Privacy Policy

 

Privacy Policy

Privacy

Last updated: March 14, 2014

American Student Assistance® (“ASA”) provides students and former students with financial education and student loan debt management services (referred to in the Privacy Policy as our “Service”). Some of our Services are provided to you on www.asa.org (“Website”), and some are provided to you offline, such as by phone and through print mail. American Student Assistance is the dba name of Massachusetts Higher Education Assistance Corporation, located at 100 Cambridge Street, Suite 1600, Boston, MA 02114. At ASA®, 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 visitors to our website located at www.asa.org. This Privacy Policy does not apply to our SALT related websites located at www.saltmoney.org, blog.saltmoney.org, www.facethered.com. This Privacy Policy is also separate from ASA’s Privacy Notice under the federal Gramm-Leach Bliley Act, which ASA sends to individuals whose loans it holds.

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, 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.

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.

WHAT PERSONAL 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, 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 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), 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, LinkedIn, 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 or if you post a comment via a plug-in 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 track where you travel on our Website and what activities you engage in. This helps us to improve 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.

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.

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, and to respond to your comments or questions.

We also 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, we may share your Personal Information in limited circumstances as outlined below.

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 of 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 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.

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 www.asa.org because Website Usage Information helps us to improve the user experience and maintain a Website that is useful, accessible, and informative for all of our visitors. 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 MESSAGING 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 opt-out at any time by notifying us at our Contact Information set forth below. 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 you have submitted to us by contacting us at our Contact Information set forth below or by leaving a comment. 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 do not collect your Social Security number unless you provide it to us through the “Submit Your Question” online form or through another type of communication with ASA. However in some cases, we may already have your Social Security number in connection with a separate relationship that we have with you (for example, if we are the guarantor of your loans).

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 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 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.

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.

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 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 webmaster@asa.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.

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.

CONTACT US

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

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