CollegeXpress Privacy Policy

Last Updated: March 21, 2025

CollegeXpress and similar services that link to this Privacy Policy are operated and provided by Carnegie Dartlet LLC (“Carnegie”). Carnegie and its affiliates appreciate your trust and respect your right to privacy. This Privacy Policy applies to personal information that Carnegie collects from or about you and describes how you can exercise your privacy rights.

This Privacy Policy applies to personal information we collect from users of www.collegexpress.com and any similar site or service in which this Privacy Policy is linked or referenced (collectively, our “Services”) and describes the types of personal information we may collect and our practices for collecting, using, maintaining, protecting, and disclosing that information. Please read this Privacy Policy carefully to understand our practices regarding your personal information. By accessing or using the Services, you agree to this Privacy Policy and the CollegeXpress Terms of Use. If you do not agree with our policies and practices, please do not visit, access, use, or otherwise interact with the Services.

Except as otherwise provided in this Privacy Policy, “personal information” is information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you. “Personal information” does not include information which is generally not considered “personal information” under applicable law or is otherwise exempted under applicable law, such as information which is publicly available or subject to special data privacy laws and/or regulations, or information not otherwise considered “personal information” under applicable law.

This Privacy Policy describes and applies exclusively to personal information (as defined below) that we collect in connection with the Services and in texts, emails, and other communications sent through or in connection with the Services. Except as otherwise provided in this Privacy Policy or as required by applicable law, this Privacy Policy does not apply to information that we collect outside of CollegeXpress and similar services, or information collected by any third-party application, website, or third party other than the Services, including through any application or content that may access, be linked to, or otherwise be accessible from the Services. If you visit an application, website, or third party that we mention or link to, be sure to review its privacy policy before providing it with any information, as that privacy policy will apply to those interactions.

This Privacy Policy does not apply to personal information that we process on behalf of our college clients in connection with the marketing, consulting, and other services Carnegie provides. When we act as a service provider for our clients, our clients determine and control what personal information we collect on their behalf and the purposes for which we process that personal information. Accordingly, please review the relevant colleges’ privacy policies to review the personal information we collect and process on their behalf.

INFORMATION WE COLLECT

We collect several types of information from and about you when you interact with us. This information may include various categories of personal information, such as:

• Identifiers – Information that identifies you personally or with which you can be contacted, such as, for example, name; postal address; email address; telephone number; IP address; account credentials and profile information; date of birth; demographic information; and other personal information that you provide to us.
• Internet or Other Similar Network Activity Information – Information about your internet connection, your equipment, browsing history, and your use of the Services, such as device type and identification number, browser type, internet service provider, operating system, and similar technical information.
• Geolocation Information – Information regarding general physical location, such as country- or city-level location, from IP address and Wi-Fi access (when your device’s operating system settings allow collection).
• Sensory Information – We may collect your photograph, if you choose to give it to us.
  Educational Information – Information such as your high school, grade point average, test scores, extracurricular activities, and expected major.
• Professional or Employment-Related Information (depending on how and why you use the Services) – Information including your current employer (e.g., college or university or advertiser) that is our client or prospective client; your status as a school counselor using CollegeXpress; and any other personal information you provide us when you apply to work with us.
• Other information you give us when you communicate with us or the Services, such as by completing our surveys or other online forms or by entering one of our sweepstakes
• Inferences drawn from any of the above

This information may also include:

• Information that is about you but individually does not identify you, such as information which has been de-identified or aggregated in a manner where it can no longer be used to identify you.
• Any other information, including personal information, which you disclose or share.

Some of the personal information we collect may be considered “sensitive” personal information. Depending on how you use the Services and the information you elect to provide, we may collect the following categories of sensitive personal information: racial or ethnic origin, religious beliefs, and gender.

We may aggregate or de-identify the information described above. Aggregated or de-identified information that we do not attempt to reidentify is not subject to this policy.

HOW WE COLLECT PERSONAL INFORMATION

We may obtain and combine personal information from different sources, collected online and offline, including information from third-party sources across different types of technology and devices.

• When you use our Services, you may directly provide us with your personal information, or we may ask you to provide certain personal information.
• We automatically collect certain information about your use of the Services from the computers or mobile devices of our users. Some of this automatically collected information is personal information under applicable law. The information that we automatically collect includes information about how your computer or device interacts with our Services, including the date, time, search requests and results, web pages accessed, and links clicked; IP address, broad geographic location (e.g., country or city-level location which Carnegie derives from IP address or other data), device type and identification number, browser type, internet service provider, operating system, and similar technical information; and stored information and files such as metadata and other information associated with files stored on your device. Some of this information is automatically collected using cookies and similar tracking technology. See the OUR USE OF COOKIES AND SIMILAR TRACKING TECHNOLOGY section below.
• From time to time, we may receive personal information about you from third-party sources, such as colleges, universities, and school counselors that use CollegeXpress, advertisers, marketing services vendors, and other third parties that help us identify individuals who may be interested in learning more about our Services, and from publicly available sources.

HOW WE USE YOUR PERSONAL INFORMATION

We may use the personal information that we collect about you or that you provide to us for the purposes described below.

We may also use the personal information that we collect for the following additional purposes:

• To fulfill or meet the reason you provided the information.
• To carry out our obligations and enforce our rights, including those arising from any contracts entered into between you and us, including for billing and collection.
• To process your requests, purchases, transactions, and payments and prevent transactional fraud.
• To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
• To help maintain the safety, security, and integrity of our Services, products and services, databases and other technology assets, and business.
• To evaluate, negotiate, or conduct a merger, divestiture, restructuring, reorganization, dissolution, other sale or transfer of some or all of our assets, or the negotiation thereof, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our users and customers is among the assets transferred.
• For testing, research, analysis, and product development, including to develop and improve our Services, products, and services.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations, or to otherwise comply with applicable law.
• For any other purpose with your consent or as otherwise permitted by law.

HOW CARNEGIE SHARES PERSONAL INFORMATION

We may disclose the categories of personal information that we collect or that you provide to us as described below.

• With colleges, universities, and education partners you want to connect with, such as when you select the green “Connect Me!” button or a heart emoji.
• To our subsidiaries, affiliates, and agents.
• To contractors, service providers, and other third parties we use to support our business, including our data storage providers, cloud service providers, and email service providers.
• To an actual or prospective buyer or other successor in the event of an actual or proposed merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our users is among the assets transferred.
• To comply with any court order, law, legal process, or law enforcement, including to respond to any government or regulatory request.
• To enforce this Privacy Policy, our Terms and Conditions, terms of use, terms of sale, and other agreements with you, including for billing or collection.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Carnegie, our customers, or others.
• As necessary to fulfill the purpose for which you provide it.
• Otherwise with your consent or as described in this Privacy Policy.

We do not sell personal information, or share personal information for targeted advertising, that we obtain from users of CollegeXpress or similar services that link to this Privacy Policy.

If you choose to create an account or disclose information through one of the interactive areas on our Services (such as when we make user community tools available to you), others may see your information and use it in ways that we cannot control. Please keep this in mind before you share information that identifies you.

OUR USE OF COOKIES AND SIMILAR TRACKING TECHNOLOGY

What are cookies?
Cookies are small text files that are sent to or accessed from your web browser or your computer’s hard drive. A cookie typically contains the name of the domain (internet location) from which the cookie originated, the “lifetime” of the cookie (i.e., when it expires), and a randomly generated unique number or similar identifier. A cookie may also contain information about your computer, such as settings, browsing history, and activities conducted while using our Services.

Carnegie also uses “pixels” (also known as web beacons). Pixels are transparent images that are used in collecting information about website usage across websites and over time.

Cookies that Carnegie sets are called first-party cookies. Cookies set by any other party are called third-party cookies. Third-party cookies enable third-party features or functionality on or through our Services, such as analytics, marketing automation, and customer support. The parties that set third-party cookies can recognize your computer both when it visits the Services and also when it visits certain other websites and online services. Please visit the privacy policy of the applicable third party for privacy terms regarding third-party cookies.

Most browsers accept cookies automatically but allow you to disable them. You also can opt out of certain cookies using the following link: http://optout.networkadvertising.org/?c=1. You can reset your browser to refuse all cookies or to indicate when a cookie is being sent. Some features of our Services may not work properly without cookies. To learn more about cookies generally, visit www.allaboutcookies.org and http://optout.aboutads.info/?c=2&lang=EN.

Some web browsers incorporate a “Do Not Track” (“DNT”) or similar feature that signals to websites that a user does not want to have his or her online activity and behavior tracked. If a website that responds to a particular DNT signal receives the DNT signal, the browser can block that website from collecting certain information about the browser’s user. The Services respond to DNT signals, and by default, the Services do not track.

Why does Carnegie use cookies and other tracking technology?

Some cookies are required for our Services to operate. Other cookies enable us to track the interests of users to enhance the experience of our Services.

The types of cookies served on our Services and why they are used is as follows:

• “Strictly necessary” cookies are required to allow us to deliver our Services to you.
• “Performance” or “Analytics” cookies help us collect information about how visitors use our Services and help us analyze and improve them. Performance or analytics cookies remain on your computer after you close your browser until you delete them.
• “Advertising” cookies are used to make advertising messages more relevant to you. They help display advertisements that are based on your inferred interests, prevent the same ad from appearing too often, and ensure that ads are properly displayed for advertisers.

Pixels and similar data collection technology enable Carnegie to monitor the traffic patterns of visitors from one web page to another, to deliver or communicate with cookies, to understand whether you visit our Services after seeing our online advertisement displayed on a third-party website, to improve performance of our Services, and to measure the success of our email marketing campaigns.

We also use Google Analytics (including Double Click) on our Services. Google Analytics provides us with demographic-type data about users, such as age and gender. Google uses a cookie that Google recognizes when you visit other websites.

Google’s cookies help us analyze how our Services are used. The information generated by the cookie about use of our Services (such as your IP address) is transmitted to and stored by Google on servers in the United States. On behalf of Carnegie, Google will use this information to evaluate use of our Services and compile reports for us and third parties that help operate and provide services related to Carnegie. Google will not associate your IP address with any other data held by Google.

For more information about how Google collects, uses, and shares your information, please visit https://www.google.com/policies/privacy/partners/ or Google’s Privacy Policy. Google has developed an opt-out browser add-on; if you want to opt out of Google Analytics, you can download and install the add-on for your web browser. You may refuse the use of these cookies by selecting the appropriate settings on your browser.

HOW CARNEGIE PROTECTS PERSONAL INFORMATION

We use technical, physical, and administrative safeguards intended to protect the personal information that we collect from and about you. Our safeguards are designed to provide a level of security appropriate to the risk of processing your personal information and include (as applicable) measures to ensure the ongoing confidentiality, integrity, availability, and resilience of processing systems and a procedure for regularly testing, assessing, and evaluating the effectiveness of technical and organizational measures for ensuring the security of the processing of personal information.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to the Services. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Services.

You are responsible for maintaining the security of your account credentials. Carnegie will treat access to our Services through your account credentials as authorized by you. We may suspend your use of all or part of our Services without notice if we suspect or detect any breach of security. If you believe that information you provided to us is no longer secure, please notify us immediately at privacy@carnegiehighered.com.

If we become aware of a breach that affects the security of your personal information, we will provide you (or the client, if applicable) with notice as required by applicable law. When permitted by applicable law, Carnegie will provide this notice to you through the email address associated with your Carnegie account.

UNAUTHORIZED ACCESS TO OUR SERVICES – INCLUDING SCRAPING – IS PROHIBITED.

HOW CARNEGIE RETAINS PERSONAL INFORMATION

We retain personal information for as long as we have a legitimate business need, such as for the duration of our contract with you or to comply with applicable legal, tax, or accounting requirements.

When we no longer have a legitimate business need to process your personal information, we follow our data retention policy and either delete or anonymize your personal information. If we cannot delete or anonymize your personal information, then we will securely store your personal information until deletion or anonymization is possible.

Once we anonymize your personal information, it is no longer personal information. We use anonymized data subject to applicable law.

For more information, please contact us as provided below.

CHILDREN’S PRIVACY

Carnegie does not knowingly collect personal information from children under age 13. Consistent with the requirements of applicable law, if we learn that a child under age 13 has provided us with personal information, we will use that information only to respond directly to that child (or his or her parent or legal guardian) to inform the child that he or she cannot use our Services and subsequently will delete that information. If you believe we might have any information from or about a child under age 13, please contact us as provided below.

YOUR PRIVACY RIGHTS AND CHOICES

We strive to provide you with choices regarding the personal information you provide to us. You can take advantage of the following mechanisms to provide you with control over your information:

• Accessing, Correcting, and Updating Your Information. You can review, change, and remove some of your personal information by logging into the Services and visiting your account profile page, or you can contact us as provided below.
• Tracking Technologies; Device Permissions. You can set your browser to refuse all or some cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, some parts of the Services may then be inaccessible or not function properly. Mobile devices offer permission settings for specific types of device data and notifications, such as phone contacts, pictures, location, and push notifications. You can change your settings on your device to either consent to or refuse the collection or processing of the corresponding information or the display of the corresponding notifications. If you disable or refuse certain permissions, the Services may then be inaccessible or not function properly.
• Promotional Offers. If you do not wish to have your contact information used by Carnegie to promote our own or third parties’ products or services, you can opt-out by unsubscribing from any emails you receive from us. Additionally, you can always opt out by contacting us using the information provided below. If we have sent you a promotional communication, you may send us a return communication asking to be omitted from future email distributions. This opt-out does not apply to information provided to Carnegie as a result of a product purchase or other transactions with respect to which we may need to communicate with you.
• Disclosure of Your Information for Third-Party Advertising and Marketing. If you do not want us to share your personal information with unaffiliated or non-agent third parties for advertising and marketing purposes, you can opt-out here by contacting us as provided below.
• Google Analytics. To learn more about Google Analytics, including how to opt out of it, visit https://tools.google.com/dlpage/gaoptout.

We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website, https://thenai.org/opt-out. Similarly, you can opt out of receiving targeted ads from members of the Digital Advertising Alliance (“DAA”) on the DAA’s website, https://www.privacyrights.info.

YOUR STATE PRIVACY RIGHTS

Certain state consumer privacy laws may provide their residents with additional rights regarding our use of their personal information. Presently, California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia provide (now or in the future) their state residents with rights to:

• Confirm whether we process their personal information, access their personal information, and obtain a copy of their personal information.
• Delete certain personal information.
• Correct inaccuracies in their personal information, taking into account the nature of the personal information and the purposes of the processing of the personal information.
• Opt out of personal information processing for targeted advertising, sales, or profiling in furtherance of decisions that produce legal or similarly significant effects; however, we do not we do not sell or share personal information that we obtain from users of CollegeXpress or similar services that link to this Privacy
• Policy, and we do not conduct profiling in furtherance of decisions that produce legal or similarly significant effects.
• Either limit (opt-out of) or require consent to process sensitive personal data.

The exact scope of these rights may vary by state. To exercise any of your rights, please submit a privacy rights request through our Personal Information Request Form here or contact us as provided below. Additionally, you can access, correct, and delete some of your personal information by logging into the Services on the applicable website and visiting your account profile page(s).

We may deny a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect, and we may retain copies of your personal information to the extent required by applicable law.

You may use an authorized agent to submit a request on your behalf. An authorized agent must have your signed permission to submit a request on your behalf or provide proof that they have power of attorney in accordance with applicable law. Before completing requests from authorized agents, we may contact you directly to confirm you’ve given your permission and/or to verify your identity. Authorized agents may submit requests by contacting us as provided below.

If you request access to, or the correction or deletion of, your personal information, we will verify your identity before disclosing the requested information. To do so, we may ask that you log into your account or provide us with your name, address, email address, and/or phone number. When you make a request, you may be asked to answer a few questions about yourself to help us verify your identity. In the event more documentation is necessary to verify your identity, we will notify you directly.

If you are unsatisfied with our actions related to the exercise of one of your privacy rights above, you may appeal our decision by contacting us using the information provided below. If you are unsatisfied with the results of your appeal, you may contact the Attorney General or other responsible department of your state.

We will not discriminate against you for exercising your rights. We will not deny you goods or services, charge different prices or rates, provide a different level of service or quality of goods, or suggest that you might receive a different price or level of quality for goods. Some programs or membership services require usage of personal information to function, so compliance with your request may impact those experiences.

If you are a California resident, please see our California Privacy Rights Notice. The California Privacy Rights Notice explains your privacy rights, how and why we collect and process your personal information, and how you can exercise your rights.

If you are located in the European Economic Area, Switzerland, or the United Kingdom, please see our Privacy Rights Notice for Individuals Located in EEA for more information about your rights and how to exercise them.

Nevada provides its residents with a limited right to opt-out of certain personal information sales. We do not currently sell any information or otherwise trigger Nevada’s opt-out requirements. Nevertheless, any Nevada resident who wishes to exercise this sale opt-out right proactively may contact us at privacy@carnegiehighered.com. Please include “Nevada” in your email subject line and include the following information in your email: (i) your name, (ii) Nevada resident address, and (iii) email address.

IF YOU ARE LOCATED IN A JURISDICTION WITH DATA PROTECTION LAWS THAT OFFER YOU PRIVACY RIGHTS NOT DESCRIBED IN THIS PRIVACY POLICY, PLEASE CONTACT US AS PROVIDED BELOW. We respect your privacy rights and will do our best to accommodate your requests.

UPDATES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time in response to changing legal, technical, or business developments. When we update our Privacy Policy, we will post the updated version and change the Last Updated date above. When there are material changes, we will also take appropriate measures to attempt to inform you in advance so that you have an opportunity to review the revised Privacy Policy. If your consent is required by applicable law, we will obtain your consent to changes before the revised Privacy Policy applies to you.

HOW TO CONTACT US

If you have questions about this Privacy Policy or how we handle your personal information, please contact us:

• By mail at Carnegie Dartlet LLC, Attn: Privacy and Legal, 210 Littleton Road, Suite 100, Westford, MA 01886;
• By filling in the contact form at https://www.collegexpress.com/contact;
• By email at privacy@carnegiehighered.com; or
• By phone at 978-692-509 or toll free at 888-562-4440