GAcollege411 Privacy Policy

Effective as of August 31, 2008

XAP Corporation ("XAP"), the company that operates GAcollege411, has adopted the following privacy policy for the information collected at this website.

As GAcollege411 evolves, we may update this privacy policy 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 policy posted here will always be current. We encourage you to review this statement regularly.

WHAT THIS PRIVACY POLICY STATEMENT COVERS:

• GAcollege411 privacy policy and its exceptions
• The personal identifying information we collect
• Reasons we collect personal identifying information
• Creating an account when you are under 13 years of age
• Ways in which personal identifying information may be used
• With whom personal identifying information may be shared
• Security measures to protect information entrusted to XAP and GAcollege411
• Cookies
• Links
• Modifying and deleting your information
• Amending this Privacy Policy
• Questions

GACOLLEGE411 PRIVACY POLICY AND ITS EXCEPTIONS

Except as set forth below, personally identifiable data you enter on GAcollege411 is not made available or distributed to third parties, except with your express consent or at your express direction. In particular, GAcollege411 and XAP will not give, sell or provide access to your personal information to any company, individual or organization for its use in marketing or commercial solicitation or for any other purpose, except with your express consent, at your direction, as is necessary for the operation of this site, or pursuant to one of the exceptions listed below.

EXCEPTIONS TO THE PRIVACY POLICY

There are limited exceptions to the GAcollege411 privacy policy. When required by law to comply with any valid legal process such as a search warrant, subpoena, statute, regulation or court order, XAP will supply such information contained in your GAcollege411 account as XAP reasonably determines, based on the advice of counsel, it is legally required to supply. In addition, XAP may release specific information relevant to special cases, such as a physical threat to you or others or an attempted breach of security on the GAcollege411 site.

THE PERSONAL IDENTIFYING INFORMATION WE COLLECT

GAcollege411 collects personal identifying information from you including, but not limited to, your name, date of birth, address, e-mail address, telephone number, grade level, parent's contact information, Social Security number, such additional information as you choose to include in your portfolio or are required to provide by the college and financial aid applications that you choose to complete, and information associated with activities you have undertaken on GAcollege411.

REASONS WE COLLECT YOUR PERSONAL IDENTIFYING INFORMATION

GAcollege411 collects personal information from you primarily for three reasons. The first reason is to perform a task on GAcollege411, such as filling out a specific college admission application, requested by you. 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 GAcollege411 or undertake a scholarship search on GAcollege411, and the third reason is to enable XAP to respond to your questions or contact you when necessary in connection with the functioning of GAcollege411. When the effective functioning of a GAcollege411 module does not require personal information, none is collected, and any such module can be accessed without opening an account or providing any personal data.

When you log on to GAcollege411, your browser will automatically transmit to the GAcollege411 server the IP address of your computer and type of browser you are using. Although your browser transmits the IP address of your computer, GAcollege411 does not associate this IP address with any personally identifiable information regarding you. GAcollege411 does not collect any personally identifiable information other than what users submit and their browsers transmit.

CREATING AN ACCOUNT WHEN YOU ARE UNDER 13 YEARS OF AGE

If you are not yet 13 years old, GAcollege411 will allow you to create an account but will not collect any personal identifying information from you. Some features of GAcollege411, such as the Resume Builder, that require personal information for effective use, will not be available.

If you are 13 years of age or older, you are encouraged to create an account on GAcollege411 and to utilize all of GAcollege411, which will help you plan, prepare and pay for your future education.

WAYS IN WHICH PERSONAL IDENTIFYING INFORMATION MAY BE USED

GAcollege411 will use your personal identifying information to complete the following forms and surveys, to obtain information for you and to effect transactions on your behalf, in each case only upon your instructions to do so:

• Complete applications for admission
• 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

Your personal identifying information may also be used for the following purposes:

• We may use your identifying information to help diagnose problems with the GAcollege411 server and to administer the GAcollege411 website.
• Summary data representing a compilation of aggregate data representing GAcollege411 users may be collected by XAP and provided to various entities including colleges and other educational institutions represented on GAcollege411. NO PERSONAL IDENTIFYING INFORMATION IS MADE AVAILABLE AS PART OF THESE SUMMARY REPORTS. Some examples of summary data are the number of monthly visitors to the site, the number of admission applications submitted over GAcollege411, and the GAcollege411 functions utilized by students in specified age or grade ranges.

WITH WHOM PERSONAL IDENTIFYING INFORMATION MAY BE SHARED

Any time you request that we perform a task that involves a transfer of data, the data related to the performance of that task will be made available to a recipient you designate or to a service provider assisting us in completing that task. For example:

• If you submit an application for admission to a college or other educational institution, the personal data required to complete that 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.

Note: If you begin an application for admission to a college or other educational institution, your name and other data 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.

If you connect your account to a school or other site using GAcollege411 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 GAcollege411 Professional Center, will be able to view your GAcollege411 portfolio including personally identifying information about you. This access is granted to these professional users so that they may assist you in a guidance capacity with your career and education planning. You have the option of not connecting your account to a school or site and making full use of GAcollege411 as an independent user.

Notwithstanding the privacy restrictions that are followed here, under Section 20-2-157 of the Official Code of Georgia, public and private high schools are required to provide all Georgia students' transcript information to GSFC. To facilitate that statutory duty, high schools provide GSFC through this site the following personal information on the student's transcript: name, address, phone number, date of birth, gender, Social Security number, ethnicity, parent's name, parent's address and parent's phone number.

SECURITY MEASURES TO PREVENT MISUSE OF INFORMATION ENTRUSTED TO GACOLLEGE411

GAcollege411 causes the data you input to be encrypted when in route between your browser and the GAcollege411 server and when in route between the GAcollege411 server and some other browser or server. This practice helps prevent unauthorized third parties from intercepting and gaining access to your private data during transmission over the Internet. GAcollege411 uses 128-bit, Secure Socket Layer encryption supported by both Netscape's and Microsoft's browsers.

Data residing on the GAcollege411 server is password protected, and access is provided only to the account holder who created the password, anyone to whom that account holder entrusted the password, and those employees of XAP who require such access to administer and maintain the GAcollege411 system or to provide requested customer support to users of GAcollege411. Each XAP employee who has access to the data residing on the GAcollege411 server has agreed in writing to respect the privacy of all such personal data. We protect customer information through physical, electronic, contractual and procedural measures that comply with or exceed applicable laws and standards. We train our employees to protect customer information and only authorize access for employees who we believe have a business need for that information. We hold employees accountable to a Code of Conduct and Ethics that properly protects customer information. We maintain policies and procedures that provide for the proper physical security of workspaces and records. We require contractors and other companies that provide services on our behalf to protect information, and we prohibit those companies from using it for any other purpose. We only provide them with information that we believe is necessary to fulfill their responsibilities or to provide a financial service to you.

COOKIES

A cookie is a small file that a website transfers to a user's computer, which may then be stored on its hard drive. GAcollege411 uses cookies to remember you and personalize your web-viewing experience by keeping track of your session when logged on to GAcollege411. Cookies enable you to maintain continuity as you move from page to page on GAcollege411 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 cannot be used to steal personal information or to gain access to information that you did not directly provide. The cookies we use are set when you log on to GAcollege411 and are erased when you log off GAcollege411 or completely close your browser.

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. You should note, however, that various GAcollege411 services might not function properly when cookies are not utilized.

LINKS

GAcollege411 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 visiting an official college website. These sites and resources have privacy policies that may differ from that of GAcollege411, 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. XAP is not responsible for the privacy practices or the content of any websites to which GAcollege411 links or for the conduct of persons operating those websites. XAP, the colleges, the associations of colleges and the agencies represented on GAcollege411 do not have control over, and do not endorse such external sites and resources. XAP, the colleges, the associations of colleges and the agencies represented on GAcollege411 shall not be liable for any content, advertising, products or other materials on or available from such sites or resources. In addition, XAP, the colleges, the associations of colleges and the agencies represented on GAcollege411 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 AND DELETING YOUR INFORMATION

You may update, otherwise modify or delete from the data stored on GAcollege411 any personal information you previously provided. To modify personal information, (i) sign in to GAcollege411, (ii) access either your portfolio or an application containing the information you want to change, and (iii) modify that information using standard word-processing techniques. To delete personal information that is not a required field to be completed in your portfolio, (i) sign in to GAcollege411, (ii) access your portfolio, and (iii) delete the information you want to remove from GAcollege411 using standard word-processing techniques and (iv) save the change. To delete personal information that is a required field to be completed in your portfolio, you will need to contact XAP at 1-800-GOTO-XAP and request that your profile be deleted. Please recognize that if you delete information, it will no longer be available on GAcollege411 so that, for example, if a college to which you previously submitted an application were to attempt to retrieve that application from GAcollege411 after you made the deletion the deleted information would no longer be accessible. Similarly, when accessed over GAcollege411, information that has been updated or otherwise modified will appear in its then-most current form, rather than in the form in which it may have been submitted at some earlier time.

AMENDING THIS PRIVACY POLICY

XAP may amend this Privacy Policy from time to time. Unless legal obligations require faster implementation, if XAP makes any substantial changes to this Privacy Policy concerning use of your personal information XAP will notify you by posting a message on the GAcollege411 homepage for at least thirty days. Thereafter, the new privacy policy will apply to all data previously submitted or subsequently submitted to GAcollege411, unless such use if prohibited by law. If you do not wish to have your information used in accordance with a newly posted privacy policy, you should modify or delete the relevant information in the manner described in the preceding section, "Modifying and Deleting Your Information."

QUESTIONS?

If you have any questions about this Privacy Policy and the privacy practices on this site, you may contact us at support@xap.com.