I. Introduction and Overview

Sid3car Co., Inc., an Indiana corporation (d/b/a Student First Technologies) (together with its affiliates, collectively, “Student First”), leverages technology to empower parents to choose best education opportunities for their children, and we believe that everyone has a right to privacy.  At Student First, we view privacy as a key part of the value that we deliver to our customers.

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Student First has adopted this Privacy Policy (this “Privacy Policy”), which applies to all of our users, to explain how we collect, store, process, use, and disclose your information when you interact with us and our websites, platform portals, applications, offerings, and other services (collectively, the “Student First Platform”).   Please read [the // your applicable] Terms of Service [(i.e., the State Agency Terms of Service, the School Terms of Service, the Marketplace Vendor and Marketplace Service Provider Terms of Service, or the Parent or Guardian Terms of Service)]  and this Privacy Policy carefully before accessing our services and submitting information to us.  In the event that you do not agree to the entirety of this Privacy Policy and your applicable Terms of Service, you are not authorized to use our services or to submit information to us, and your sole remedy will be to stop accessing and using our services.

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Capitalized terms used herein and not otherwise defined have the meanings ascribed to such terms in your applicable Terms of Service.  The Terms of Service are hereby incorporated into and made a part of this Privacy Policy.

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II. Scope of This Privacy Policy

This Privacy Policy is global in nature, meaning that it applies to the entirety of the Student First Platform, and it describes our privacy practices when we process:

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             (i) Personal information for the purposes of providing the benefits of the Student First Platform;

             (ii) Personal information for the purposes of preparing tax statements  for you to use in preparing your tax returns or other tax filings (collectively, “Tax Preparation Information”); and/or

             (iii) Personal information as necessary to manage, run, and improve our business.

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This Privacy Policy applies when Student First provides services directly on our own behalf and acts as a controller with respect to your personal information, which means that Student First is the party that determines the purposes and means of processing of your personal information (an “Information Controller”).  Student First may share your personal data with other affiliates of Student First to process as joint controllers for the purposes set out in this Privacy Policy.  If you have any questions about the processing of your personal data, then please contact us in the section “How to Contact Us” below.

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In certain situations, there may be more than one Information Controller processing your information.  For example, a U.S. state agency (a “State Agency”), nonprofit (“Nonprofit”), school (“School”), or other vendor (a “Marketplace Vendor”) or service provider (a “Marketplace Service Provider”) may also act as an Information Controller.   In these situations, we act as an independent Information Controller over our processing activities, meaning that we make determinations over how your personal information will be processed independently from the other Information Controller.  The other Information Controller may have their own obligations under applicable information privacy law, and you may need to speak with the other Information Controller directly for questions on how they process your personal information.

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This Privacy Policy does not apply when Student First processes personal information merely as a service provider on behalf of a customer or entity who acts as an Information Controller.  When we act as a service provider, the privacy policy of the relevant Information Controller and our agreements with such business or entity will govern our processing of personal information.  As such, you should review the privacy policy of such third parties because they will be responsible for your personal information.

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III. The Student First Platform

The Student First Platform allows State Agencies and Nonprofits to administer education savings account, scholarship, and tax credit programs for the benefit of Parents or Guardians, who can access the Student First Platform to make state-funded payments, or receive reimbursement for personal payments, to Schools, Marketplace Vendors, and/or Marketplace Service Providers for educational goods and services that such Schools, Marketplace Vendors, and/or Marketplace Service Providers have provided to such Parents’ or Guardians’ students.

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When you access the Student First Platform, whether as a State Agency, Nonprofit, School, Marketplace Vendor, Marketplace Service Provider, Parent or Guardian, or an Authorized User of any of the foregoing, you are choosing to share data with us, or bring over information from third parties (like a bank), and we use that data holistically, not just within the individual offering or offerings that you are using.

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The personal information that we use in this centralized way is all of the information that Student First knows about you.  It includes your credentials; your name and contact details; payment information; information about your activities, interests, and preferences; the content that you place on the Student First Platform; and any information that we have collected about you from any third-party sources.

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             A. Organizational Account Access

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Some experiences and services within the Student First Platform allow an organizational or individual user to grant access to that user’s account to another user (an “Authorized User”).  For example, a State Agency, Nonprofit, School, Marketplace Vendor, or Marketplace Service Provider may grant access to an employee, and a Parent or Guardian may grant access to another Parent or Guardian.  In the event that you receive such access to another account as an Authorized User, a designated administrator of that account may control and administer details of your account, including, without limitation, by deciding your access rights; making decisions about your personal information; or requiring you to take certain actions, such as using location tracking to clock in for a shift.  In the event that a designated administrator amends your access rights, you may lose access to the information that is in the control of that organizational or individual user.

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In addition, in the event that you use the Student First Platform as an Authorized User of the account of another user, such as an organization or an individual, your use of the Student First Platform may be subject to that organization’s or individual’s policies, which may be different from this Privacy Policy.  We are not responsible for the privacy or security practices of other organizations or individuals, and you should consider both the organization’s policies and whether you are comfortable granting that organization or individual access to your information before connecting to their services.

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             B. Interacting with Other Organizations and Entities

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Some experiences and services within the Student First Platform allow you to interact with other organizations and individuals, such as a State Agency, Nonprofit, School, Marketplace Vendor, Marketplace Service Provider, Parent or Guardian, or a service provider of your own (such as a bank).  For example, a Parent or Guardian may enroll a student in a School or purchase educational goods or services from a Marketplace Vendor or Marketplace Service Provider.  In the event that you interact with another organization or individual on the Student First Platform, a designated administrator acting on behalf of that organization or individual may control and administer details of your account, including, without limitation, by deciding your access rights; making decisions about your personal information (such as details about your payments and reimbursements); or requiring you to take certain actions (for example, certifying to the truthfulness or accuracy of submissions).  In the event that a designated administrator amends your access rights, you may lose access to the information that is in the control of that organizational or individual user.

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In addition, in the event that you use the Student First Platform to interact with another organization or individual, your use of the Student First Platform may be subject to that organization’s or individual’s policies, which may be different from this Privacy Policy.  We are not responsible for the privacy or security practices of other organizations or individuals, and you should consider both the organization’s or individual’s policies and whether you are comfortable granting that organization or individual access to your information before connecting to their services.

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IV. Information We Collect

Student First collects information about you when you interact with the Student First Platform.  We may collect this information when you provide it to us, from third parties, or from other sources.

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             A. Information We Receive from You

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The personal information that we receive about you depends on the context of your interactions with Student First, how you configure your account, and the choices that you make, including your privacy settings.  Personal information that you provide may also depend upon what services or experiences you use, your location, and applicable law.

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             1. Creating an Account

We collect information when you create an account, interact with the Student First Platform, or activate a subscription.  Personal information may include your contact information (such as your name, address, phone number, and e-mail address), profile photo, billing and payment information, usernames, social media accounts, and credentials.

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             2. Identification Information

We collect information to verify your identity, including your name, social security number, social insurance number, driver’s license numbers, and government-issued identification details, for example, in order to help you file your tax return.

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             3. Financial Information

We collect information about your finances, including bank routing and account numbers.

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             4. Customer Support, Product Research, Training, and Feedback

We may collect personal information when you reach out to us for support, give us feedback, participate in optional surveys, product research, or training and you choose to share.

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             5. Social and Community Content

We receive content you post on our social media pages and our community pages.

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             6. Device Information

We may collect information about the device that you use to access our services, such as your Internet Protocol (“IP”) addresses, log information, error messages, device type, and unique device identifiers.  For example, we may collect IP addresses from you as part of our sign in and security features.

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             7. Content

We may receive information about you, your student, finances, expenses, invoices, financial statements, details of your financial transactions, payment details, tax return details, and/or details about your vendors.

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             8. Third-Party Service Content

We receive information about you when you sign into a third-party service with your account or when you connect your account to a third-party service.  For example, you may choose to connect your account with your bank accounts.  To sync your financial account information, we must access your financial account information.

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             9. Usage Information

We may collect usage information such as your search history, the pages you viewed, the features you use, your browser type, and details about any links with which you interact.

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             10. Location Information

Certain features in the Student First Platform may collect information that permits us to determine your precise location, device motion information, or both, if you grant permission to do so in your device settings.

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             11. Expert Advice

The Student First Platform provides many opportunities for you to connect with live experts, including, for example, accountants or tax preparers.  When you interact with these experts, we may receive information about the questions you ask, the details of your accounts, and the guidance provided to you.

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             12. Camera, Contacts, and Push Notifications

Certain features may have access to your camera, contacts, and push notification services if you grant permission in your device settings.

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             13. Information From Cookies and Other Technologies

Student First and our service providers may use commonly used tools such as cookies, web beacons, pixels, local shared objects and similar technologies (collectively, "Cookies") to collect information about you (collectively, “Cookie Information”) so that we can provide the experiences you request, recognize your visit, track your interactions, and improve your and other customers’ experience.  You have control over some of the information that we collect from Cookies and how we use it.

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             14. Information Stored Locally

Some of our web-enabled desktop services and offerings synchronize with the information on your computer or mobile device.  In doing so, we may collect information such as device information, product usage, and error reports.  We may also store personal information locally on your device.

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             15. Biometric Information

Certain parts of the Student First Platform make use of biometric personal information (“Biometric Information“).  Biometric Information can be subject to additional laws and regulations.

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We collect Biometric Information from you when you enroll in our biometric identity program and automatically as part of our anti-fraud protection, authentication, and customer support activities.  These identifiers may include facial recognition information, voiceprints, and key-stroke information, as well as mathematical representations of your biometric identifier, such as the template maintained for comparison.  We use Biometric Information to identify and authenticate you, and for security and similar purposes.  We share Biometric Information with third-party service providers who assist with our information technology, security, and ant-fraud programs, our professional advisors, and as required by law or regulation.  Student First does not sell your Biometric Information.

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When we collect Biometric Information, you will receive a specific notice and consent request at the time of that collection.  You are not required to consent to the collection of Biometric Information in order to use our services, although some functionality may not be available if you decline, and you may withdraw your consent at any time.

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Student First will retain Biometric Information until the purposes for which it was collected have been satisfied or three years from your or your organizational account manager’s last interaction with Student First, whichever comes first.

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             B. Information Provided by Others

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Our platform is designed to help you connect with other people and organizations.  As a result of those connections, others may be able to input information about you.  For example, a U.S. state agency, nonprofit, school, or vendor or other service provider may input information about your student and educational activity in order to process their invoices.  You may also be able to input or process information about others, for example, if you are an account administrator.  If you input information about others into our platform, then you must only do so if you have first received the appropriate rights and permissions to do so, including by getting advanced written consent, if required by applicable law.

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             C. Other Information Sources

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We may also get information about you from others when permitted by applicable law.  We protect and process information obtained from those parties as described in this Privacy Policy, consistent with any additional restrictions imposed by the source of the information.  Our sources may vary over time and depend upon how you use the Student First Platform.  For example, we receive information from:

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             1. Your Service Providers

In the event that you choose to sync a non–Student First account or service with your account, we will receive information from that account or service according to your settings with that account or service.

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             2. Supplemental Information and Identity Verification Providers

Service providers who help us verify your identity and the specifics of your business, supplement the information you have provided, and ensure the accuracy of your information.  For example, we use third-party service providers to validate your mailing address and phone number and provide additional details about your business.  These providers may include, for example, your financial institution, telecommunications provider, or e-mail provider.

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             3. Customer Support Providers

Service providers provide us with information about you or your interaction with the Student First Platform for troubleshooting purposes.  For example, we may obtain support information or technical issues you have raised with these third parties.

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             4. Credit Bureaus and Other Third Parties

Many of our features rely on information about you that we receive from third parties.  Our partners may provide information such as employment or income data or vehicle or driver information so that we can give you more personalized recommendations.

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             5. Other Users

As described above, we may get information about you from other users, such as a State Agency, Nonprofit, School, Marketplace Vendor, Marketplace Service Provider, Parent or Guardian or Authorized User of any of the foregoing.  We may also collect such information through features like member referral programs.

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             6. Risk Management, Cybersecurity, and Anti-Fraud Providers

We may receive information from service providers who help us assess risks associated with our offerings, including to help combat fraud and illegal activity and to help protect your personal information.

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             7. Content Providers

We may receive information from software providers that make user-generated content from their service available to others, such as local business reviews or public social media posts.

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             8. Communication Providers and Social Networks

In the event that you give us permission, we may collect information from e-mail providers, communication providers, and social networks.

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             9. Joint Offering Partners

We may offer co-branded services or experiences or engage in joint-marketing activities with others, including through our conferences or live events.

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             10. Publicly Available Sources

We collect information from publicly available sources, such as open government databases.

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             11. Government Agencies

We receive information from government agencies, including from various tax agencies.

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             12. Required Information

Some services and experiences in the Student First Platform require you to provide information for it to function.  In the event that you do not wish to provide the required information, you may not be able to use certain features.

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             D. Children’s Personal Information

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Our services are not intended for or directed to children.  We do not verify the age of any of our visitors or users, and by using our services, you represent to Student First that you are at least eighteen (18) years of age.

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We do not knowingly collect personal information from children, although we may collect information about children from other sources, such as applicable State Agencies, Nonprofits, Schools, Marketplace Vendors, Marketplace Service Providers, and Parents or Guardians, in order to provide the benefits of the Student First Platform to their Parents or Guardians.  In the event that you believe that we may have received information directly from a child, please contact us.

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V. How We Use Your Information

We collect and process personal information from you only when:

• We have your consent to do so;

• We need the personal information to perform a contract with you or provide a service to you;

• We need the personal information to provide you with the benefits of the Student First Platform and operate our business;

• The processing is in our legitimate business interests in those jurisdictions where legitimate business interest is a legitimate basis for processing; and/or

• We need to comply with legal requirements, including applicable laws and regulations.

We use personal information to operate our business for the following purposes, which are required to originate and maintain our relationship with you, including, without limitation:

• Providing you with access to the Student First Platform and to create your account;

• Improving our products and services;

• Running and managing our business, including resolving billing and financial disputes;

• Evaluating your eligibility for financial offers, products, and services;

• Providing features to you;

• Connecting you with experts and other users;

• Communicating with you, such as sending you electronic notifications concerning your financial privacy;

• Advertising and marketing our services and experiences;

• Personalizing your experience and tailoring recommendations and offers presented to you, including through the development of insights about you and your needs;

• Providing you with support and resolve disputes;

• Conducting research, including by partnering with academic institutions;

• Complying with our legal and regulatory requirements;

• Authenticating your identity, including through the use of Biometric Information;

• Protecting the rights, property, safety, or security of the Student First Platform, our customers, employees, or others and prevent fraudulent or illegal activity;

• Exercising our rights in the course of judicial, administrative, or arbitration proceedings;

• Enforcing, remedying, or applying our Terms of Service or other agreements; and/or

• Other purposes that are compatible with the disclosed purposes if and when this is permitted by applicable law.

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To provide you with valuable personalized advice, recommendations, and experiences, we may process your personal information using automated and manual (human) methods.  Our automated methods include artificial intelligence (AI) and a range of technologies that help our services learn and reason to improve our ability to personalize and enhance your experience in the Student First Platform.

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VI. How We Protect Your Information

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             A. Safeguards

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We use physical, technical, and organizational safeguards designed to protect your information.  Despite these controls, however, we cannot completely ensure or warrant the security of your information.

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             B. International Data Transfers

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Unless you have provided us with consent to transfer your information, your information will be processed and stored in the United States in accordance with applicable law.

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[With the exceptions noted above, you agree and Student First reserves the right to store and process your personal information in the United States and in any other country where Student First or its affiliates, subsidiaries, or service providers operate facilities in accordance with and as permitted by applicable laws and regulations.  Some of these countries may have data protection laws that are different from the laws of your country (and, in some cases, may not be as protective).

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When we transfer, store or process personal information outside of your jurisdiction, we take appropriate safeguards to require that your personal information remain protected in accordance with this Privacy Policy and applicable law.  We may use contracts or the European Commission–approved Standard Contractual Clauses to help ensure your information is protected.]

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In the event that you are visiting or using the services from outside the United States, please be aware that your information may be transferred to, stored, processed, used, and/or disclosed in the United States, where our servers are located and our central database is operated.

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VII. How We Share Your Information

We may share your information in the following circumstances:

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             A. With Your Consent

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Except for as outlined below, we only share your information with third parties when you have directed us to do so.

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             B. When You Connect with a State Agency or Nonprofit

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If you are a Parent or Guardian, then a State Agency or Nonprofit must confirm the enrollment status of your student before your account can be activated.  In the event that you choose to create an account and submit information about yourself and your student to a State Agency or Nonprofit or approval, you consent and direct Student First to share such information to such State Agency or Nonprofit.

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In some cases, in the event that you click through to go to a State Agency’s or Nonprofit’s website, you will automatically be sending your personal information to that State Agency or Nonprofit.  Remember that any information that you provide to a State Agency or Nonprofit, whether through the Student First Platform or on your own, will be subject to their privacy practices and terms and conditions.

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             C. When You Connect with a School, Marketplace Vendor, or Marketplace Service Provider

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If you are a Parent or Guardian, then you may enroll your student in a School or purchase educational goods or services from a Marketplace Vendor or Marketplace Service Provider.  In the event that you choose to interact with a School, Marketplace Vendor, or Marketplace Service Provider, you consent and direct Student First to share your information about yourself and your student to such School, Marketplace Vendor, or Marketplace Service Provider.

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In some cases, in the event that you click through to go to a School’s, Marketplace Vendor’s, or Marketplace Service Provider’s website, you will automatically be sending your personal information to that School, Marketplace Vendor, or Marketplace Service Provider.  Remember that any information you provide to a School, Marketplace Vendor, or Marketplace Service Provider, whether through the Student First Platform or on your own, will be subject to their privacy practices and terms and conditions.

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             D. When You Connect to Your Social Media Account

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Some of our features enable you to connect to a social media account or share information on social media platforms, like Facebook and Twitter.  Any information that you choose to share on social media may potentially be visible to a global audience and will be subject to the social media provider’s privacy policies (not this Privacy Policy).  You should take care only to share information on social media that you are comfortable sharing.

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             E. For Research

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With appropriate controls, we may share information with third parties, such as academic institutions, governments, and non-profit organizations, for research purposes or to publish academic or policy-related materials.  We only share information in a way that would not allow any individual to be identified without their consent.

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             F. For Joint Features, Sales, Promotions, and Events

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We may share your information with third-party companies who are jointly providing features, sales initiatives, promotions, or events with us.

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             G. With Financial Services Providers

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We may share personal information with collection agencies, credit bureaus, loan service providers, and payment card association members.  We may also share your personal information with other companies, lawyers, credit bureaus, agents, government agencies, and card associations in connection with issues related to fraud, credit, defaults, or debt collection.

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             H. When You Publicly Post the Information

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We may provide opportunities for you to publicly post reviews, questions, comments, suggestions, or other content, which may include personal information, such as your name or username.  Anything you share in a public forum is public, and you should think carefully before you decide to share.

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             I. With Service Providers or Agents

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We share personal information with our service providers or agents who provide services on our behalf for the purposes described in this Privacy Policy.  Service providers or agents are required to implement reasonable privacy and information protection controls to maintain the privacy and security of information provided to them consistent with the privacy practices outlined in this Statement.  Service providers or agents may include companies that assist us with our advertising, marketing, and sales efforts, help us with our technology offerings (such as a hosting, security, or anti-fraud providers), and help us run our business.

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             J. For Mergers and Acquisitions

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In the event that we are involved with a merger, asset sale, financing, liquidation, bankruptcy, or acquisition of all or part of our business to another company, we may share your information with that company and its advisors before and after the transaction date, including in connection with due diligence activities.

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             K. No Sale of Personal Information to Third Parties

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We do not and will not sell personal information to third parties.  We do share personal information with third parties for the business purposes described in this Privacy Policy.

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             L. With our Affiliates and Subsidiaries

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We may share your information with our affiliates and subsidiaries for everyday business purposes as described in this Privacy Policy, including for marketing purposes.  Certain laws may provide you with the right to limit our information sharing activities in certain circumstances.  Please review these rights in the “Country and Region-Specific Terms” section below.

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             M. Cookies and Other Tracking Technologies

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You can find information on changing your browser settings to opt-out of Cookies in your browser settings.  In certain countries, you may also be able to make changes to your cookies settings by using our Cookie preferences tool.  In the event that you disable some or all of the Cookies, the service, or parts of the service, may not work.

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Student First may use advertising networks and other providers to display advertising on our Student First Platform or to manage our advertising on other sites.  Our advertising partners may place Cookies on unaffiliated websites in order to serve advertisements that may be relevant to you based on your browsing activities and interests and determine the effectiveness of such advertisements.  See also the “Country and Region-Specific Terms” section below for additional pages.

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The Student First Platform is not currently configured to respond to browsers’ “Do Not Track” signals because at this time no formal “Do Not Track” standard has been adopted.

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             N. For Legal Reasons

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We may share your information with third parties for legal reasons without your consent, and as permitted by law, including:

• When we reasonably believe disclosure is required in order to comply with a subpoena, court order, or other applicable law, regulation, or legal process;

• To protect the rights, property, or safety of Student First, the Student First Platform, our customers, or others;

• To protect or defend against attacks;

• To enforce, remedy, or apply our Terms of Service or other agreements;

• To prevent fraud, cybersecurity attacks, or illegal activity;

• For debt collection; and/or

• With regulatory agencies, including government tax agencies, as necessary to help detect and combat fraud and/or protect our customers, users, and/or the Student First Platform, or in required institutional risk control programs.

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VIII. Your Information Rights

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             A. Your Rights

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At Student First, we believe that you have rights to information that pertains to you.  In the event that another person has input or processed information in the Student First Platform on your behalf and we are processing such information as an Information Controller, you may ask to receive a copy of your information, even if you do not have an account with us.

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Depending on where you live, you may have certain nation- or state-specific rights with respect to your personal information that we collect and process.

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For specific information on what steps you can take to manage your privacy, please see the “Country and Region-Specific Terms” section for your country below.

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             B. Verification

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To help protect privacy and the security of your information, you may be asked to provide additional information to verify your identity and/or ownership rights prior to us exercising your data rights.  In the event that we are unable to verify your identity or ownership rights to the data, we may not be able to provide you with data rights until you are able to provide us with proper documents.

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             C. Information Retention

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Unless you specifically ask us to delete your personal information, we retain your personal information as long as it is necessary to comply with our data retention requirements and provide you with services and the benefits of the Student First Platform.  Even in the event that you request a deletion, however, we may be required to maintain your information for as long as necessary to:

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             (i) comply with our legal or regulatory compliance needs (e.g., maintaining records of transactions you have made with us);

             (ii) to exercise, establish, or defend legal claims; and/or

             (iii) to protect against fraudulent or abusive activity on our service.

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This means we may keep different information for different periods.  In the event that your account is canceled because you haven’t used it in a long time, we may delete this information immediately.

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There may be situations in which we are unable to fully delete, anonymize, or de-identify your information due to technical, legal, regulatory compliance, or other operational reasons.  When this is the case, we will take reasonable measures to securely isolate your personal information from any further processing until such time as we are able to delete, anonymize, or de-identify it.

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             D. Do Not Track

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Some web browsers incorporate a Do Not Track (“DNT”) or other similar feature that signals to websites that a visitor does not want to have his or her online activity and behavior tracked.  Not all browsers offer a DNT option, and there is currently no industry consensus for how to recognize or respond to a DNT signal.  For these reasons, Student First does not currently respond to DNT signals.

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IX. Country and Region-Specific Terms

Additional terms may apply to you based upon the country you reside in or the products you use.  Please click the country or region that applies to you to learn more about additional terms and rights that may apply to you.

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             A. United States

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If you are a resident of the United States, then you may have the following rights:

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             1. U.S. Tax Preparation Information

We understand that your Tax Information is special.  Except as necessary to provide you with tax preparation services or as authorized by law, we will not disclose your Tax Information—including to Student First’s affiliates and subsidiaries—unless you consent.

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We will only use your Tax Information to provide you with tax preparation services or as authorized by law, unless you consent that we can use and/or share it for other purposes.

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If you agree to share your Tax Information outside of our tax products to be used for purposes other than tax preparation services, including by sharing it with the Student First Platform, your Tax Preparation Information will be handled in accordance with this Privacy Policy.

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             2. Vermont

If you are a Vermont resident, then you may have the following rights:

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Student First group companies will not share your non-public personal information with unaffiliated third parties unless you authorize us to make those disclosures without your consent, other than as permitted by law.  Further, Student First group companies’ consumer offerings will not share credit reports with our affiliates without your consent.

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             3. California

If you are a California resident, then you may have the following rights:

Access.  You may have the right to access:

• the categories of personal information we have collected about you;

• the sources from which that information was collected;

• the business or commercial purpose for collecting your personal information;

• the categories of third parties with whom we share your personal information;

• the specific pieces of personal information we have collected about you;

• the categories of personal information we sold about you;

• the categories of third parties to whom we sold personal information about you; and

• the categories of personal information we disclosed for a business purpose.

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Deletion.  You may have the right, under certain circumstances, to request that we delete the personal information that you have provided to us.

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Non-Discrimination.  You may have the right to be free from discrimination related to your exercise of any of your California privacy rights.

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Verification.  In order to protect your personal information from unauthorized access or deletion, we may require you to verify your credentials before you can submit a rights request.  If you do not have an account with us, or if we suspect that your account has suffered fraudulent or malicious activity, we may ask you to provide additional personal information for verification.  For Credit Karma members, we may require that you confirm certain pieces of personal information that we have on file and/or log into your Credit Karma account.  If we are subsequently unable to confirm your identity, we may refuse your rights request.

Authorized Agents.  You may use an authorized agent to submit a rights request.  If you do so, the agent must present signed written authorization to act on your behalf, and you may also be required to independently verify your identity or your legal authority or ownership of the personal information with us.

Please note that we may claim legal exemptions for certain types of personal information from all or certain parts of the CCPA pursuant to various CCPA exemptions.

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You have choices when it comes to managing the privacy of your personal information:

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Update your privacy settings.  You may update your privacy settings by visiting your account settings.

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Manage marketing communications from us.  To update your marketing communication preferences, you can go to the marketing preference tools in your account settings. You may also click unsubscribe at the bottom of the marketing e-mails.

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Request a copy of your personal information.  You may request a copy of your personal information by contacting Student First.

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Correct your personal information.  You can edit and correct your personal information at any time by changing it directly in our products and services.

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Delete your personal information.  You may request for us to delete your personal information by contacting Student First.

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Cookies and other tracking technologies.  You may be able to opt-out of interest-based advertising by contacting Student First.

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Limit Information Sharing.  You have the right to limit our sharing of your information to both affiliates and third-parties for marketing purposes.  You may be able to limit our information sharing by contacting Student First.

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             B. European Union–Area Countries

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[GDPR to be discussed]

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X. Changes to This Privacy Policy

From time to time, we may change or update our Privacy Policy.  We reserve the right to make changes or updates at any time and in our sole discretion.  In the event that we make material changes to the way we process your personal information, we will notify you by posting a notice on the Student First Platform or on a community post; by sending you a notification; or by other means consistent with applicable law.

You can see when this Privacy Policy was last updated by checking the “last updated” date displayed at the top of this Privacy Policy.  In the event that we amend our Privacy Policy, the amended Privacy Policy will take effect immediately for all users of our services, and your continued use of the services following an amendment will constitute your acceptance of the amended Privacy Policy.  Please review this Privacy Policy periodically to stay informed about how Student First protects your privacy.

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XI. How to Contact Us

In the event that you have any questions or comments about this Privacy Policy or our practices, please contact us.

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You can report security or compliance concerns to security@studentfirsttech.com. You can also contact us through the following country and regional channels.

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United States

Student First Technologies

301 W. Kirkwood Avenue, Suite 101

Bloomington, Indiana  47404

Attention: Privacy

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