User Agreement & Policies.

1. Introduction

Our goal is to help you search, find and connect with colleges, universities and trade schools. We do so by sharing content and information based on your preferences.

Below you will see:

• What we expect from you, which establishes certain rules for using our services
• What you can expect from us, which describes how we provide and develop our services

1.1 Contract

When you use our Services you agree to all of these terms. Your use of our Services is also subject to our Cookie Policy and Privacy Policy which covers how we collect, use, share, and store your personal information.

You agree that by clicking “Join Now”, “Join SpringPath”, “Sign Up” or similar, registering, accessing or using our services (described below), you are agreeing to enter into a legally binding contract with SpringPath (even if you are using our Services on behalf of a company). If you do not agree to this contract (“Contract” or “User Agreement”), do not click “Join Now” (or similar) and do not access or otherwise use any of our Services. If you wish to terminate this contract, at any time you can do so by closing your account and no longer accessing or using our Services.

Services

This Contract applies to SpringPath.net, SpringPath-branded apps, and other SpringPath-related sites, apps, communications and other services that state that they are offered under this Contract (“Services”). Registered users of our Services are “Users” and unregistered users are “Guests”.

SpringPath

You are entering into this Contract with SpringPath (also referred to as “we” and “us”).

This Contract applies to Users and Guests.

As a User or Guest of our Services, the collection, use and sharing of your personal data is subject to this Privacy Policy (which includes our Cookie Policy and other documents referenced in this Privacy Policy) and updates.

1.2 Users and Guests

When you register and join the SpringPath Service, you become a User. If you have chosen not to register for our Services, you may access certain features as a “Guest.”

1.3 Change

We may make changes to the Contract.

We may modify this Contract and our Privacy Policy from time to time. If we make material changes to it, we will provide you notice through our Services, or by other means, to provide you the opportunity to review the changes before they become effective. We agree that changes cannot be retroactive. If you object to any changes, you may close your account. Your continued use of our Services after we publish or send a notice about our changes to these terms means that you are consenting to the updated terms as of their effective date.

2. Obligations

What we expect from you

2.1 Service Eligibility

You’re eligible to enter into this Contract and you are at least our “Minimum Age.” The Services are not for use by anyone under the age of 18 without parental consent granted. Anyone ages 13-17 may be eligible to use our service with parental consent granted.

To use the Services, you agree that: (1) you must be the “Minimum Age” with parental consent (age 13) or without parental consent (age 18) as described above or older; (2) you will only have one SpringPath account, which must be in your real name; and (3) you are not already restricted by SpringPath from using the Services. Creating an account with false information is a violation of our terms, including accounts registered on behalf of others or persons under the age of 18.

“Minimum Age” with parental consent means age 13 and without parental consent means age 18. However, if law requires that you must be older in order for SpringPath to lawfully provide the Services to you without parental consent (including using your personal data) then the Minimum Age is such older age.

2.2 Your Account

You will keep your password a secret.

You will not share an account with anyone else and will follow our rules and the law.

Users are account holders. You agree to: (1) use a strong password and keep it confidential; (2) not transfer any part of your account and (3) follow the law and Professional Policies. You are responsible for anything that happens through your account unless you close it or report misuse.

2.3 Notices and Messages

You’re okay with us providing notices and messages to you through our websites, apps, and contact information. If your contact information is out of date, you may miss out on important notices.

You agree that we will provide notices and messages to you in the following ways: (1) within the Service, or (2) sent to the contact information you provided us (e.g., email, mobile number, physical address). You agree to keep your contact information up to date.

Please review your settings to control messages you receive from us.

2.4 Sharing

When you share information on our Services, others can see, copy and use that information.

Our Services allow messaging and sharing of information in many ways, such as your profile, podcast episodes, articles, group posts, links to news articles, job postings, and messages. Information and content that you share or post may be seen by others (including 3rd party services, e.g., Colleges or Career School Admissions). Where we have made settings available, we will honor the choices you make about who can see content or information (e.g., your user account and SpringPath profile information.) For college and career searching activities, we default to not notifying the public. So, if you opt to signal that you are interested in a college or career school, our default is to share it only with the college or career school poster.

We are not obligated to publish any information or content on our Service and can remove it with or without notice.

3. Rights and Limits

What you can expect from us:

3.1. Your License to SpringPath

You own all of the content, feedback and personal information you provide to us, but you also grant us a non-exclusive license to it.

We’ll honor the choices you make about who gets to see your information and content, including how it can be used for ads or content promotion.

As between you and SpringPath, you own the content and information that you submit or post to the Services, and you are only granting SpringPath and our affiliates the following non-exclusive license:

A worldwide, transferable and sublicensable right to use, copy, modify, distribute, publish and process, information and content that you provide through our Services and the services of others, without any further consent, notice and/or compensation to you or others. These rights are limited in the following ways:

• You can end this license for specific content by deleting such content from the Services, or generally by closing your account, except (a) to the extent you shared it with others as part of the Service and they copied, re-shared it or stored it and (b) for the reasonable time it takes to remove from backup and other systems.
• We will not include your content in advertisements for the products and services of third parties to others without your separate consent (including sponsored content). However, we have the right, without payment to you or others, to serve ads near your content and information, and your social actions may be visible and included with ads, as noted in the Privacy Policy. If you use a Service feature, we may mention that with your name or photo to promote that feature within our Services, subject to your settings.
• We will get your consent if we want to give others the right to publish your content beyond the Services. However, if you choose to share your post as public, we will enable a feature that allows other Members to embed that public post onto third-party services, and we enable search engines to make that public content findable though their services.
• While we may edit and make format changes to your content (such as translating or transcribing it, modifying the size, layout or file type or removing metadata), we will not modify the meaning of your expression.
• Because you own your content and information and we only have non-exclusive rights to it, you may choose to make it available to others.

You and SpringPath agree that if content includes personal data, it is subject to our Privacy Policy.

You and SpringPath agree that we may access, store, process and use any information and personal data that you provide in accordance with, the terms of the Privacy Policy and your choices (including settings).

By submitting suggestions or other feedback regarding our Services to SpringPath, you agree that SpringPath can use and share (but does not have to) such feedback for any purpose without compensation to you.

You promise to only provide information and content that you have the right to share, and that your SpringPath profile will be truthful. You agree to only provide content or information that does not violate the law nor anyone’s rights (including intellectual property rights). You also agree that your profile information will be truthful. SpringPath may be required by law to remove certain information or content in certain countries.

3.2 Service Availability

We may change or end any Service or modify our prices prospectively.

We may change, suspend or discontinue any of our Services. We may also modify our prices effective prospectively upon reasonable notice to the extent allowed under the law.

We don’t promise to store or keep showing any information and content that you’ve posted. SpringPath is not a storage service. You agree that we have no obligation to store, maintain or provide you a copy of any content or information that you or others provide, except to the extent required by applicable law and as noted in our Privacy Policy.

3.3 Other Content, Sites and Apps

Your use of others’ content and information posted on our Services, is at your own risk.

Others may offer their own products and services through our Services, and we aren’t responsible for those third-party activities.

By using the Services, you may encounter content or information that might be inaccurate, incomplete, delayed, misleading, illegal, offensive or otherwise harmful. SpringPath generally does not review content provided by our Users or others. You agree that we are not responsible for others’ (including other Users) content or information. We cannot always prevent this misuse of our Services, and you agree that we are not responsible for any such misuse. You also acknowledge the risk that you or your organization may be mistakenly associated with content about others when we let connections and followers know you or your organization were mentioned in the news.

SpringPath may help connect Colleges & Career Schools offering their services (career coaching, career services, college or job placement, etc.) with users seeking services. SpringPath does not perform nor employs individuals to perform these services. You must be at least 18 years of age to offer, perform or procure these services. You acknowledge that SpringPath does not supervise, direct, control or monitor users in the performance of these services and agree that (1) SpringPath is not responsible for the offering, performance or procurement of these services, (2) SpringPath does not endorse any particular user’s offered services, and (3) nothing shall create an employment, agency, or joint venture relationship between SpringPath and any user offering services. If you are a user offering services, you represent and warrant that you have all the required licenses and will provide services consistent with our User Agreement, Privacy Policy and Advertising Agreement.

Similarly, SpringPath may help you register for and/or attend events organized by users and connect with other users who are attendees at such events. You agree that (1) SpringPath is not responsible for the conduct of any of the users or other attendees at such events, (2) SpringPath does not endorse any particular event listed on our Services, (3) SpringPath does not review and/or vet any of these events, and (4) that you will adhere to these terms and conditions that apply to such events.

3.4 Limits

We have the right to limit how you connect and interact on our Services.

SpringPath reserves the right to limit your use of the Services, including the number of your connections and your ability to contact other users. SpringPath reserves the right to restrict, suspend, or terminate your account if you breach this Contract or the law or are misusing the Services (e.g., violating any of the Dos and Don’ts or Policies)

3.5 Intellectual Property Rights

We’re providing you notice about our intellectual property rights.

SpringPath reserves all of its intellectual property rights in the Services. Trademarks and logos used in connection with the Services are the trademarks of their respective owners. SpringPath, and “in” logos and other SpringPath trademarks, service marks, graphics and logos used for our Services are trademarks or registered trademarks of SpringPath.

3.6 Automated Processing

We use data and information about you to make relevant suggestions to you and others.

We use the information and data that you provide and that we have about Members to make recommendations for connections, content and features that may be useful to you. For example, we use data and information about you to recommend podcast content to you and you to admissions recruiters. Keeping your profile accurate and up to date helps us to make these recommendations more accurate and relevant.

4. Disclaimer and Limit of Liability

4.1 No Warranty

This is our disclaimer of legal liability for the quality, safety, or reliability of our Services.

SPRINGPATH AND ITS AFFILIATES MAKE NO REPRESENTATION OR WARRANTY ABOUT THE SERVICES, INCLUDING ANY REPRESENTATION THAT THE SERVICES WILL BE UNINTERRUPTED OR ERROR-FREE, AND PROVIDE THE SERVICES (INCLUDING CONTENT AND INFORMATION) ON AN “AS IS” AND “AS AVAILABLE” BASIS. TO THE FULLEST EXTENT PERMITTED UNDER APPLICABLE LAW, SPRINGPATH AND ITS AFFILIATES DISCLAIM ANY IMPLIED OR STATUTORY WARRANTY, INCLUDING ANY IMPLIED WARRANTY OF TITLE, ACCURACY OF DATA, NON-INFRINGEMENT, MERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE.

4.2 Exclusion of Liability

These are the limits of legal liability we may have to you.

TO THE FULLEST EXTENT PERMITTED BY LAW (AND UNLESS SPRINGPATH HAS ENTERED INTO A SEPARATE WRITTEN AGREEMENT THAT OVERRIDES THIS CONTRACT), SPRINGPATH, INCLUDING ITS AFFILIATES, WILL NOT BE LIABLE IN CONNECTION WITH THIS CONTRACT FOR LOST PROFITS OR LOST BUSINESS OPPORTUNITIES, REPUTATION (E.G., OFFENSIVE OR DEFAMATORY STATEMENTS), LOSS OF DATA (E.G., DOWN TIME OR LOSS, USE OF, OR CHANGES TO, YOUR INFORMATION OR CONTENT) OR ANY INDIRECT, INCIDENTAL, CONSEQUENTIAL, SPECIAL OR PUNITIVE DAMAGES.

SPRINGPATH AND ITS AFFILIATES WILL NOT BE LIABLE TO YOU IN CONNECTION WITH THIS CONTRACT FOR ANY AMOUNT THAT EXCEEDS (A) THE TOTAL FEES PAID OR PAYABLE BY YOU TO SPRINGPATH FOR THE SERVICES DURING THE TERM OF THIS CONTRACT, IF ANY, OR (B) US $1000.

4.3 Basis of the Bargain; Exclusions

The limitations of liability in this Section 4 are part of the basis of the bargain between you and SpringPath and shall apply to all claims of liability (e.g., warranty, tort, negligence, contract and law) even if SpringPath or its affiliates has been told of the possibility of any such damage, and even if these remedies fail their essential purpose.

These limitations of liability do not apply to liability for death or personal injury or for fraud, gross negligence or intentional misconduct, or in cases of negligence where a material obligation has been breached, a material obligation being such which forms a prerequisite to our delivery of services and on which you may reasonably rely, but only to the extent that the damages were directly caused by the breach and were foreseeable upon conclusion of this Contract and to the extent that they are typical in the context of this Contract.

5. Termination

We can each end this Contract, but some rights and obligations survive.

Both you and SpringPath may terminate this Contract at any time with notice to the other. On termination, you lose the right to access or use the Services. The following shall survive termination:

• Our rights to use and disclose your feedback;
• Users and/or Visitors’ rights to further re-share content and information you shared through the Services;
• Sections 4, 6, 7, and 8.2 of this Contract;

6. Governing Law and Dispute Resolution

In the unlikely event we end up in a legal dispute, you and SpringPath agree to resolve it in New York courts using New York law.

For others outside of Designated Countries, including those who live outside of the United States: You and SpringPath agree that the laws of the State of New York, U.S.A., excluding its conflict of laws rules, shall exclusively govern any dispute relating to this Contract and/or the Services. You and SpringPath both agree that all claims and disputes can be litigated only in the federal or state courts in New York, USA, and you and SpringPath each agree to personal jurisdiction in those courts.

7. General Terms

Here are some important details about the Contract.

If a court with authority over this Contract finds any part of it unenforceable, you and we agree that the court should modify the terms to make that part enforceable while still achieving its intent. If the court cannot do that, you and we agree to ask the court to remove that unenforceable part and still enforce the rest of this Contract.

This Contract (including additional terms that may be provided by us when you engage with a feature of the Services) is the only agreement between us regarding the Services and supersedes all prior agreements for the Services.

If we don’t act to enforce a breach of this Contract, that does not mean that SpringPath has waived its right to enforce this Contract. You may not assign or transfer this Contract (or your membership or use of Services) to anyone without our consent. However, you agree that SpringPath may assign this Contract to its affiliates or a party that buys it without your consent. There are no third-party beneficiaries to this Contract.

You agree that the only way to provide us legal notice is at the addresses provided in Section 10.

8. SpringPath “Dos and Don’ts”

8.1. Dos

SpringPath is a community of professionals. This list of “Dos and Don’ts” along with our Privacy Policy and Advertising Agreement limit what you can and cannot do on our Services.

You agree that you will:

• Comply with all applicable laws, including, without limitation, privacy laws, intellectual property laws, anti-spam laws, export control laws, tax laws, and regulatory requirements;
• Provide accurate information to us and keep it updated;
• Use your real name on your profile; and
• Use the Services in a professional manner.

8.2. Don’ts

You agree that you will not:

• Create a false identity on SpringPath, misrepresent your identity, create a Member profile for anyone other than yourself (a real person), or use or attempt to use another’s account;
• Develop, support or use software, devices, scripts, robots or any other means or processes (including crawlers, browser plugins and add-ons or any other technology) to scrape the Services or otherwise copy profiles and other data from the Services;
• Override any security feature or bypass or circumvent any access controls or use limits of the Service (such as caps on keyword searches or profile views);
• Copy, use, disclose or distribute any information obtained from the Services, whether directly or through third parties (such as search engines), without the consent of SpringPath;
• Disclose information that you do not have the consent to disclose (such as confidential information of others (including your employer));
• Violate the intellectual property rights of others, including copyrights, patents, trademarks, trade secrets or other proprietary rights. For example, do not copy or distribute (except through the available sharing functionality) the posts or other content of others without their permission, which they may give by posting under a Creative Commons license;
• Violate the intellectual property or other rights of SpringPath, including, without limitation, (i) copying or distributing our learning videos or other materials or (ii) copying or distributing our technology, unless it is released under open source licenses; (iii) using the word “SpringPath” or our logos in any business name, email, or URL except as provided under written consent for usage.
• Post anything that contains software viruses, worms, or any other harmful code;
• Reverse engineer, decompile, disassemble, decipher or otherwise attempt to derive the source code for the Services or any related technology that is not open source;
• Imply or state that you are affiliated with or endorsed by SpringPath without our express consent (e.g., representing yourself as an accredited SpringPath trainer);
• Rent, lease, loan, trade, sell/re-sell or otherwise monetize the Services or related data or access to the same, without SpringPath’s consent;
• Deep-link to our Services for any purpose other than to promote your profile or a Group on our Services, without SpringPath’s consent;
• Use bots or other automated methods to access the Services, add or download contacts, send or redirect messages;
• Monitor the Services’ availability, performance or functionality for any competitive purpose;
• Engage in “framing,” “mirroring,” or otherwise simulating the appearance or function of the Services;
• Overlay or otherwise modify the Services or their appearance (such as by inserting elements into the Services or removing, covering, or obscuring an advertisement included on the Services);
• Interfere with the operation of, or place an unreasonable load on, the Services (e.g., spam, denial of service attack, viruses, gaming algorithms); and/or
• Violate the Privacy Policy or any additional terms concerning a specific Service that are provided when you sign up for or start using such Service where applicable.

9. Complaints Regarding Content

Contact information for complaint about content provided by our Members.

We respect the intellectual property rights of others. We require that information posted by Members be accurate and not in violation of the intellectual property rights or other rights of third parties. We provide an email support@springpath.net for complaints concerning content posted by our users.

10. How To Contact Us

For general inquiries, you may contact us online or sales@springpath.net. For legal notices or service of process, you may write us at 1185 New Litchfield Street, Torrington, CT 06790.

Cookie Policy

This Cookie Policy applies to any SpringPath product or service that links to this policy or incorporates it by reference. We use cookies and similar technologies such as pixels, local storage and mobile ad IDs (collectively referred to in this policy as “cookies”) to collect and use data as part of our Services, as defined in our Privacy Policy (“Services”).

What technologies are used?

Please note that these tables may be updated from time to time to provide you with the latest information.

What are these technologies used for?

Below we describe the ways in which we may use cookies.

What third parties use these technologies in connection with our Services?

Third parties such as our customers, partners and service providers may use cookies in connection with our Services.

For example, third parties may use cookies in their SpringPath pages, internship posts and their advertisements on and off SpringPath for their own marketing purposes.

Third parties may also use cookies in connection with our off-site Services, such as SpringPath ad services. Third parties may use cookies to help us to provide our Services. We may also work with third parties for our own marketing purposes and to enable us to analyze and research our Services.

Your Choices

You have choices on how SpringPath uses cookies. Please note that if you limit the ability of SpringPath to use cookies, you may worsen your overall user experience, since it may no longer be as personalized to you. It may also stop you from saving customized settings like login information.

Targeted Advertising

Some mobile device operating systems such as Android and iOS provide the ability to control the use of mobile advertising IDs for ads personalization. You can learn how to use these controls by visiting the manufacturer’s website for both Android and iOS.

Browser Controls

Most browsers allow you to control cookies through their settings, which may be adapted to reflect your consent to the use of cookies. Further, most browsers also enable you to review and erase cookies, including SpringPath cookies. To learn more about browser controls, please consult the documentation that your browser manufacturer provides.

Manage Cookie Preferences

Where required, we enable you to reject the use of certain cookies for purposes such as advertising and analytics and research, by visiting your cookie settings, without affecting the lawfulness of processing based on your consent before its withdrawal.

What is Do Not Track (DNT)?

DNT is a concept that has been promoted by regulatory agencies such as the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing Internet users to control the tracking of their online activities across websites by using browser settings. As such, SpringPath does not generally respond to “do not track” signals.

Privacy Policy

Introduction

We are a College & Career Network and online platform for students and professionals. People use our Services to find and be found for school and internship opportunities, to connect with others and find information. Our Privacy Policy applies to any User or Guest to our Services.

Our registered users (“Users”) share their student or professional identities, engage with their network, exchange knowledge and professional insights, post and view relevant content, learn and develop skills, and find school and career opportunities. Content and data on some of our Services is viewable to non-users (“Guests”).

Services

This Privacy Policy, including our cookie policy applies to your use of our Services.

This Privacy Policy applies to SpringPath.net, SpringPath-branded apps and other SpringPath-related sites, apps, communications and services (“Services”), including off-site Services, such as our ad services and SpringPath plugins, but excluding services that state that they are offered under a different privacy policy. For California residents, additional disclosures required by California law may be found in our CCPA Policy.

Data Controllers and Contracting Parties

SpringPath Corporation will be the controller of your personal data provided to, or collected by or for, or processed in connection with, our Services.

As a Guest or User of our Services, the collection, use and sharing of your personal data is subject to this Privacy Policy and other documents referenced in this Privacy Policy, as well as updates.

Change

Changes to the Privacy Policy apply to your use of our Services after the “effective date.”

SpringPath (“we” or “us”) can modify this Privacy Policy, and if we make material changes to it, we will provide notice through our Services, or by other means, to provide you the opportunity to review the changes before they become effective. If you object to any changes, you may close your account.

You acknowledge that your continued use of our Services after we publish or send a notice about our changes to this Privacy Policy means that the collection, use and sharing of your personal data is subject to the updated Privacy Policy, as of its effective date.

1. Data We Collect

1.1 Data You Provide To Us

You provide data to create an account with us.

Registration

To create an account you need to provide data including your name, email address and/or mobile number, and a password. You create your SpringPath profile (a complete profile helps you get the most from our Services). If you register for a premium Service (e.g., Colleges, Universities and Trade Schools) you will need to provide payment (e.g., credit card) and billing information.

Profile

You have choices about the information on your profile, such as your education, work experience, skills, photo, city or area and endorsements. You don’t have to provide additional information on your profile; however, profile information helps you to get more from our Services, including helping recruiters and school opportunities find you. It’s your choice whether to include sensitive information on your profile and to make that sensitive information public. Please do not post or add personal data to your profile that you would not want to be publicly available.

Posting and Uploading

We collect personal data from you when you provide, post or upload it to our Services, such as when you fill out a form, (e.g., with demographic data or academic data), respond to a survey, or submit an application on our Services. If you opt to import your address book, we receive your contacts (including contact information your service provider(s) or app automatically added to your address book when you communicated with addresses or numbers not already in your list).

If you sync your contacts or calendars with our Services, we will collect your address book and calendar meeting information to keep growing your network by suggesting connections for you and others, and by providing information about events, e.g. times, places, attendees and contacts.

You don’t have to post or upload personal data; though if you don’t, it may limit your ability to grow and engage with your network over our Services.

1.2 Data From Others

Others may post or write about you.

Content and News

You and others may post content that includes information about you (as part of articles, posts, comments, videos) on our Services. Unless you opt-out, we collect public information about you, such as professional-related news and accomplishments (e.g., academic accomplishments, student recognition, conference speakers, projects, etc.) and make it available as part of our Services (e.g. suggestions for your profile, or notifications to others of mentions in the news).

Others may sync their contacts or calendar with our Services.

Contact and Calendar Information

We receive personal data (including contact information) about you when others import or sync their contacts or calendar with our Services, associate their contacts with User profiles, scan and upload info or send messages using our Services (including invites or connection requests). If you or others opt-in to sync email accounts with our Services, we will also collect “email header” information that we can associate with User profiles.

Partners

We receive personal data (e.g., your grade level and email address) about you when you use the services of our customers and partners, such as employers or college recruiters and applicant tracking systems providing us data.

Related Companies and Other Services

We receive data about you when you use some of the other services provided by us or our affiliates.

1.3 Service Use

We log your visits and use of our Services, including mobile apps.

We log usage data when you visit or otherwise use our Services, including our sites, app and platform technology, such as when you view or click on content (e.g., learning video) or ads (on or off our sites and apps), perform a search, install or update one of our mobile apps, share articles or recommend schools. We use log-ins, cookies, device information and internet protocol (“IP”) addresses to identify you and log your use.

1.4 Cookies and Similar Technologies

We collect data through cookies and similar technologies.

As further described in our Cookie Policy, we use cookies and similar technologies (e.g., pixels and ad tags) to collect data (e.g., device IDs) to recognize you and your device(s) on, off and across different services and devices where you have engaged with our Services. We also allow some others to use cookies as described in our Cookie Policy. We also collect (or rely on others who collect) information about your device where you have not engaged with our Services (e.g., ad ID, IP address, operating system and browser information) so we can provide our Users with relevant ads and better understand their effectiveness. You can opt-out from our use of data from cookies and similar technologies that track your behavior on the sites of others for ad targeting and other ad-related purposes.

1.5 Your Device and Location

We receive data from your devices and networks, including location data.

When you visit or leave our Services (including some plugins and our cookies or similar technology on the sites of others), we receive the URL of both the site you came from and the one you go to and the time of your visit. We also get information about your network and device (e.g., IP address, proxy server, operating system, web browser and add-ons, device identifier and features, cookie IDs and/or ISP, or your mobile carrier). If you use our Services from a mobile device, that device will send us data about your location based on your phone settings. We will ask you to opt-in before we use GPS or other tools to identify your precise location.

1.6 Messages

If you communicate through our Services, we learn about that.

We collect information about you when you send, receive, or engage with messages in connection with our Services. For example, if you get a SpringPath connection request, we track whether you have acted on it and will send you reminders. We also use scanning technology on messages to support and protect our site. For example, we use this technology to suggest possible responses to messages and to manage or block content that violates our User Agreement from our Services.

1.7 Sites and Services of Others

We get data when you visit sites that include our ads, cookies or some of our plugins or when you log-in to others’ services with your SpringPath account.

We receive information about your visits and interaction with services provided by others when you log-in with SpringPath or visit others’ services that include some of our plugins or our ads, cookies or similar technologies

1.9 Other

We are improving our Services, which means we get new data and create new ways to use data.

Our Services are dynamic, and we often introduce new features, which may require the collection of new information. If we collect materially different personal data or materially change how we collect, use or share your data, we will notify you and may also modify this Privacy Policy.

2. How We Use Your Data

We use your data to provide, support, personalize and develop our Services.

How we use your personal data will depend on which Services you use, how you use those Services and the choices you make in your settings. We use the data that we have about you to provide and personalize our Services, including with the help of automated systems and inferences we make, so that our Services (including ads) can be more relevant and useful to you and others.

2.1 Services

Our Services help you connect with others, find and be found for post-secondary, work and business opportunities, stay informed, get training and be more productive.

We use your data to authorize access to our Services and honor your settings.

Stay Connected

Our Services allow you to stay in touch and up to date with colleagues, schools, teachers, and other related content. To do so, you can “connect” with the User who you choose, and who also wish to “connect” with you. (e.g., You may elect to “connect” with a college and we will share your contact information with a college admissions contact from that college.)

We use data about you (such as your profile, profiles you have viewed or data provided through partner integrations) to help others find your profile, suggest connections for you and enable you to share your information with colleges, universities and trade schools.

It is your choice whether to invite someone to our Services, send a connection request, or allow another User to become your connection. When you invite someone to connect with you, your invitation will include your network and basic profile information (e.g., name, profile photo, school, region). We will send invitation reminders to the person you invited.

Stay Informed

Our Services allow you to stay informed about news, events and ideas regarding school topics you care about, and from connections you respect. Our Services also allow you to improve your educational skills, or learn new ones. We use the data we have about you (e.g., data you provide, data we collect from your engagement with our Services and inferences we make from the data we have about you), to personalize our Services for you, such as by recommending or ranking relevant content and conversations on our Services. We also use the data we have about you to suggest skills you could add to your profile and skills that you might need to pursue your next opportunity. So, if you let us know that you are interested in a new skill (e.g., by watching a learning video), we will use this information to personalize content in your feed, suggest that you follow certain Users on our site, or suggest related learning content to help you towards that new skill. We use your content, activity and other data, including your name and photo, to provide notices to your network and others. For example, subject to your settings, we may notify others that you have updated your profile, posted content, took a social action, used a feature, made new connections or were mentioned in the news.

Career

Our Services allow you to explore careers, evaluate educational opportunities, and seek out, and be found for, career opportunities. Your profile can be found by those looking to hire (for an internship). We will use your data to recommend schools or mentees, show you and others relevant school contacts (e.g., who works at a school, in an industry, function or location or have certain skills and connections). You can signal that you are interested in changing schools and share information with recruiters. We will use your data to recommend schools to you and you to recruiters. We may use automated systems to provide content and recommendations to help make our Services more relevant to our Users, Guests and customers. Keeping your profile accurate and up-to-date may help you better connect to others and to opportunities through our Services.

Productivity

Our Services allow you to collaborate with colleagues, search for potential school programs, customers, partners and others to connect with. Our Services allow you to communicate and connect with other Users (e.g., Colleges, Universities and Trade Schools)

2.2 Premium Services for Colleges, Universities and Trade Schools

Our premium Services help paying users (e.g., Colleges, Universities and Trade Schools) to search for and connect with Users through our Services, such as searching for and contacting school candidates, internship leads and co-students, manage talent and promote content through social media.

We sell premium Services that provide our customers and subscribers with customized-search functionality and tools (including messaging and activity alerts) as part of our talent, marketing and solutions. Customers can export limited information from your profile, such as name, headline, current school, current grade, and general location, such as to manage leads or talent. We do not provide contact information to customers as part of these premium Services without your consent. Premium Services customers can store information they have about you in our premium Services, such as a work history or contact information or academic history. The data stored about you by these customers is subject to the policies of those customers.

2.3 Communications

We contact you and enable communications between Users. We offer settings to control what messages you receive and how often you receive some types of messages.

We will contact you through email, mobile phone, notices posted on our websites or apps, messages to your SpringPath inbox, and other ways through our Services, including text messages and push notifications. We will send you messages about the availability of our Services, security, or other service-related issues. We also send messages about how to use our Services, network updates, reminders, school suggestions and promotional messages from us and our partners. You may change your communication preferences at any time. Please be aware that you cannot opt out of receiving service messages from us, including security and legal notices.

We also enable communications between you and others through our Services.

2.4 Advertising

We serve you tailored ads both on and off our Services. We offer you choices regarding personalized ads, but you cannot opt-out of seeing other ads.

We target (and measure the performance of) ads to Users, Guests and others both on and off our Services directly or through a variety of partners, using the following data, whether separately or combined:

• Data from advertising technologies on and off our Services, pixels, ad tags, cookies, and device identifiers;
• User-provided information (e.g., profile, contact information, school and industry);
• Data from your use of our Services (e.g., search history, feed, content you read, who you follow or is following you, connections, groups participation, page visits, videos you watch, clicking on an ad, etc.), including as described in Section 1.3;
• Information from advertising partners and vendors
• Information inferred from data described above (e.g., using information from a profile to infer graduation dates to infer age or using first names or pronoun usage to infer gender; using your feed activity to infer your interests; or using device data to recognize you as a User).

We will show you ads called sponsored content which look similar to non-sponsored content, except that they are labeled as advertising (e.g., as “ad” or “sponsored”). If you take a social action (such as like, comment or share) on these ads, your action is associated with your name and viewable by others, including the advertiser. Subject to your settings, if you take a social action on the SpringPath Services, that action may be mentioned with related ads.

Ad Choices

We adhere to self-regulatory info for interest-based advertising and participate in industry opt-outs from such ads. This does not opt you out of receiving advertising; you will continue to get other ads by advertisers not listed with these self-regulatory tools. You can also opt-out specifically from our uses of certain categories of data to show you more relevant ads.

Info to Ad Providers

We do not share your personal data with any third-party advertisers or ad networks except for: (i) hashed IDs or device identifiers, (ii) with your separate permission or (iii) data already visible to any users of the Services (e.g., profile). However, if you view or click on an ad on or off our Services, the ad provider will get a signal that someone visited the page that displayed the ad, and they may, through the use of mechanisms such as cookies, determine it is you. Advertising partners can associate personal data collected by the advertiser directly from you with hashed IDs or device identifiers received from us. In such instances, we seek to contractually require such advertising partners to obtain your explicit, opt-in consent before doing so.

2.5 Marketing

We promote our Services to you and others.

In addition to advertising our Services, we use Users’ data and content for invitations and communications promoting Usership and network growth, engagement and our Services, such as by showing your connections that you have used a feature on our Services.

2.6 Developing Services and Research

We develop our Services and conduct research.

Service Development

We use data, including public feedback, to conduct research and development for our Services in order to provide you and others with a better, more intuitive and personalized experience, drive Usership growth and engagement on our Services, and help connect students to each other and to academic opportunity.

Other Research

We seek to create economic opportunity for Users of the global workforce and to help them be more productive and successful. We use the personal data available to us to research social, economic and workplace trends, such as jobs or internship availability and skills needed for each and policies that help bridge the gap in various industries and geographic areas. In some cases, we work with trusted third parties to perform this research, under controls that are designed to protect your privacy. We publish or allow others to publish economic insights, presented as aggregated data rather than personal data.

Surveys

Polls and surveys are conducted by us and others through our Services. You are not obligated to respond to polls or surveys, and you have choices about the information you provide. You may opt-out of survey invitations.

2.7 Customer Support

We use data to help you and fix problems.

We use data (which can include your communications) to investigate, respond to and resolve complaints and for Service issues (e.g., bugs).

2.8 Insights That Do Not Identify You

We use data to generate insights that do not identify you.

We use your data to produce and share insights that do not identify you. For example, we may use your data to generate statistics about our Users, their background or school, to calculate ad impressions served or clicked on, or to publish Guest demographics for a Service or create demographic workforce insights.

2.9 Security and Investigations

We use data for security, fraud prevention and investigations.

We use your data (including your communications) for security purposes or to prevent or investigate possible fraud or other violations of our User Agreement and/or attempts to harm our Users, Guests or others.

3. How We Share Information

3.1 Our Services

Any data that you include on your profile and any content you post or social action (e.g., likes, follows, comments, shares) you take on our Services will be seen by others, consistent with your settings.

Profile

Your profile is fully visible to customers of our Services (e.g., Colleges, Universities and Trade Schools). Your settings, degree of connection with the viewing User, the subscriptions they may have, their usage of our services, access channels and search types (e.g., by name or by keyword) impact the availability of your profile and whether they can view certain fields in your profile.

Posts, Likes, Follows, Comments, Messages

Our Services allow viewing and sharing information including through posts, likes, follows and comments.

• When you share an article or a post (e.g., an update, image, video or article) publicly it can be viewed by everyone and re-shared anywhere (subject to your settings). Users, Guests and others will be able to find and see your publicly shared content, including your name (and photo if you have provided one).
• In a group, posts are visible to others in the group. Your Usership in groups is public and part of your profile, but you can change visibility in your settings.
• Any information you share through companies’ or other organizations’ pages on our Services will be viewable by it and others who visit those pages.
• When you follow a person or organization, you are visible to others and that “page owner” as a follower.
• We let senders know when you act on their message, subject to your settings where applicable.
• Subject to your settings, we let a User know when you view their profile.
• When you post content on your profile, others will be able to view these “social actions” and associate it with you (e.g., your name, profile and photo if you provided it).

3.2 Communication Archival

Regulated Users may need to store communications outside of our Service.

Some Users (or their employers) need, for legal or professional compliance, to archive their communications and social media activity, and will use services of others to provide these archival services. We enable archiving of messages by and to those Users outside of our Services. For example, a financial advisor needs to archive communications with her clients through our Services in order to maintain her professional financial advisor license.

3.3 Others’ Services

You may link your account with others’ services so that they can look up your contacts’ profiles, post your shares on such platforms, or enable you to start conversations with your connections on such platforms. Excerpts from your profile will also appear on the services of others.

Subject to your settings, customers (e.g., Colleges, Universities and Trade Schools) may look up your profile. When you opt to “connect” with other services, personal data will become available to them. Third-party services have their own privacy policies, and you may be giving them permission to use your data in ways we would not. You may revoke the connection to customers and their third party services.

Subject to your settings, excerpts from your profile will appear on the services of others (e.g., search engine results, mail and calendar applications that show a user limited profile data of the person they are meeting or messaging, social media aggregators, talent and lead managers). “Old” profile information remains on these services until they update their data cache with changes you made to your profile.

3.4 Related Services

We share your data across our different Services and SpringPath affiliated entities.

We will share your personal data with our affiliates to provide and develop our Services. We may combine information internally across the different Services covered by this Privacy Policy to help our Services be more relevant and useful to you and others. For example, we may personalize your feed or recommendations based on your learning history.

3.5 Service Providers

We may use others to help us with our Services.

We use others to help us provide our Services (e.g., maintenance, analysis, audit, payments, fraud detection, marketing and development). They will have access to your information as reasonably necessary to perform these tasks on our behalf and are obligated not to disclose or use it for other purposes.

3.6 Legal Disclosures

We may need to share your data when we believe it’s required by law or to help protect the rights and safety of you, us or others.

It is possible that we will need to disclose information about you when required by law, subpoena, or other legal process or if we have a good faith belief that disclosure is reasonably necessary to (1) investigate, prevent or take action regarding suspected or actual illegal activities or to assist government enforcement agencies; (2) enforce our agreements with you; (3) investigate and defend ourselves against any third-party claims or allegations; (4) protect the security or integrity of our Services (such as by sharing with companies facing similar threats); or (5) exercise or protect the rights and safety of SpringPath, our Users, personnel or others. We attempt to notify Users about legal demands for their personal data when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand.

3.7 Change in Control or Sale

We may share your data when our business is sold to others, but it must continue to be used in accordance with this Privacy Policy.

We can also share your personal data as part of a sale, merger or change in control, or in preparation for any of these events. Any other entity which buys us or part of our business will have the right to continue to use your data, but only in the manner set out in this Privacy Policy unless you agree otherwise.

4. Your Choices & Obligations

4.1 Data Retention

We keep most of your personal data for as long as your account is open.

We generally retain your personal data as long as you keep your account open or as needed to provide you Services. This includes data you or others provided to us and data generated or inferred from your use of our Services. Even if you only use our Services when looking for a new school or job every few years, we will retain your information and keep your profile open, unless you close your account. In some cases we choose to retain certain information (e.g., insights about Services use) in a depersonalized or aggregated form.

4.2 Rights to Access and Control Your Personal Data

You can access or delete your personal data. You have many choices about how your data is collected, used and shared.

We provide many choices about the collection, use and sharing of your data, from deleting or correcting data you include in your profile and controlling the visibility of your posts to advertising opt-outs and communication controls. We offer you settings to control and manage the personal data we have about you.

For personal data that we have about you, you can:

• Delete Data: You can ask us to erase or delete all or some of your personal data (e.g., if it is no longer necessary to provide Services to you).
• Change or Correct Data: You can edit some of your personal data through your account. You can also ask us to change, update or fix your data in certain cases, particularly if it’s inaccurate.
• Object to, or Limit or Restrict, Use of Data: You can ask us to stop using all or some of your personal data (e.g., if we have no legal right to keep using it) or to limit our use of it (e.g., if your personal data is inaccurate or unlawfully held).
• Right to Access and/or Take Your Data: You can ask us for a copy of your personal data and can ask for a copy of personal data you provided in machine readable form.

You may also contact us using the contact information below, and we will consider your request in accordance with applicable laws.

4.3 Account Closure

We keep some of your data even after you close your account.

If you choose to close your SpringPath account, your personal data will generally stop being visible to others on our Services within 24 hours. We generally delete closed account information within 30 days of account closure, except as noted below.

We retain your personal data even after you have closed your account if reasonably necessary to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse (e.g., if we have restricted your account for breach of our Policies, enforce our User Agreement, or fulfill your request to “unsubscribe” from further messages from us. We will retain de-personalized information after your account has been closed.

Information you have shared with others (e.g., through messaging, updates or group posts) will remain visible after you close your account or delete the information from your own profile or mailbox, and we do not control data that other Users have copied out of our Services. Groups content and ratings or review content associated with closed accounts will show an unknown user as the source. Your profile may continue to be displayed in the services of others (e.g., search engine results) until they refresh their cache.

5. Other Important Information

5.1. Security

We monitor for and try to prevent security breaches. Please use the security features available through our Services.

We implement security safeguards designed to protect your data, such as HTTPS. We regularly monitor our systems for possible vulnerabilities and attacks. However, we cannot warrant the security of any information that you send us. There is no guarantee that data may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.

5.2. Cross-Border Data Transfers

We store and use your data outside your country.

We process data both inside and outside of the United States and rely on legally-provided mechanisms to lawfully transfer data across borders. Countries where we process data may have laws which are different from, and potentially not as protective as, the laws of your own country.

5.3 Lawful Bases for Processing

We have lawful bases to collect, use and share data about you. You have choices about our use of your data.

At any time, you can withdraw consent you have provided by going to settings.

We will only collect and process personal data about you where we have lawful bases. Lawful bases include consent (where you have given consent), contract (where processing is necessary for the performance of a contract with you (e.g., to deliver the SpringPath Services you have requested) and “legitimate interests.”

Where we rely on your consent to process personal data, you have the right to withdraw or decline your consent at any time and where we rely on legitimate interests, you have the right to object. If you have any questions about the lawful bases upon which we collect and use your personal data, please contact our Data Protection Team.

5.4. Direct Marketing and Do Not Track Signals

Our statements regarding direct marketing and “do not track” signals.

We currently do not share personal data with third parties for their direct marketing purposes without your permission.

5.5. Contact Information

You can contact us or use other options to resolve any complaints.

If you have questions or complaints regarding this Policy, please first contact SpringPath online. You can also reach us by physical mail.