Apply to Virginia's Community Colleges Privacy Policy

Effective as of June 10, 2020

Please read this policy carefully. It is your choice whether or not to provide personal information to us. If you choose to do so, you are giving your express consent to use, process, transfer and disclose your personal information, within the United States, as set forth in this policy. If you choose not to provide your personal information to us, you will not be able to complete an online admission application to Virginia's Community Colleges.

XAP Corporation ("XAP"), the company that operates Apply to Virginia's Community Colleges, has adopted the following privacy policy for the information collected at this website.

As Apply to Virginia's Community Colleges evolves, we may update this privacy policy to reflect changes in the manner in which we deal with personal information, whether to comply with then-applicable regulations and self-regulatory standards or otherwise. The privacy policy posted here will always be current. We encourage you to review this statement regularly.

What This Privacy Policy Statement Covers:

• Apply to Virginia's Community Colleges privacy policy and its exceptions
• The personal identifying information ("PII") we collect
• Reasons we collect personal identifying information
• Creating an account when you are under 13 years of age or over the age of 13 but under the age of 16 and reside in the European Union
• Ways in which personal identifying information may be used
• With whom personal identifying information may be shared
• Security measures to protect information entrusted to XAP and Apply to Virginia's Community Colleges
• Cookies
• Links
• Modifying and deleting your information
• Your European Union Privacy Rights
• Amending this Privacy Policy
• Questions

Online Application Privacy Policy and its Exceptions

Except as set forth below, personally identifiable data you enter on Apply to Virginia's Community Colleges 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 or provide access to your personal information to any company, individual or organization for its use in marketing or commercial solicitation or for any other purpose, except with your express consent, at your direction, as is necessary for the operation of this site, or pursuant to one of the exceptions listed below.

Exceptions to the Privacy Policy

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

The Personal Identifying Information We Collect

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

Reasons We Collect Your Personal Identifying Information

Apply to Virginia's Community Colleges collects personal information from you primarily for three reasons. The first reason is to perform a task on Apply to Virginia's Community Colleges, such as filling out a specific community college admission application, requested by you. The second reason is to enable you to submit, in a convenient and efficient manner, information that is likely to be needed when you complete community college admissions applications and forms made available through Apply to Virginia's Community Colleges. The third reason is to enable XAP to respond to your questions or contact you when necessary in connection with the functioning of Apply to Virginia's Community Colleges. When the effective functioning of a module on Apply to Virginia's Community Colleges does not require personal information, none is collected, and any such module can be accessed without opening an account or providing any personal data.

When you log on to Apply to Virginia's Community Colleges, your browser will automatically transmit to the Apply to Virginia's Community Colleges server the IP address of your computer and type of browser you are using. Apply to Virginia's Community Colleges combines your personal identifying information with your IP address for the purposes of operating the site and to comply with any valid legal process as described in the section 'Exceptions to the Privacy Policy', above. The combined information is treated in accordance with the terms of this Privacy Policy.

Creating an Account When You Are Under 13 Years of Age

If you are not yet 13 years old, Apply to Virginia's Community Colleges will not allow you to create an account.

If you are over the age of 13 but under the age of 16 and reside in the European Union, you may not create an account on Apply to Virginia's Community Colleges.

If you are 13 years of age or older and not a citizen of the European Union, or a citizen of the European Union aged 16 years or older, you are encouraged to create an account on Apply to Virginia's Community Colleges and to utilize all of the Apply to Virginia's Community Colleges online applications, to apply to the Virginia Community College System.

Ways in Which Personal Identifying Information May Be Used

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

• Complete applications for admission

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

• We may use your identifying information to help diagnose problems with the Apply to Virginia's Community Colleges server and to administer the Apply to Virginia's Community Colleges website.
• Summary data representing a compilation of aggregate data representing the Apply to Virginia's Community Colleges users may be collected by XAP and provided to various entities including community colleges and other educational institutions represented on Apply to Virginia's Community Colleges. No personal identifying information is made available as part of these summary reports. Some examples of summary data are the number of monthly visitors to the site, the number of admission applications submitted over Apply to Virginia's Community Colleges, and the Apply to Virginia's Community Colleges functions utilized by Apply to Virginia's Community Colleges users in specified age or grade ranges.

With Whom Personal Identifying Information May Be Shared

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

• If you submit an application for admission to a community college or other educational institution, the personal data required to complete that application will be provided on your behalf to the admissions office of the institution to which you are applying.

Note: If you begin an application for admission to a community college or other educational institution, your name and other data entered on that application may be provided to the admissions office of that institution, even though you have not yet submitted a completed application to that institution. The admissions office of that institution may contact you to follow up regarding your incomplete application to determine if you need assistance in completing and submitting the application. By starting an application, you give consent to the process described in this paragraph.

Security Measures to Prevent Misuse of Information Entrusted to Apply to Virginia's Community Colleges

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, Apply to Virginia's Community Colleges encrypts the PII you enter when it is in route from your browser to the Apply to Virginia's Community Colleges 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. Apply to Virginia's Community Colleges 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 built-in Internet browsers for iOS and Android. PII residing on the Apply to Virginia's Community Colleges 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 staff, and those employees of XAP who require such access to administer and maintain the Apply to Virginia's Community Colleges system or to provide requested customer support to users of Apply to Virginia's Community Colleges. Each XAP employee who has access to the PII residing on the Apply to Virginia's Community Colleges server has agreed in writing to respect the privacy of all such PII. XAP trains employees to protect customer information and only authorizes access for 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 your 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 non-public 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, which may then be stored on its hard drive. Apply to Virginia's Community Colleges uses cookies to remember you and personalize your web-viewing experience by keeping track of your session when logged on to Apply to Virginia's Community Colleges. Cookies enable you to maintain continuity as you move from page to page on Apply to Virginia's Community Colleges and to avoid the nuisance of being asked to provide the same information repeatedly. Cookies also allow us to make sure that only your browser can exchange information regarding your account with our servers. Cookies cannot be used to steal personal information or to gain access to information that you did not directly provide. The cookies we use are set when you log on to Apply to Virginia's Community Colleges and are erased when you log off Apply to Virginia's Community Colleges or completely close your browser.

We use third-party services provided by Google Analytics to track and analyze your Apply to Virginia's Community Colleges activity. In order to gather this Automatically-Collected Information, we use a Google Analytics cookie on Apply to Virginia's Community Colleges. 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. You should note, however, that various Apply to Virginia's Community Colleges services might not function properly when cookies are not utilized.

Links

Apply to Virginia's Community Colleges hosts links to other sites or resources, and you may link to one of those sites or resources for a variety of purposes, such as visiting an official university website. These sites and resources have privacy policies that may differ from that of Apply to Virginia's Community Colleges, and for your protection, we recommend that you read and understand the privacy policy at any website prior to providing personal information on that website. XAP is not responsible for the privacy practices or the content of any websites to which Apply to Virginia's Community Colleges links or for the conduct of persons operating those websites. XAP, the Virginia Community College System, the community colleges, the associations of community colleges and the agencies represented on Apply to Virginia's Community Colleges do not have control over, and do not endorse such external sites and resources. XAP, the Virginia Community College System, the community colleges, the associations of community colleges and the agencies represented on Apply to Virginia's Community Colleges shall not be liable for any content, advertising, products or other materials on or available from such sites or resources. In addition, the Virginia Community College System, the community colleges, the associations of community colleges and the agencies represented on Apply to Virginia's Community Colleges shall not be responsible or liable, directly or indirectly, for any damage or loss caused or alleged to be caused by or in connection with use of or reliance on any such content, advertising, products or materials on or available through any such site or resource.

Modifying and Deleting Your Information

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

Your European Union Privacy Rights

If you are citizen of the European Union you have additional privacy rights under the General Data Protection Regulation (GDPR) effective May 25, 2018, including but not limited to:

• The right to know who is collecting and processing your personal data.
• The right to know the purpose and legal justification for the collection and processing of your personal data.
• The right to access, receive or correct your personal data.
• The right to restrict the processing of your data where the data is inaccurate, the processing is unlawful, or your personal data is no longer needed or there are no longer legitimate grounds to process your personal data.
• The right to request that your personal data be deleted (where there are no longer legal or necessary grounds to process or store your personal data).
• The right to withdraw your consent to the collection, handling, storage and/or processing of your personal data and to complain to XAP and/or the appropriate EU data protection authority if you have reason to believe that any of your rights are being violated.
• The right to know that the personal data that was collected, handled, stored and processed was required in order to accomplish the purposes that you have given express consent to.

The lawful collection and processing of your personal data is necessary for XAP to provide Apply to Virginia's Community Colleges. If you would like to exercise any of the above rights in relation to your Apply to Virginia's Community Colleges account or if you have any questions about your rights under the GDPR, please contact us at support@xap.com.

Retention and Storage

We retain all PII and Automatically-Collected Information in our databases for five years following the last active account session to fulfill the purpose for which the information was collected, with the exception of in-progress applications which will be automatically deleted if not submitted within one year from start date. Note that even after we remove your information from our databases, 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 even after we remove your information from our databases, for use in the aggregate and to analyze and improve Apply to Virginia's Community Colleges.

Amending This Privacy Policy

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

Questions?

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