CFWV.com Privacy Policy
Last Updated: September 30, 2020
XAP Corporation including its subsidiary Bridges Transitions
Inc. (collectively, "XAP") (the company that operates www.cfwv.com) has adopted the
following Privacy Statement for the information collected at this
website. When you use CFWV.COM XAP has access to your
information and may use your information to operate and maintain www.cfwv.com and in accordance with
the terms of this Privacy Statement.
As www.cfwv.com evolves, we
may update this Privacy Statement to reflect changes in the manner
in which we deal with personal information, whether to comply with
then-applicable regulations and self-regulatory standards or
otherwise. The Privacy Statement posted here will always be
current. We encourage you to review this Statement regularly.
Please see additional information regarding amending this Statement
in the Section entitled "Amending this Privacy Statement"
below.
IMPORTANT NOTICE: Please see the information in
the Section entitled "With whom personally identifying information
and automatically collected information may be shared" for an
understanding regarding the parties who may access your
information.
WHAT THIS PRIVACY STATEMENT COVERS:
- Your agreement to this Privacy Statement
- Types of information collected
- Creating an account when you are under the age of 18
- Reasons we collect personally identifying information
- Ways in which personally identifying information and
automatically-collected information may be used
- With whom personally identifying information and
automatically-collected information may be shared
- Security measures to protect information; Disclaimer
- Cookies
- Links
- Modifying your information
- Retention and Storage
- Amending this Privacy Statement
- Unenforceability
- Questions
YOUR AGREEMENT TO THIS PRIVACY STATEMENT
When you use www.cfwv.com, you
signify and affirm that you have read, understand, and agree to the
terms of this Statement; that you are competent and capable of
understanding, agreeing to, and complying with this Statement; and
that this Statement forms a legally-binding agreement between you
and XAP. You agree that this Statement is supported by reasonable
and valuable consideration (which includes your use of www.cfwv.com), and you acknowledge
your receipt of and the sufficiency of such consideration. If you
do not agree with all of the provisions of this Statement, you may
not use www.cfwv.com).
TYPES OF INFORMATION COLLECTED
This Statement covers information you expressly enter into www.cfwv.com and information that we
automatically collect as you use www.cfwv.com.
THE PERSONALLY IDENTIFYING INFORMATION WE COLLECT
To use certain features of www.cfwv.com we will require you to
provide us with information that personally-identifies you
("Personally Identifying Information" or "PII"). If you choose not
to provide us your Personally Identifying Information, you will not
be able to use certain features of www.cfwv.com. When you do provide us
your PII, you are authorizing us to use that PII in accordance with
this Statement and to store your PII on our servers in the United
States. The categories of PII that www.cfwv.com may collect from you
include your name, date of birth, address, email address, phone
number, grade level, Social Security number, username and password,
demographic data (such as your gender, ethnicity, and zip code),
parent's or guardian's names, parent's or guardian's addresses and
phone number and other contact information, user preferences, and
such additional information as you choose to actively enter into www.cfwv.com and include in your
portfolio or are required to provide by the college and/or
financial aid applications that you choose to complete or other
actions you choose to take through www.cfwv.com. Further, some schools
provide students' transcript information to us, including at least
the following student PII contained on the applicable student's
transcript: Name, address, date of birth, gender, ethnicity,
graduation year, email address, grade point average (GPA), Student
number (from your school district), and State Student ID. If a
school provides us this transcript information about you, we will
automatically include that information in your account on www.cfwv.com.
AUTOMATICALLY-COLLECTED INFORMATION
When you use www.cfwv.com, we
automatically track, collect, and store the following types of
information (referred to as "Automatically-Collected Information"):
1) Date and time you access www.cfwv.com; 2) pages visited and
features used, and the order of use; 3) type of computer or other
operating device accessing www.cfwv.com and type of browser
used to access www.cfwv.com; 4)
referring source (meaning the website you visit prior to visiting
www.cfwv.com); and 5) other
similar information about the interaction between your browser and
www.cfwv.com and activities in
which you engage while using www.cfwv.com. Unless otherwise
stated in this Statement, Automatically-Collected Information may
be combined with your PII.
When you visit www.cfwv.com,
we collect your Internet Protocol ("IP") address to track and
aggregate Automatically-Collected Information. We also collect IP
addresses of users when they log onto their account portfolios on
www.cfwv.com in order to confirm
the applicable user's identity.
CREATING AN ACCOUNT WHEN YOU ARE UNDER THE AGE OF 18
Between Age 13 and 17
If you are between the ages of 13 and 17, by using www.cfwv.com, you represent and
warrant that you possess legal parental or guardian consent to use
www.cfwv.com and provide PII and
Automatically-Collected Information through www.cfwv.com.
Under Age 13
If you are under the age of 13 and you indicate to us that you
are under age 13 when you enter your birthdate into www.cfwv.com, you can only create an
anonymous account that does not require you to enter your name or
other Personally Identifying Information. When there are
open fields required in order to create such an anonymous account,
you may not use any of these open fields to enter Personally
Identifying Information, and your account portfolio will not
include your Personally Identifying Information. Further,
you will be restricted from using any areas of www.cfwv.com that require you to
enter Personally Identifying Information. You will only be able to
use www.cfwv.com features or
modules that do not require you to enter Personally Identifying
Information.
REASONS WE COLLECT PERSONALLY IDENTIFYING INFORMATION
www.cfwv.com collects PII from
you primarily for three reasons. The first reason is to perform a
task on
www.cfwv.com requested by
you, such as filling out a financial aid application. The second
reason is to enable you to submit, in a convenient and efficient
manner, information that is likely to be needed when you complete
college admission, financial aid, and other applications and forms
made available through
www.cfwv.com or undertake a
scholarship search on
www.cfwv.com. The third reason is to
enable XAP to respond to your questions or contact you when
necessary in connection with the functioning of
www.cfwv.com or to provide required
notices.
WAYS IN WHICH PERSONALLY IDENTIFYING INFORMATION AND
AUTOMATICALLY-COLLECTED INFORMATION MAY BE USED
Upon your instructions to do so, www.cfwv.com will use your PII to
complete the following forms and surveys, to obtain information for
you, and to effect transactions on your behalf:
- Complete financial aid applications
- Complete financial aid calculators
- Complete a scholarship search
- Complete Your Plan of Study, which can assist you in selecting
courses and otherwise planning to meet admission requirements
- Communicate your requests for information or material to
colleges or other institutions you have specified
- Complete applications for admission to educational
institutions
Your PII and Automatically-Collected Information may also be
used for the following purposes:
- We may use your PII and Automatically-Collected Information to
help diagnose problems with the www.cfwv.com server and to
administer www.cfwv.com.
- We may use your PII and Automatically-Collected Information to
customize and tailor your experience using www.cfwv.com, displaying content on
www.cfwv.com that we think you
might be interested in and according to your preferences (but we do
not track your activity across multiple websites for the purpose of
serving targeted advertising to you).
Summary data consisting of a compilation of de-identified and
aggregate data representing www.cfwv.com users may be collected
by XAP and provided to various entities including colleges and
other educational institutions represented on www.cfwv.com. NO PII IS MADE
AVAILABLE AS PART OF THESE SUMMARY REPORTS. Some examples of
summary data are the number of monthly visitors to www.cfwv.com, the number of
admission applications submitted over www.cfwv.com, and the www.cfwv.com functions utilized by
students in specified age or grade ranges.
WITH WHOM PERSONALLY IDENTIFYING INFORMATION AND
AUTOMATICALLY-COLLECTED INFORMATION MAY BE SHARED
Except as set forth below, PII you enter on www.cfwv.com is not made available
or distributed to third parties, except with your express consent
or at your express direction. In particular, XAP will not give,
sell, rent, trade, transfer, otherwise provide or provide access to
your PII to any company, individual, or organization for its use in
marketing or commercial solicitation or for any other purpose,
except with your express consent and at your direction, unless it
is pursuant to one of the exceptions listed below or necessary for
operation of www.cfwv.com.
We may share your PII as follows:
- School Administration and Staff. Your account is meant
to help you set goals and plan for the future. If you connect your
account to a school or other site using www.cfwv.com as part of a career and
education planning program, then professional staff at that school
or site designated by the administration of the school or site to
have access to the www.cfwv.com
Professional Center will have access to view (i) your www.cfwv.com portfolio, including
your PII that is part of your portfolio, (ii) email communications
to and from you through www.cfwv.com, (iii) and all other
PII and other content that you add to www.cfwv.com as part of your
portfolio. This access is granted to these professional users so
that they may assist you in a guidance capacity with your career
and education planning.
- Parents and Guardians. You may request that
your parent or legal guardian be given permission to view your
portfolio (including all PII and other content that you add to www.cfwv.com as you use www.cfwv.com). And if you do make
this request, your parent or legal guardian will be granted access
to your portfolio and may view all of your PII associated with your
portfolio.
- Bridges Transitions Inc. XAP Corporation and
Bridges Transitions Inc. reserve the right to share PII with one
another (regardless of which entity first collected the
information) in connection with the maintenance and operation of www.cfwv.com and for use in
accordance with this Statement.
- As Directed by You. Any time you request that
we perform a task that involves a transfer of PII, the PII related
to the performance of that task will be made available to a
recipient you designate. For example:
- If you submit an application for admission to a college or
other educational institution, the PII required to complete that
application and any other PII you entered onto the application will
be provided on your behalf to the admissions office of the
institution to which you are applying.
- If you request that a college or other educational institution
send you material, your contact information will be provided to
that institution so the institution can send you material and
contact you.
Note: If you begin an application for admission to a
college or other educational institution, your name and other PII
entered on that application may be provided to the admissions
office of that institution, even though you have not yet submitted
a completed application to that institution. The institution may
then contact you regarding your potential attendance.
- Required by Law. When required by law to
comply with any valid legal process such as a statute, regulation,
search warrant, subpoena, or court order, XAP may supply PII
contained in your www.cfwv.com
account as XAP reasonably determines, based on the advice of
counsel, it is legally required to supply. XAP may also disclose
PII in emergency situations, to protect your safety or the safety
of others, to defend against legal claims, to enforce XAP's
contractual or other rights, or to take actions regarding illegal
activities or suspected fraud.
- Merger, Acquisition, or Sale of XAP. XAP may
transfer your PII and Automatically-Collected Information to
another entity if XAP is involved in a merger, acquisition,
reorganization, restructuring, or other sale or transfer of all or
any portion of its assets or business. In this event, we will, if
allowed, use reasonable efforts to notify you when your information
is transferred to a third party (this notification may be made via
email to you or by posting a prominent notice on www.cfwv.com). Unless you consent
otherwise, XAP will contractually require any successor to treat
your PII in accordance with the promises made in this Statement,
even after the transfer. But any information you provide after the
transfer will likely be subject to a new privacy statement, and you
should review that statement.
- Third-Party Payment Processor. We use a
third-party intermediary to manage payment processing when you
submit payment to apply to an educational institution through www.cfwv.com. This intermediary is
not permitted to store, retain, or use your financial information
or other PII, except for the sole purpose of processing payments
you initiate.
- Third-Party Service Providers. We may share
Automatically-Collected Information with our third-party service
providers who assist us by performing services related to our
operation of www.cfwv.com (such
as hosting, data storage, and security). Such third-party service
providers are not authorized to use your information in any way
other than as described here and are required to keep the
information confidential.
- Third-Party Analytics Services. We may use
third-party analytics services to assist us in better understanding
our www.cfwv.com users. For
example, we use these services to track and analyze certain
Automatically-Collected Information, such as feature usage. We only
ever provide these service providers with (or allow these service
provides to collect on our behalf) Automatically-Collected
Information. We use the information collected from these service
provides to make www.cfwv.com
better and easier to use. The information we receive from these
third parties may be re-associated with your PII after we receive
it back from these third parties. These third parties are not
authorized to use the information in any other way and are required
to keep it the information confidential.
SECURITY MEASURES TO PROTECT INFORMATION; DISCLAIMER
XAP uses industry standard physical, electronic, and procedural
security measures to protect against the loss, misuse, and
unauthorized access, disclosure, alteration, and destruction of PII
and Automatically-Collected Information we collect and store. For
example, www.cfwv.com encrypts
the PII you enter when it is in route from your browser to the www.cfwv.com web servers, and again
when your PII is in route from the web servers to the back-end
database servers using TLS 1.2. This practice helps prevent
unauthorized third parties from intercepting and gaining access to
your PII during transmission over the Internet. www.cfwv.com is WC3 compliant and
performs properly on all major operating system platforms as well
as all major modern internet browsers specifically including, but
not limited to, Windows, Macintosh, Linux, iOS, Chrome, Safari,
Firefox, Edge, Internet Explorer, and the build-in Internet
browsers for iOS and Android.
PII residing on the www.cfwv.com server is password
protected, and account access is provided only to the account
holder who created the password, anyone to whom that account holder
entrusted the password, designated school administrators and staff,
and those employees of XAP who require such access to administer
and maintain the www.cfwv.com
system or to provide requested customer support to users of www.cfwv.com. Each XAP employee who
has access to the PII residing on the www.cfwv.com server has agreed in
writing to respect the privacy of all such PII. XAP trains
employees to protect customer information and only authorize access
for employees who XAP believes have a business need for that
information. XAP holds employees accountable to a Code of Conduct
and Ethics to protect user information.
The safety and security of your PII also depends on you. You
should not send us sensitive PII via email, as this is not secure.
You are also responsible for keeping your account username and
password confidential. Please notify us if you become aware that
your PII is lost, stolen, or used without permission; we may
disable access to your account in order to prevent an unauthorized
third party from accessing your account.
While we take industry-standard security measures to protect the
privacy of your PII, we cannot guarantee that your PII will never
be compromised. No Internet or wireless network transmission is
ever 100% secure, and no security system can prevent all security
breaches. We do not and cannot guarantee that there will be no
unintended disclosures of your PII or that unauthorized third
parties will not defeat our security measures or use non-public
information for improper purposes.
COOKIES
We collect and store Automatically-Collected Information through
a standard feature found in browser software called a "cookie." A
cookie is a small file that a website transfers to a user's
computer or other operating device, which may then be stored on the
computer's or operating device's hard drive. www.cfwv.com uses cookies to
remember you and personalize your web-viewing experience by keeping
track of your session when using www.cfwv.com. Cookies enable you to
maintain continuity as you move from page to page on www.cfwv.com and to avoid the
nuisance of being asked to provide the same information repeatedly.
Cookies also allow us to make sure that only your browser can
exchange information regarding your account with our servers.
Cookies also provide us Automatically-Collected Information about
www.cfwv.com features used and
activities conducted while using www.cfwv.com. We may use cookies to
aggregate data about user traffic on and user interaction with www.cfwv.com so we can offer better
experiences and tools in the future. The cookies we use are called
session cookies, meaning they are set when you use www.cfwv.com and are erased when you
end your session on www.cfwv.com
or completely close your browser. The XAP cookies we use do not
remain on your hard drive after you end your session on www.cfwv.com or completely close
your browser.
Third-Party Cookies
We use third-party services provided by Google Analytics to
track and analyze your www.cfwv.com activity. In order to
gather this Automatically-Collected Information, we use a Google
Analytics cookie on www.cfwv.com.
If you don't want your Automatically-Collected Information used by
Google Analytics, Google recommends installing the Google Analytics
Opt-out Browser Ad-on, located here: https://tools.google.com/dlpage/gaoptout/.
We also have third-party widgets on www.cfwv.com, such as widgets
provided by YouTube, PollDaddy and Screencast. When you use these
third-party widgets by using features of our site, the widgets may
place cookies associated with these widgets on your computer or
other operating device.
Don't want cookies?
Most browsers are initially set to accept cookies. If you don't
want cookies, you can set your browser to disable or refuse cookies
or to alert you when cookies are being used. Please refer to your
browser for information on how to disable and control cookies. You
should note, however, that various www.cfwv.com services and features
might not function properly when cookies are not utilized.
LINKS
www.cfwv.com hosts links to
other sites or resources, and you may link to one of those sites or
resources for a variety of purposes, such as but not limited to
visiting an official college website. These sites and resources
have privacy statements that may differ from that of www.cfwv.com, and for your
protection, we recommend that you read and understand the privacy
policy at any website prior to providing personal information on
that website or otherwise continuing to use that website. XAP is
not responsible for the privacy practices or the content of any
websites to which www.cfwv.com
links or for the conduct of persons operating those websites. XAP
does not have control over such external sites and resources. XAP
shall not be liable for any content, advertising, products, or
other materials on or available from such sites or resources. In
addition, XAP shall not be responsible or liable, directly or
indirectly, for any damage or loss caused or alleged to be caused
by or in connection with use of or reliance on any such content,
advertising, products, or materials on or available through any
such site or resource.
MODIFYING YOUR INFORMATION
You may update on www.cfwv.com
any PII you previously provided. To modify PII: (i) Sign in to www.cfwv.com, (ii) access either
your portfolio or an application containing the information you
want to change, (iii) modify that information using standard
word-processing techniques, and (iv) save the change. If you want
to remove PII that is in a required field (and not replace it with
other data), you will need to contact XAP at 1-800-281-1168 and
request that your account be inactivated.
Please recognize that if you delete information, it will
no longer be available on www.cfwv.com so that, for example,
if a college to which you previously submitted an application were
to attempt to retrieve that application from www.cfwv.com after you made the
deletion, the deleted information would no longer be accessible.
Similarly, when accessed over www.cfwv.com, PII that has been
updated or otherwise modified will appear in its then-current form,
rather than in the form in which it may have been submitted at some
earlier time. Please note that if you modify or delete any
PII, we may retain the earlier-submitted PII, as described in the
section below entitled "Retention and Storage."
RETENTION AND STORAGE
We retain all PII and Automatically-Collected Information in our
databases to fulfill the purpose for which the information was
collected. Because www.cfwv.com
is intended to help you set goals and plan for your future
education and career path, the PII you put into www.cfwv.com will be retained until
you ask us to remove your information. Note that even after you ask
that we remove your information from our databases, it may be
impossible to remove some information, such as information tracked
in our web server log files and information that may reside in
backup files. We may also retain Automatically-Collected
Information even after you request that we remove your information
from our databases, for use in the aggregate and to analyze and
improve www.cfwv.com. Further,
even after you request that we remove your information from our
databases, we may retain PII and Automatically-Collected
Information to comply with applicable laws, rules, regulations, or
guidelines; to prevent fraudulent activity; to protect ourselves
against liability; to resolve disputes; and to enforce our
contractual or other rights. Notwithstanding the foregoing, XAP
will not retain PII for longer than is allowed under applicable
law.
AMENDING THIS PRIVACY STATEMENT
XAP may amend this Privacy Statement from time to time. We will
post any new Statement here, and you should review this Statement
regularly to make sure you are aware of its terms. You can
determine if this Statement has been revised since your last visit
to www.cfwv.com by referring to
the "last updated" date at the top of this Statement. If XAP makes
any substantial changes to this Privacy Statement, XAP may also
notify you (i) by posting a message on the www.cfwv.com homepage for at least
thirty (30) days; or (ii) by providing direct notice to you via
your contact information or by requiring that you agree to the
revised Statement to next time you log into your account on www.cfwv.com. Once posted to
www.cfwv.com, the new Privacy
Statement will apply to all data previously submitted and
subsequently submitted to www.cfwv.com, unless such use is
prohibited by law.
UNENFORCEABILITY
If any part of this Statement is determined to be invalid,
illegal, or unenforceable under applicable law, then the invalid,
illegal, or unenforceable provision will be deemed to be superseded
by a valid, legal, and enforceable provision that most closely
matches the intent of the original provision, and the remainder of
this Statement will continue in full force and effect.
QUESTIONS?
If you have any questions about this Privacy Statement and the
privacy practices on this site, you may contact us at support@xap.com.