Privacy Policy

Website Privacy Policy – Effective April 9, 2018

This Website Privacy Policy describes how we collect and use information you provide to us when you use a VSAC website or web application. The information we collect from you and how we use it depends on how you use the website. By accessing or using our website or web application, you hereby consent to the terms of this Website Privacy Policy. This Website Privacy Policy applies to this website and the other VSAC websites or web applications that display or link to this Website Privacy Policy.

How we collect information

We collect personally identifiable information that you provide to us by email, website forms, or other electronic means. Personally identifiable information is information that can specifically identify you, such as your name, phone number, address, email address, date of birth, income, account number, Social Security number, or driver’s license number. If you email us at [email protected] (email contact links on our website use this address), we will automatically receive your email address. We will use it to respond to you by email and to send information about VSAC to you via social media and/or other electronic means.

We collect information related to your use of our website using HTTP cookies, Adobe Flash cookies, web beacons, and log information. When you visit our website, we collect information including, but not limited to, your domain name, your internet Protocol address, internet sites that linked you to our website, the browser you use, and the pages of our websites that you view. We may store this information in our website logs. This information helps us to determine what kind of information is most useful to our website visitors. We do not collect personally identifiable information about you from your visit to the website unless you provide it to us.

We may receive information about you from third parties. This may include information about your interactions with our service providers or your use of our web applications, including our social networking applications or pages. We may combine information collected about you through one VSAC service with other information collected through another VSAC service or information collected through our service providers.

How we use information

We use the information you provide to respond to your request for information from VSAC; process loan and grant applications; service your account; contact you with service updates, marketing information, or reminders; comply with legal or regulatory requirements; measure, improve, and customize our services; fulfill other technical, logistical, financial, tax, legal, regulatory, compliance, administrative functions; and provide customer service.

We, our service providers, and other companies we work with may deploy and use cookies, web beacons, local shared objects, and other tracking technologies for different purposes, including fraud prevention and managing our advertising performance. This includes monitoring and tracking the settings of the device you use to access the services we offer online.

“Cookies” collect information about your use of our website, such as particular pages visited, so that we can understand how you and other customers navigate our site, improve your experience with our site and landing pages, facilitate application processing, and collect anonymous traffic data. Cookies are small files of data that we store on your computer to help us understand how you use the website. We use session cookies and persistent cookies when you visit the website. Session cookies expire when you leave our website. Persistent cookies are stored on your computer to retain information about how you use our website. Cookies also enable us and our service providers to relate your use of our online services to provide you with a customized experience. Most browsers are initially set to accept cookies, but you may set your preferences to refuse cookies or alert you when cookies are being sent. We do not use cookies to store your name, mailing address, or other personally identifiable information.

We also use clear GIFs, pixel tags, web beacons, and information gathered from logs to monitor website performance; improve website design, functionality, and security; and assemble web analytics and activity trends. Pixel tags are one-pixel, transparent images located in an email, webpage, or other message that may be used when you are served advertisements by us or interact with advertisements you receive from third parties. web beacons are objects embedded into web pages that allow us to determine whether and for how long users view web pages. You may stop your browser from accepting web beacons. Your browser may have add-ons that may help you block web beacons. However, you may have limited functionality if you block cookies or web beacons set by our website. We use these primarily to identify users, monitor website traffic, and review marketing response rates.

We use Adobe Flash videos and applications to provide content such as video clips or animation. Adobe Flash uses cookies (also called Local Shared Objects) similar to browser cookies but they are usually managed using an interface different than the one provided by your browser. We use Flash cookies to remember settings, preferences, and usage. We do not use Flash cookies to serve interest-based advertising. You may control these cookies by using Adobe’s Flash Settings Manager. Your browser may also have add-ons that may help you manage Flash cookies. You may also turn off or uninstall Adobe Flash for your web browser. However, you may have limited functionality if you block flash cookies set by our website or if you turn off Adobe Flash.

Online Advertising

We use Google Analytics/Tag Manager (and other third-party sites) to collect visitor data and analyze traffic on our website. This information helps us to understand our customer interests and helps us improve our website. We also use Google AdWords to advertise on third-party sites (including Google) to show advertisements on our websites and across the internet. The advertisements you see will generally be based upon the information we or our service providers and other companies we work with have about you, including information about the services and products you have with us. Where permitted by applicable law, we may share this information with others. Third-party vendors, including Google, use cookies to serve ads based on someone’s past visits to VSAC owned websites (vsac.org or vheip.org).

Online behavioral advertising (known as “OBA” or “internet-based advertising”) involves the collection of information from a computer or other device about a visitor’s web browsing activity across non-affiliated websites to allow us to deliver advertisements based on that visitor’s website browsing history, including, but not limited to, web pages viewed, search terms used, or the manner in which you navigate a website. Companies we work with may place cookies on your devices and use related tracking technologies to support our OBA efforts. If you do not want your information collected and used by the companies involved in our OBA efforts, you can opt out by following the OBA Opt-Out procedure.

Opting Out of Online Behavioral Advertising

We provide two (2) ways you may opt out of OBA involving our advertisements on third-party websites. You may opt out through Network Advertising Initiative opt out page. To opt out, please follow the instructions located at https://optout.networkadvertising.org/#!/

Another way to opt out is by visiting Google’s Ad Settings and disabling Google’s use of cookies by following the instructions located at https://support.google.com/ads/answer/2662922?hl=en.

How We Share Personal Information

We do not share your personally identifiable information except as authorized by you or otherwise permitted by law. For example, we may share your personally identifiable information with individuals and companies we use to perform services on our behalf including, but not limited to, marketing assistance, data analytics, data processing, sending postal mail, email or text messages, customer service, and collections. Any service providers we use must agree to keep such information confidential and not use it for any purpose we do not authorize. We may also share your information with schools, guarantors, and other government agencies if necessary to process your application for a grant or loan.

We may share your personally identifiable information when we believe it is necessary to comply with the law, assist law enforcement, enforce our Terms of Use and other agreements, or to protect your property or safety. We also may share your personally identifiable information with other companies for credit risk reduction or fraud protection.

VSAC’s websites do not respond to “Do-Not-Track” settings or other mechanisms that provide the ability to exercise choice regarding the collection of personally identifiable information of your online activities over time and across third-party websites or online services.

Use and Sharing of information Relating to Social Networks

If you access our applications or pages on social networking sites, such as Facebook, you may also be required to read and accept those sites’ terms of service or privacy policies. Those sites may use the information you provide them to serve you personalized advertising based on your background, location, demographics, likes, keywords, and any other information they receive from you, including the information you share with VSAC on those sites. You acknowledge that you have agreed to and are bound by those sites’ privacy policies and terms of use with regard to those sites’ use of your information. VSAC is not responsible for those sites’ use of your information, including the information you may submit to VSAC using those social networking sites.

If you access our applications or pages on social networking sites, you authorize VSAC to collect, store, and use all information you submit to our Facebook applications or pages. You also authorize VSAC to collect, store, and use all information that you agreed the social networking site could provide to VSAC through those sites’ application programming interfaces. For instance, if you use our Facebook applications, Facebook may pass certain information about your use of its service to us, including your user ID, status, any information you have permitted Facebook to share with us, any information you have made public in connection with Facebook, or aggregate, anonymous, or technical information relating to the use of our applications. VSAC will collect, store, and use this information in accordance with this Website Privacy Policy. You agree to these conditions when you allow this sharing on social networking sites or start using our applications or pages on those sites.

Please remember that when you interact with social networking applications or pages, you may have privacy controls at your disposal. When you publish content or information using a public setting on these social networking sites, you may be allowing everyone, including people off of those social networking sites, to access and use that information, and to associate it with you.

Security

If personally identifiable information is accessed through our website, it is encrypted before it is transmitted over the internet. To protect your personally identifiable information, we use technical and physical safeguards and train our employees.

Children’s Online Privacy

We do not knowingly collect information from children under the age of 13. We will delete any information from our systems if we learn that is from a child under the age of 13. Please visit the FTC’s website at www.ftc.gov to learn more about protecting children online.

Links to other sites

Our website contains both “internal” links (links to other parts of the VSAC website), and “external” links (links to other sites on the web). This Website Privacy Policy applies only to websites or web applications where it is linked or displayed. Other sites to which we link may have other privacy policies and terms of use. Please review each site to determine if their terms of use and privacy policies differ from ours.

Contact Information

If you have questions about this website, please contact us.

Effective Date

This Web Privacy Policy is effective as of April 9, 2018, and replaces any prior VSAC Website Privacy Policy.

Changes to the Website Privacy Policy

You agree that we may change this Privacy Policy by posting a revision on this website.

Privacy Act Notice

If you apply for a Vermont grant, section 7(b) of the Privacy Act of 1974 (5 U.S.C. 522a) requires that when any federal, state, or local government agency requests an individual to disclose his/her Social Security number, that individual must also be advised whether that disclosure is mandatory or voluntary, by what statutory or other authority the number is solicited, and what uses will be made of it. Accordingly, grant applicants are advised that disclosure of their Social Security number is and has been since 1966 a requirement and condition for participation in the grant program.

VSAC uses the Social Security number of the applicant to identify the applicant, to ensure the information concerning the application is properly placed in our files, to certify attendance and status at college, and to identify the student for making grant program payments.

Section 7(a)(2) of the Privacy Act provides that an agency may continue to require the disclosure of an individual’s Social Security number where the agency required this disclosure under statute or regulations prior to Jan. 1, 1975, in order to verify the identity of the individual. Since 1966, applicants have been required to provide Social Security numbers, and all subsequent application forms have required applicants to submit their Social Security numbers. On Nov. 1, 1974, the VSAC Board of Directors adopted regulations that authorize the grant program to withdraw a student’s application from consideration for failure to provide required information.

In addition, based upon the same authority, VSAC also requires parents’ Social Security numbers on the grant application. The parents’ Social Security numbers are used by VSAC to verify parents’ income with the Vermont Department of Taxes as required in 16 VSA S2843(b) or to obtain copies of U.S. income tax returns as authorized by the parents’ signature on the Vermont Grant Application.

If you apply for an education loan through VSAC, the Privacy Act of 1974 (5 U.S.C. 552a) requires that the following notice be provided.

The authority for collecting the requested information from and about you is Section 484(a)(4)(B) of the Higher Education Act of 1965, as amended [20 U.S.C. 1091(a)(4)(B)]. You are advised that participation in the Federal Family Education Loan Program is voluntary, but the requested information is necessary for participation.

The principal purpose of this information is to verify your identity, to determine your program eligibility and benefits, to permit the servicing of your loan(s), and, in the event it is necessary, to locate you and to collect on your loan(s) if it becomes delinquent or defaulted.

The routine uses of this information include its disclosure to federal, state, or local agencies, to private parties such as relatives, present and former employers, business and personal associates, to guaranty agencies, to credit bureau organizations, to educational and financial institutions, and to agency contractors in order to verify your identity, to determine your program eligibility and benefits, to permit the servicing or collecting of your loan(s), to counsel you in repayment efforts, to investigate possible fraud and to verify compliance with program regulations, or to locate you if you become delinquent in your loan(s) payments or you default.

You must provide all of the information requested in order to have your application processed.

Section 7(b) of the Privacy Act of 1974 (5 U.S.C. 552a note) requires that when any federal, state, or local government agency requests an individual to disclose his/her Social Security number, that individual must also be advised whether that disclosure is mandatory or voluntary, by what statutory or other authority the number is solicited, and what uses will be made of it.

Section 7(a)(2) of the Privacy Act provides that an agency may continue to require the disclosure of an individual’s Social Security number where the agency required this disclosure under statute or regulations prior to Jan. 1, 1975, in order to verify the identity of the individual.

Disclosure of your Social Security number is required to participate in the Federal Family Education Loan Program (FFELP). The US Department of Education has, for several years, consistently required the disclosure of individuals’ Social Security numbers on application forms and other necessary FFELP documents adopted pursuant to published regulations.

Your Social Security number will be used to verify your identity, and as an account number (identifier) throughout the life of your loan(s) in order to record necessary data accurately. As an identifier, the Social Security number is used in such program activities as determining your program eligibility, certifying your school attendance and student status, determining your eligibility for deferment of payments, determining your eligibility for disability or death claims, and for tracing and collecting from you in case you become delinquent in your loan payments or you default.

Under the Right to Financial Privacy Act of 1978 (12 U.S.C. 3401-3421), the US Department of Education will have access to financial records in an individual’s student loan file maintained by the lender in compliance with the administration of FFELP loans.

If you apply for a VSAC-assisted scholarship, section 7(b) of the Privacy Act of 1974 (5 U.S.C. 522a) requires that when any federal, state, or local government agency requests an individual to disclose his/her Social Security number, that individual must also be advised whether that disclosure is mandatory or voluntary, by what statutory or other authority the number is solicited, and what uses will be made of it. Accordingly, scholarship applicants are advised that disclosure of their Social Security number is and has been since 1966 a requirement and condition for participation in VSAC-assisted scholarship programs.

VSAC uses the Social Security number of the applicant to identify the applicant, to ensure that information and documents associated with the application are properly entered and filed, to certify attendance and status at college, and to identify a scholarship recipient for disbursing the scholarship.

Section 7(a)(2) of the Privacy Act provides that an agency may continue to require the disclosure of an individual’s Social Security number where the agency required this disclosure under statute or regulations prior to Jan. 1, 1975, in order to verify the identity of the individual. Since 1966, scholarship applicants have been required to provide their Social Security number, and all subsequent application forms have required scholarship applicants to provide their Social Security number.