Choices 360 Professional Center Privacy Statement

Last Updated: June 28, 2017

XAP Corporation including its subsidiary Bridges Transitions Inc. (collectively, "XAP") (the company that operates this Choices 360 Professional Center website) has adopted the following Privacy Statement for the information collected at the Choices 360 Professional Center website (referred to hereafter as the "Professional Center"). This Professional Center is operated for educators, counselors, and administrators. When you use this Professional Center, XAP has access to your information and may use your information to operate and maintain this Professional Center and in accordance with the terms of this Privacy Statement.

As the Professional Center 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
  • 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 this Professional Center, you signify and affirm that you have read, understand, and agree to the terms of this Statement; that you are at least eighteen (18) years old; 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 the Professional Center), 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 the Professional Center.

TYPES OF INFORMATION COLLECTED

This Statement covers information you expressly enter into the Professional Center and information that we automatically collect as you use the Professional Center.

THE PERSONALLY IDENTIFYING INFORMATION WE COLLECT

To use certain features of the Professional Center, 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 the Professional Center. 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 the Professional Center may collect from you include your name, address, email address, phone number, username and password, school affiliation, user preferences, and such additional information as you choose to actively enter into the Professional Center.

AUTOMATICALLY-COLLECTED INFORMATION

When you use the Professional Center, we may automatically track, collect, and store the following types of information (referred to as "Automatically-Collected Information"): 1) Date and time you access the Professional Center; 2) pages visited and features used, and the order of use; 3) type of computer or other operating device accessing the Professional Center and type of browser used to access the Professional Center; and 4) other similar information about the interaction between your browser and the Professional Center and activities in which you engage while using the Professional Center. Unless otherwise stated in this Statement, Automatically-Collected Information may be combined with your PII.

When you visit the Professional Center, 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 accounts on the Professional Center in order to confirm the applicable user’s identity.

REASONS WE COLLECT YOUR PERSONALLY IDENTIFYING INFORMATION

The Professional Center collects PII from you to set up your user account; to perform a task on the Professional Center, as requested by you; to enable XAP to respond to your questions or contact you when necessary in connection with the functioning of the Professional Center or to provide required notices; and for any other reason indicated when PII is collected on the Professional Center.

WAYS IN WHICH PERSONALLY IDENTIFYING INFORMATION AND AUTOMATICALLY-COLLECTED INFORMATION MAY BE USED

We may use your PII and Automatically-Collected Information to help diagnose problems with the Professional Center and to administer the Professional Center. We may use your PII and Automatically-Collected Information to customize and tailor your experience using the Professional Center, displaying content that we think you might be interested in and according to your preferences.

We may use your PII and Automatically-Collected Information as described elsewhere in this Privacy Statement.

WITH WHOM PERSONALLY IDENTIFYING INFORMATION AND AUTOMATICALLY-COLLECTED INFORMATION MAY BE SHARED

Except as set forth below, PII you enter on the Professional Center 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 entered through the Professional Center to any company, individual, or organization for its use in marketing or commercial solicitation or for any other purpose, except with your express consent or at your direction, unless it is pursuant to one of the exceptions listed below or necessary for operation of the Professional Center.

We may share your PII and Automatically-Collected Information as follows:

  1. School/Organization Administration. Staff at your school/organization who have administrative accounts on the Professional Center will be able to review your PII associated with your account and the activities in which you’ve engaged while using the Professional Center.

  2. 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 the Professional Center and for use in accordance with this Statement.

  3. 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 the recipient(s) you designate. For example, if you send an email to a student through the Professional Center, any PII associated with and included in your message will be provided to the student.

  4. 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 Professional Center 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.

  5. 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, through your account, or by posting a prominent notice on the Professional Center). Unless you consent otherwise, XAP will contractually require any successor to treat your previously-submitted 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.

  6. Third-Party Service Providers. We may share Automatically-Collected Information with our third-party service providers (or allow these service providers to collect Automatically-Collected Information on our behalf). These third-party service providers assist us by performing services related to our operation of the Professional Center (such as hosting, data storage, security, and analytics services).

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, the Professional Center encrypts the PII you enter when it is in route from your browser to the Professional Center 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. The Professional Center 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 Professional Center 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 those employees of XAP who require such access to administer and maintain the Professional Center or to provide requested customer support to users of the Professional Center. Each XAP employee who has access to the PII residing on the Professional Center server has agreed in writing to respect the privacy of all such PII. XAP trains employees to protect user information and only authorizes access to 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 nonpublic 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 other operating device’s hard drive. The Professional Center uses cookies to remember you and personalize your web-viewing experience by keeping track of your session when using the Professional Center. Cookies enable you to maintain continuity as you move from page to page on the Professional Center 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 Professional Center features used and activities conducted while using the Professional Center. We may use cookies to aggregate data about user traffic on and user interaction with the Professional Center 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 the Professional Center and are erased when you end your session on the Professional Center or completely close your browser. The cookies we use do not remain on your hard drive after you end your session on the Professional Center or completely close your browser.

Third-Party Cookies

We use third-party services provided by Google Analytics to track and analyze your Professional Center activity. In order to gather this Automatically-Collected Information, we use a Google Analytics cookie on Professional Center. 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/

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 Professional Center services and features will not function properly when cookies are not utilized.

LINKS

The Professional Center hosts links to other sites or resources, and you may link to one of those sites or resources for a variety of purposes. These sites and resources have privacy statements that may differ from that of the Professional Center, and for your protection, we recommend that you read and understand the privacy statement 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 the Professional Center 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 the Professional Center the PII you previously provided. To modify PII: (i) Sign in to the Professional Center, (ii) access your account, (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 note that if you modify or delete any PII, we may retain the earlier-submitted PII, as descried in the Section below entitled "Retention and Storage."

Finally, note that the school with which you are affiliated may, at any time, request that XAP suspend or inactivate your account permanently. XAP will comply with any such request made by the school with which you are affiliated. If you dispute the suspension or account inactivation, you must address that with the school with which you are affiliated, as applicable.

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 the Professional Center is intended to help you assist students to set goals and plan for their future educations and career paths, the PII you put into the Professional Center will be retained until you ask us to remove your information or until the school with which you are affiliated asks us to remove your PII or inactivate your account (such as if your employment is terminated for any reason). Note that even after you ask that we remove your information from our databases or even after the school with which you are affiliated asks us to remove your PII or inactivate your account, 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 for use in the aggregate and to analyze and improve the Professional Center. Further, 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 periodically. We will post any new Privacy 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 the Professional Center 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 Professional Center 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 the next time you log into your account on the Professional Center. Once posted to the Professional Center, the new Privacy Statement will apply to all data previously submitted and subsequently submitted to the Professional Center, 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.

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