Intersect Privacy Policy March 29, 2017

Intersect by Hobsons (“Intersect”) is a web and mobile-based platform owned and operated by Hobsons, Inc (“Hobsons”). Intersect is a matching platform that enables higher education institutions to increase awareness with high school counselors and students and to facilitate connections with best-fit students that enhance the likelihood of successful application and enrollment. It includes access to the Hobsons Counselor Community, which connects K-12 school counselors with higher education admissions officers in a community environment to better support students’ education pathways. 

Your privacy is important to us and we are committed to protecting your information. This Privacy Policy explains how we collect, use and protect information in Intersect. This Privacy Policy must be read together with the Terms of Use.

If you are located outside of the United States, please be aware that the information you provide to us is transmitted to and processed in the United States. Data will be protected subject to this Privacy Policy and applicable law, which may be different from the laws in your country. By using Intersect, you agree to this.

User Provided Information:

Š       Higher Education Institutions (Clients):

When Clients decide to use Intersect, the primary account representative submits their first and last name, email address and institution name.  This information is used to create their institution account and to allow the Client to create access credentials for their admissions representatives.  Admissions representatives may then activate their profile and enter their user information, including their first and last names, email addresses, user names, passwords, job title, role, and institution.

Clients may also import information on their prospective students to host within Intersect.  This information is only available to the Client that imported the information.  It is not made public and is only used to allow the Client’s Users to manage their admissions planning.

 

Clients may share aggregated, deidentified information about their student population with the community.  This information is provided to Intersect in a deidentified state.  Intersect does not allow Clients to share identified student information on the platform.

 

Higher Education Institution Admissions Representatives and High School Counselors (Users):

Users create their profile by submitting minimally required information:

o   First Name and Last Name

o   Institution of Employment

o   Email Address

o   Job Title

 

Additional information Users would like to include in their profile is at their discretion and includes, but is not limited to:

o   Personal Email

o   Office Phone

o   Mobile Phone

o   Population Served

o   Profile Picture of User

o   Alma Mater

o   Biography

 

User may also provide additional information and content when participating in community forums and discussions with other Users.

 

Intersect Usage Information and Cookies:

When using Intersect, our servers automatically collect the Internet Protocol (“IP”) address associated with the user’s computer. We may also collect additional information such as login timestamp, the browser type and version, and the operating system of the computer. This information is logged to help us to diagnose technical problems and to administer Intersect.

 

To collect information about the use of Intersect, we use cookies. Cookies are small data files sent by a website or application and stored on the computer or device at the request of that site or app. Cookies store information related to the browser to enable us to recognize the browser on return visits to Intersect and to remember your preferences. We use third-party service providers to assist us in collecting and understanding the usage information. Most browsers can be set to detect browser cookies and to let you reject them, but Intersect will not function properly without cookies enabled.  To learn more about browser cookies, including how to manage or delete them, look in the Tools, Help or similar section of your web browser.

 

How We Use and Disclose Information:

WE DO NOT SELL DATA, and we do not use personal information for commercial purposes. We do not disclose, distribute, access or reference student information that Clients may import into Intersect.

 

In addition, we do not disclose, distribute, access or reference Client or User personal information except as noted at the time that we request the information, when Users choose to connect with other Users and share their information, when Users post in public forums, or in the following circumstances:

Š       To create the Client account, provide log in credentials and authenticate Users

Š       To share with our third party service providers which support and administer the internal operations of Intersect and provide features on our behalf

Š       To resolve a problem or support issue on behalf of a Client or User

Š       To investigate a suspected violation of the Terms of Use or to investigate fraud or other unlawful uses

Š       To protect the rights, property and safety of Users

Š       As may be required by law or as ordered by a court, in which event we will notify Clients when permissible and will work with Clients to seek to limit the scope of the required disclosure

Š       In the event of a reorganization, merger, sale, assignment, bankruptcy, or other disposition of our business, in which case the transferred information will remain subject to the terms of this Privacy Policy.

We may use non-personal information from Clients and Users, including aggregated, de-identified data for a variety of purposes subject to applicable law, including, but not limited to developing and improving our products and services and demonstrating the effectiveness of our products, including in our marketing of those products.  We do not create aggregated, de-identified data from prospective student information that Clients may choose to import into Intersect.

Third Party Services:

We may work with third party service providers to facilitate delivery of certain Intersect features on our behalf.  These providers may require a limited amount of information, including personal information, in order to deliver the services.  We do not disclose more information than is necessary for a third party to provide a feature on our behalf, and all third parties agree to handle information they may receive in compliance with this Privacy Policy and the Intersect security requirements.  Third parties may only use personal information for the sole purpose of providing the services.

How Clients and Users Can Modify Information:

Clients may update or change their institution’s information by contacting us, or in some cases, may update their records through the relevant areas of Intersect. We also provide Clients with a dashboard that allows them to access, modify, and delete their institution data.  Clients always have access to their prospective student information and may modify, delete or download that information at any time.

 

Users may update or change their profile information through their profile page in Intersect.

 

Clients and Users should be aware that if they share information with other Users, we are unable to retrieve that information.  In addition, Clients and Users should be aware that if they choose to connect with a postsecondary institution in another country, their data will be subject to the laws of that country.

 

Links:

Intersect allows Clients and Users to post links to their institution websites. We do not control, and therefore are not responsible for, the content or privacy practices of those websites. Those websites are governed by their own privacy policies, and we encourage Clients and Users to read them.

 

Security:

We are committed to protecting the security, integrity and confidentiality of the data through the use of physical, technical and administrative safeguards. Intersect uses Transport Layer Security (TLS) encryption and server authentication technology to protect data when Intersect is accessed using a supported web browser.

We host the data in secure cloud-based environments that use a firewall and other industry-standard technology in an effort to prevent interference or access from outside intruders. We also require unique account identifiers, user names, and passwords that must be entered each time Clients or Users sign on to Intersect. The Internet, however, is not perfectly secure and we are not responsible for security breaches not reasonably within its control.

We require that Clients and Users maintain the confidentiality of their user names and passwords. If Clients or Users become aware of any unauthorized use of an account, loss of their account credentials or suspect a security breach, they should notify us immediately at infosec@hobsons.com.

Data Retention:

We retain the data at the discretion of Clients, and for as long as they have active agreements for Intersect. After termination of an agreement, we will retain Client and User data for a limited time period in accordance with the Intersect Data Retention Policy for the convenience of Clients, so that they may retain continuity of their experience should they choose to reengage with Intersect. At the end of the data retention period, we securely delete and destroy personal information from Clients from our server environment.   

 

Note that deleting data from our server will not delete information that users have posted within message boards or in other community areas, and such posts will persist as long as the message board or community area remains active, unless the User chooses to delete their posts or the Client or a User sends us a written request to have all of their user posts deleted.  We will comply with such written requests within 30 days.

At any time upon termination of an agreement or otherwise at their discretion, Clients may submit a written request to have their personal information and any prospective student information provided to Intersect deleted. We will comply with such written requests within (30) days.

Note that in the event that a User chooses to share data with another User, we are unable to delete or otherwise retract that information from that User.   

Notwithstanding the above, we do retain non-personal information, including aggregated, de-identified data for the purposes described in the section titled, “How We Use and Disclose Information.”

Opt-Out Policy:

We send emails to Clients with information about our products that we believe may be of interest. Clients may opt out of receiving email messages from Intersect by contacting us at privacypolicy@hobsons.com or by clicking on the “unsubscribe” link found at the bottom of every email that we send.

If Clients have opted out of receiving communications from us, we may still send essential communications regarding Intersect to Clients’, such as password change messages.

We do not send email messages on behalf of third parties.

Updates to This Policy:

As our product evolves, we may make changes to this Privacy Policy. The “last updated” note at the top of this page indicates when it was last revised. Material changes to the Privacy Policy will be provided to the business contacts for our Clients, and such changes will be effective when accepted by Clients on behalf of their employees and when the Privacy Policy is posted within Intersect. Non-material changes will become effective when we post the revised Privacy Policy within Intersect.

 

Contact:

If you have any questions regarding this Privacy Policy, please contact us at:

Hobsons, Inc.

50 E-Business Way, Suite 300
Cincinnati, OH 45241

Attn: Privacy Office

Email: privacypolicy@hobsons.com