does not include data from which identifying information has been removed (i.e., anonymous data).

The Scholar Snapp system may contain the following personal information about you if you’ve provided it to us or granted permission for one of our partners to send this information to us:

  • Name.
  • E-mail address.
  • Contact information such as phone number and address information.
  • Demographic information such as ethnicity, gender, and gender identity.
  • Financial information commonly requested by scholarship and college applications such as income and employment status.

To set up a Scholar Snapp account, only your name and e-mail address are required; all other information is optional. Naturally, the more information you provide, the more useful Scholar Snapp can be in filling out other applications – but if you want to keep certain information completely private you can do so by choosing not to complete the fields which ask for information you do not want to provide.

In addition to the personal information above, we may collect the following information if you provide it to us:

  • Citizenship information
  • Grade and transcript information
  • Educational attainment and current degree information
  • Family and home environment
  • SAT, ACT and other test scores
  • FAFSA and other government aid information
  • Employment and income information
  • Scholarship purpose
  • Current enrollment and graduation status
  • College choices and acceptance status
  • Current and intended majors
  • Field of study
  • References
  • Activities
  • Application attachments
  • Essay prompts and essay content

The complete details about information we collect are defined by the Scholar Snapp Profile, which is periodically updated. Links to current specifications can be found on the Scholar Snapp website (www.scholarsnapp.org).

HOW WE COLLECT YOUR PERSONAL DATA

We may collect personal information about you via a few different methods:

  • Direct Entry via Scholar Snapp Online Application. We provide a web-based tool called the Scholar Snapp Online Application that allows you to add information directly to your Snapp Profile. You are the only person who can update your personal information through the Online Application.
  • Import from Scholar Snapp Partners. The Scholar Snapp Central data hub allows Scholar Snapp partners to send data to us which we use to build and update your Snapp Profile. You provide permission (using your Snapp login) before we receive any of your personal information from a Scholar Snapp partner, so you have control over which Scholar Snapp partners can send us data.
  • E-mail or Direct Contact. If you contact us via e-mail or other means, for example, to answer a question or provide technical support, we will have a record of that contact.

HOW WE USE YOUR PERSONAL DATA

WE ONLY USE AND SHARE YOUR PERSONAL DATA WITH SCHOLAR SNAPP PARTNERS TO HELP YOU APPLY FOR SCHOLARSHIPS AND COLLEGE ADMISSIONS. WE DO NOT USE YOUR PERSONAL INFORMATION FOR COMMERCIAL PURPOSES AND WE NEVER SELL YOUR DATA TO OTHERS FOR COMMERCIAL PURPOSES.

We only use your personal data to provide our core service – helping you to apply for scholarships and college admissions.  You control which Scholar Snapp partners can access your data. Through our core service, your personal information may be used in the following ways:

  • Export to Scholar Snapp Partners. The Scholar Snapp Central data hub allows you to approve the transfer of data from Scholar Snapp to another Scholar Snapp partner system, which allows those other systems to fill in application forms and other data for you. You are the only person who can authorize the export of your information, and you approve each individual Scholar Snapp partner before we send your data to that organization.
  • Essential E-mail Notifications. We may contact you via e-mail for important notifications. We only do this occasionally, mostly when it is required by law or regulation. For example, we will notify you of any major changes to our Privacy Policy.
  • Opt-In E-mail Messages. If you’ve elected to receive general communications, updates, and reminders from Scholar Snapp, we will provide that information via e-mail.
  • Technical Support and Operations. We may use your data, including your personal information, for internal troubleshooting, operational and administrative purposes. For example, when you contact us for technical support, we may need to use your personal information to confirm your identity.

We may use anonymous, de-identified, and aggregated information for a variety of purposes, including:

  • To improve the services we provide.
  • To evaluate the usefulness and popularity of specific features.
  • To understand in the aggregate who is using Scholar Snapp.
  • To demonstrate to scholarship providers that Scholar Snapp serves their scholarship programs’ qualified applicants. When doing so, we do not reveal any identifying information to external parties.
  • For academic research, internal reporting, or other non-commercial purposes.

SHARING OF YOUR PERSONAL DATA

When do we share your data?

Our core service is providing your information to scholarship and college application systems to speed up the process of filling out application forms. You are alerted whenever a new scholarship application system attempts to exchange your personal information with Scholar Snapp and you must provide your login information and consent before your personal information can be exchanged.

You can deny permission to exchange your personal information with a particular partner for any reason.

As a convenience, some Scholar Snapp partners will offer to keep you logged in to Scholar Snapp (so you don’t have to provide your user name and password with every update). However, you can revoke a partner’s permission to access your information any time.

There are a few rare exceptions where your information may be shared without your consent:

  • We will, of course, comply with legitimate requests from law enforcement agencies. Should this occur, we will notify you as soon as is reasonably practical.
  • We may access information, including personal information, to investigate a suspected violation of the terms under which Scholar Snapp provides its services.
  • Third parties to whom we may transfer or merge Scholar Snapp at some point in the future will have access to your information. Alternatively, we may acquire a third party who may operate Scholar Snapp. If such a change happens, the new organization will only be allowed to use your information under terms consistent with the Scholar Snapp Terms of Service, and this Privacy Policy.
With whom do we share your data?

We only share your data with Scholar Snapp partners who have written, signed data sharing agreements in place with Scholar Snapp, and with whom you’ve authorized us to share your data.

We require that all our Scholar Snapp partners:

  • Have a publicly available, easily readable privacy policy.
  • Have a contact at their organization for security and privacy concerns.
  • Have the means for you to edit and delete your account information, either in the system or by request.
  • Do not use your information for marketing or commercial purposes without your explicit consent.
  • Do not forward your information without your explicit consent.

Once you authorize the export of your personal information to one of our Scholar Snapp partners, that partner will have your information and will use that information in accordance with its privacy policies. We strongly encourage you to review a partner’s policy before providing your authorization, and we will provide you with a link to each partner’s policy before you are asked to consent to sending your information to that partner.  Scholar Snapp does not control the activities of its partners and is not responsible for any uses or disclosures of your personal data by a partner once you have consented to release of your information to that partner. By using the Scholar Snapp platform, you agree to waive your right to make any claims against Scholar Snapp or the Michael & Susan Dell Foundation, and any of its affiliates, for any action or inaction by a Scholar Snapp partner.

A list of current partners can be found on our public website: www.scholarsnapp.org.

HOW WE SECURE YOUR DATA

A big part of keeping your data private is keeping your data secure. We do that in several ways:

  • Data is encrypted in transit and in storage.
  • Our servers and storage are in secure facilities.
  • We use the latest security protocols for login and authorization.
  • We only share information with the Scholar Snapp partners listed on our public website and only with your consent.
  • Our partners cannot access your information without your permission.

We keep a list of the technical details and certifications here.

OUR DATA RETENTION POLICIES

The information you provide Scholar Snapp is not held forever. We delete or anonymize information as soon as it is no longer useful to due to the passage of time or other reasons. The period for which we keep information varies depending on the type of information.

Your Scholar Snapp Profile. A Snapp Profile can be useful over a long period, from your early high school years through college, and beyond. We delete your Scholar Snapp Profile after four years of inactivity.

Backups of your Scholar Snapp Profile. The system maintains backups of your Snapp Profile data, including previous versions and original data we receive from Scholar Snapp partner organizations. We delete backups of your Snapp Profile after a period not to exceed one year.

Log and activity data. The Scholar Snapp system maintains activity logs for a variety of reasons, including to ensure proper function of the system and to aid in support requests. These activity logs contain information related to your use of the system, and errors related to your account. We delete log and activity data regularly, after a period not to exceed 90 days.

System backups. The Scholar Snapp system maintains backups to recover from a system failure or other disaster. These backups mirror the live system, and so contain your Scholar Snapp Profile information. We delete system backups regularly, after a period not to exceed 90 days.

Please note that our Scholar Snapp partners may have different data retention policies than we do.  Once you have consented to transferring your personal data to a partner, Scholar Snapp no longer controls your personal data and your personal data will be handled by the partner in accordance with its privacy policies.  Please be sure to read each partner’s privacy policy carefully before consenting to disclosure of your personal information to that partner.

Marketing information, cookies, and web tracking. If you have elected to receive marketing e-mails from us, we retain information about your preferences for a reasonable period from the date you last expressed interest in our services or used the Scholar Snapp system. We retain information derived from cookies and other tracking technologies for a reasonable period from the date such information was created. Unless required by law or other specific purpose, the period we keep marketing information does not exceed four years after a period of inactivity.

Administrative Data. We retain administrative data such as communications related to your use of the Scholar Snapp system, records of your acceptance of agreements such as the Scholar Snapp terms of service, records of your authorization to share data with specific partners, and other information of this nature. We retain administrative data until the information is no longer necessary to provide our services, and for a reasonable time thereafter as necessary to comply with our legal obligations, to resolve disputes, to enforce agreements, to support business operations, and to improve our services. Unless required by law or other specific purpose, the period we keep administrative data does not exceed four years after a period of inactivity.

We may retain indefinitely anonymized or otherwise deidentified information related to your Scholar Snapp Profile and system activity after deletion.

YOUR RIGHTS

Under most circumstances, you have the following rights with respect to your personal information held by Scholar Snapp.

  • The right to access your personal information. You can review all information, including personal information, in your Snapp Profile by logging in to the Scholar Snapp Online Application.
  • The right to the correction of your personal information. You can edit all information, including personal information, by logging in to the Scholar Snapp Online Application.
  • The right to erasure of your personal information. This right is often called the “right to be forgotten.” You can erase all information, including personal information, in your Snapp Profile by deleting your account. This will remove your main profile and any archived profiles we have for you. This can be done by logging in to the Scholar Snapp Online Application.
  • The right to restrict processing of your personal information. Every time you want to exchange your personal information between Scholar Snapp and a Scholar Snapp partner, you must provide permission by entering your Scholar Snapp credentials. Once we’re sure it’s you, Scholar Snapp will let you know who is requesting access to your information. You can approve or deny permissions. In addition, the Scholar Snapp Online Application provides the ability to revoke permissions. (Revoking permissions can’t “take back” any information you’ve already shared, but it prevents the partner system from accessing your data until you explicitly provide permissions again.)
  • The right to object to processing of your personal information. Other than provide our core function to store and securely share your Scholar Snapp Profile, we don’t process your personal information. Nevertheless, you can delete your Profile at any time, which removes your personal data from our system. You can delete your Scholar Snapp Profile by logging in to the Scholar Snapp Online Application and deleting your account.
  • The right to transfer your personal information. You can download a complete copy of your Snapp Profile. This downloadable Snapp Profile contains all information, personal and otherwise, that you’ve provided to us. You can download your Snapp Profile by logging in to the Scholar Snapp Online Application. If you want to stop using Scholar Snapp and transfer your data to another system, just remember to download your Snapp Profile before you delete your account. Once you delete your account, your information is gone.

These rights can be exercised using the online features of the Scholar Snapp system. However, you may also contact us (via https://www.scholarsnapp.org/faq/#faq-form) with questions, if you require assistance, or if the system appears to have an error preventing you from taking the desired action.

Please note that our Scholar Snapp partners may have different policies regarding your rights relating to your personal information than we do.  Once you have consented to transferring your personal data to a partner, Scholar Snapp no longer controls your personal data and your personal data will be handled by the partner in accordance with its privacy policies.  Please be sure to read each partner’s privacy policy carefully before consenting to disclosure of your personal information to that partner.

COMPLIANCE AND REGULATIONS

The European Union General Data Protection Regulation (EU GDPR)

We adhere to the principles and practices of the EU GDPR. However, Scholar Snapp is based in the United States, so if you are visiting our site from the European Union then there are important details you should know.

Information collected and hosted by Scholar Snapp is stored in the United States and may be exchanged with organizations in other jurisdictions. To the extent that our storage and sharing of your information is considered processing of information, our lawful basis for processing your information is that you have provided consent.

Many of our partners are also based in the United States, and so we do not require that all our partners comply with the EU GDPR. You will need to review and understand our partners’ privacy policies to understand any potential policy or practical limitations to your data protection rights. As noted, you have control over which partners can see your personal information, and you may choose not to permit a partner to access your personal information for any reason – including privacy concerns.

BY USING SCHOLAR SNAPP, YOU ARE AGREEING TO THE PROCESSING OF YOUR PERSONAL INFORMATION IN THE UNITED STATES, AND POSSIBLY OTHER JURISDICTIONS.

Student Data Privacy Pledge

We are a signatory to the U.S. Student Data Privacy Pledge. In the language of the pledge, this means we have committed to:

  • Not collect, maintain, use, or share your information beyond that which is needed for authorized purposes, or as authorized by you.
  • Not sell your personal information.
  • Not use or disclose the information you provide to us information for behavioral targeting of advertisements.
  • Not build a personal profile about you other than for supporting the core service we provide.
  • Not make material changes to our privacy policy without first providing prominent notice to you, and providing you with choices before data is used in any manner inconsistent with terms that were initially provided.
  • Not knowingly your personal information beyond the time period required to support our core service, or as authorized by you.
  • Collect, use, share, and retain student personal information only for purposes for which we were authorized by you.
  • Disclose clearly in privacy policies what types of personal information we collect, and the purposes for which the information we maintain is used or shared with our partners.
  • Support access to and correction of your personal information by you.
  • Maintain a comprehensive security program that is reasonably designed to protect the security, privacy, confidentiality, and integrity of your personal information against risks of unauthorized disclosure.
  • Require that our contracted service providers with whom your personal information is shared are obligated to implement these same commitments for your personal information.
  • Allow a successor entity to maintain your personal information, provided the successor entity is subject to these same commitments for the previously collected personal information.

HOW TO CONTACT US

For general questions, tech support, or requests regarding the exercise of your data privacy rights, e-mail us via https://www.scholarsnapp.org/faq/#faq-form.

Direct any questions or concerns about Scholar Snapp privacy to:

Scholar Snapp
Attn: Data Protection Officer
P.O. Box 163867
Austin, TX 78716
U.S.A.
E-mail: Privacy@ScholarSnapp.org

If you send us a message via postal mail, please include contact information.

We try to acknowledge all requests within two business days after we receive your message and will generally have a resolution (or an estimated time to resolution) within one week.

GLOSSARY

  • Anonymous or de-identified information. Information from which all personally identifying characteristics have been removed, or which has been aggregated in a way that prevents identification of an individual.
  • Partners. When this Policy refers to “partners,” it means organizations that provide scholarships and/or facilitate college admissions and that have signed a Data Sharing Agreement with Scholar Snapp to allow for transfer of your personal data between Scholar Snapp and the partner.
  • Users or you. When this Policy refers to “users” or “you,” it means the students who have created Scholar Snapp profiles and have provided consent to move their data between applications.
  • We or us. When this Policy refers to “we” or “us,” it means the Michael & Susan Dell Foundation, which is the organization that provides support for the Scholar Snapp technology.