I Have A Plan Iowa Privacy Policy
Last Updated: August 24, 2022
XAP Corporation including its subsidiary Bridges Transitions
Inc. (collectively, "XAP") (the company that operates
www.IHaveaPlanIowa.org) has adopted the following Privacy Statement
for the information collected at this website. When you use
I Have a Plan Iowa™ XAP has access to your information and may use
your information to operate and maintain www.IHaveaPlanIowa.org and
in accordance with the terms of this Privacy
Statement.
As www.IHaveaPlanIowa.org evolves, we may update this Privacy
Statement to reflect changes in the manner in which we deal with
personal information, whether to comply with then-applicable
regulations and self-regulatory standards or otherwise. The Privacy
Statement posted here will always be current. We encourage you to
review this Statement regularly. Please see additional information
regarding amending this Statement in the Section entitled "Amending
this Privacy Statement" below.
IMPORTANT NOTICE: Please see the information in
the Section entitled "With whom personally identifying information
and automatically collected information may be shared" for an
understanding regarding the parties who may access your
information.
WHAT THIS PRIVACY STATEMENT COVERS:
- Your agreement to this Privacy Statement
- Types of information collected
- Creating an account when you are under the age of 18
- Reasons we collect personally identifying information
- Ways in which personally identifying information and
automatically-collected information may be used
- With whom personally identifying information and
automatically-collected information may be shared
- Security measures to protect information; Disclaimer
- Cookies
- Links
- Modifying your information
- Retention, Deletion and Storage
- Amending this Privacy Statement
- Unenforceability
- Questions
YOUR AGREEMENT TO THIS PRIVACY STATEMENT
When you use www.IHaveaPlanIowa.org, you signify and affirm that
you have read, understand, and agree to the terms of this
Statement; that you are competent and capable of understanding,
agreeing to, and complying with this Statement; and that this
Statement forms a legally-binding agreement between you and XAP.
You agree that this Statement is supported by reasonable and
valuable consideration (which includes your use of
www.IHaveaPlanIowa.org), and you acknowledge your receipt of and
the sufficiency of such consideration. If you do not agree with all
of the provisions of this Statement, you may not use
www.IHaveaPlanIowa.org).
TYPES OF INFORMATION COLLECTED
This Statement covers information you expressly enter into
www.IHaveaPlanIowa.org and information that we automatically
collect as you use www.IHaveaPlanIowa.org.
THE PERSONALLY IDENTIFYING INFORMATION WE COLLECT
To use certain features of www.IHaveaPlanIowa.org we will
require you to provide us with information that
personally-identifies you ("Personally Identifying Information" or
"PII"). If you choose not to provide us your Personally Identifying
Information, you will not be able to use certain features of
www.IHaveaPlanIowa.org. When you do provide us your PII,
you are authorizing us to use that PII in accordance with this
Statement and to store your PII on our servers in the United
States. The categories of PII that www.IHaveaPlanIowa.org
may collect from you include your name, date of birth, address,
email address, phone number, grade level, Social Security number,
username and password, demographic data (such as your gender,
ethnicity, and zip code), parent's or guardian's names, parent's or
guardian's addresses and phone number and other contact
information, user preferences, and such additional information as
you choose to actively enter into www.IHaveaPlanIowa.org and
include in your portfolio or are required to provide by the college
and/or financial aid applications that you choose to complete or
other actions you choose to take through www.IHaveaPlanIowa.org.
Further, some schools may provide students' transcript information
to us, including at least the following student PII contained on
the applicable student's transcript: Name, address, date of birth,
gender, ethnicity, graduation year, email address, grade point
average (GPA), Student number (from your school district), and
State Student ID. If a school provides us this transcript
information about you, we will automatically include that
information in your account on www.IHaveaPlanIowa.org.
AUTOMATICALLY-COLLECTED INFORMATION
When you use www.IHaveaPlanIowa.org, we automatically track,
collect, and store the following types of information (referred to
as "Automatically-Collected Information"): 1) Date and time you
access www.IHaveaPlanIowa.org; 2) pages visited and features used,
and the order of use; 3) type of computer or other operating device
accessing www.IHaveaPlanIowa.org and type of browser used to access
www.IHaveaPlanIowa.org; 4) referring source (meaning the website
you visit prior to visiting www.IHaveaPlanIowa.org); and 5) other
similar information about the interaction between your browser and
www.IHaveaPlanIowa.org and activities in which you engage while
using www.IHaveaPlanIowa.org. Unless otherwise stated in this
Statement, Automatically-Collected Information may be combined with
your PII.
When you visit www.IHaveaPlanIowa.org, we collect your Internet
Protocol ("IP") address to track and aggregate
Automatically-Collected Information. We also collect IP addresses
of users when they log onto their account portfolios on
www.IHaveaPlanIowa.org in order to confirm the applicable user's
identity.
CREATING AN ACCOUNT WHEN YOU ARE UNDER THE AGE OF 18
Between Age 13 and 17
If you are between the ages of 13 and 17, by using
www.IHaveaPlanIowa.org, you represent and warrant that you possess
legal parental or guardian consent to use www.IHaveaPlanIowa.org
and provide PII and Automatically-Collected Information through
www.IHaveaPlanIowa.org.
Under Age 13
If you are under the age of 13 and you indicate to us that you
are under age 13 when you enter your birthdate into
www.IHaveaPlanIowa.org, you can only create an anonymous account
that does not require you to enter your name or other Personally
Identifying Information. When there are open fields
required in order to create such an anonymous account, you may not
use any of these open fields to enter Personally Identifying
Information, and your account portfolio will not include
your Personally Identifying Information. Further, you will be
restricted from using any areas of www.IHaveaPlanIowa.org that
require you to enter Personally Identifying Information. You will
only be able to use www.IHaveaPlanIowa.org features or modules that
do not require you to enter Personally Identifying Information.
REASONS WE COLLECT PERSONALLY IDENTIFYING INFORMATION
www.IHaveaPlanIowa.org collects PII from you primarily for three
reasons. The first reason is to perform a task on
www.IHaveaPlanIowa.org requested by you, such as filling out a
financial aid application. 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 college admission, financial
aid, and other applications and forms made available through
www.IHaveaPlanIowa.org or undertake a scholarship search on
www.IHaveaPlanIowa.org. The third reason is to enable XAP to
respond to your questions or contact you when necessary in
connection with the functioning of www.IHaveaPlanIowa.org or to
provide required notices.
WAYS IN WHICH PERSONALLY IDENTIFYING INFORMATION AND
AUTOMATICALLY-COLLECTED INFORMATION MAY BE USED
Upon your instructions to do so, www.IHaveaPlanIowa.org will use
your PII to complete the following forms and surveys, to obtain
information for you, and to effect transactions on your behalf:
- Complete financial aid applications
- Complete financial aid calculators
- Complete a scholarship search
- Complete Your Plan of Study, which can assist you in selecting
courses and otherwise planning to meet admission requirements
- Communicate your requests for information or material to
colleges or other institutions you have specified
- Complete applications for admission to educational
institutions
- Complete applications for Work-Based Learning
opportunities
Your PII and Automatically-Collected Information may also be
used for the following purposes:
- We may use your PII and Automatically-Collected Information to
help diagnose problems with the www.IHaveaPlanIowa.org server and
to administer www.IHaveaPlanIowa.org.
- We may use your PII and Automatically-Collected Information to
customize and tailor your experience using www.IHaveaPlanIowa.org,
displaying content on www.IHaveaPlanIowa.org that we think you
might be interested in and according to your preferences (but we do
not track your activity across multiple websites for the purpose of
serving targeted advertising to you).
Summary data consisting of a compilation of de-identified and
aggregate data representing www.IHaveaPlanIowa.org users may be
collected by XAP and provided to various entities including
colleges and other educational institutions represented on
www.IHaveaPlanIowa.org. NO PII IS MADE AVAILABLE AS PART OF THESE
SUMMARY REPORTS. Some examples of summary data are the number of
monthly visitors to www.IHaveaPlanIowa.org, the number of admission
applications submitted over www.IHaveaPlanIowa.org, and the
www.IHaveaPlanIowa.org functions utilized by students in specified
age or grade ranges.
WITH WHOM PERSONALLY IDENTIFYING INFORMATION AND
AUTOMATICALLY-COLLECTED INFORMATION MAY BE SHARED
Except as set forth below, PII you enter on
www.IHaveaPlanIowa.org is not made available or distributed to
third parties, except with your express consent or at your express
direction. In particular, XAP will not give, sell, rent, trade,
transfer, otherwise provide or provide access to your PII to any
company, individual, or organization for its use in marketing or
commercial solicitation or for any other purpose, except with your
express consent and at your direction, unless it is pursuant to one
of the exceptions listed below or necessary for operation of
www.IHaveaPlanIowa.org.
We may share your PII as follows:
- School Administration and Staff. Your account is meant
to help you set goals and plan for the future. If you connect your
account to a school or other site using www.IHaveaPlanIowa.org as
part of a career and education planning program, then professional
staff at that school or site designated by the administration of
the school or site to have access to the www.IHaveaPlanIowa.org
Professional Center will have access to view (i) your
www.IHaveaPlanIowa.org portfolio, including your PII that is part
of your portfolio, (ii) email communications to and from you
through www.IHaveaPlanIowa.org, (iii) and all other PII and other
content that you add to www.IHaveaPlanIowa.org as part of your
portfolio. This access is granted to these professional users so
that they may assist you in a guidance capacity with your career
and education planning.
- Parents and Guardians. You may request that
your parent or legal guardian be given permission to view your
portfolio (including all PII and other content that you add to
www.IHaveaPlanIowa.org as you use www.IHaveaPlanIowa.org). And if
you do make this request, your parent or legal guardian will be
granted access to your portfolio and may view all of your PII
associated with your portfolio.
- Bridges Transitions Inc. XAP Corporation and
Bridges Transitions Inc. reserve the right to share PII with one
another (regardless of which entity first collected the
information) in connection with the maintenance and operation of
www.IHaveaPlanIowa.org and for use in accordance with this
Statement.
- As Directed by You. Any time you request that
we perform a task that involves a transfer of PII, the PII related
to the performance of that task will be made available to a
recipient you designate. For example:
- If you submit an application for admission to a college or
other educational institution, the PII required to complete that
application and any other PII you entered onto the application will
be provided on your behalf to the admissions office of the
institution to which you are applying.
- If you request that a college or other educational institution
send you material, your contact information will be provided to
that institution so the institution can send you material and
contact you.
-
Note: If you begin an application for admission to a
college or other educational institution, your name and other PII
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 institution may
then contact you regarding your potential attendance.
- Required by Law. When required by law to
comply with any valid legal process such as a statute, regulation,
search warrant, subpoena, or court order, XAP may supply PII
contained in your www.IHaveaPlanIowa.org account as XAP reasonably
determines, based on the advice of counsel, it is legally required
to supply. XAP may also disclose PII in emergency situations, to
protect your safety or the safety of others, to defend against
legal claims, to enforce XAP's contractual or other rights, or to
take actions regarding illegal activities or suspected fraud.
- Merger, Acquisition, or Sale of XAP. XAP may
transfer your PII and Automatically-Collected Information to
another entity if XAP is involved in a merger, acquisition,
reorganization, restructuring, or other sale or transfer of all or
any portion of its assets or business. In this event, we will, if
allowed, use reasonable efforts to notify you when your information
is transferred to a third party (this notification may be made via
email to you or by posting a prominent notice on
www.IHaveaPlanIowa.org). Unless you consent otherwise, XAP will
contractually require any successor to treat your PII in accordance
with the promises made in this Statement, even after the transfer.
But any information you provide after the transfer will likely be
subject to a new privacy statement, and you should review that
statement.
- Third-Party Payment Processor. We use a
third-party intermediary to manage payment processing when you
submit payment to apply to an educational institution through
www.IHaveaPlanIowa.org. This intermediary is not permitted to
store, retain, or use your financial information or other PII,
except for the sole purpose of processing payments you
initiate.
- Third-Party Service Providers. We may share
Automatically-Collected Information with our third-party service
providers who assist us by performing services related to our
operation of www.IHaveaPlanIowa.org (such as hosting, data storage,
and security). Such third-party service providers are not
authorized to use your information in any way other than as
described here and are required to keep the information
confidential.
- Third-Party Analytics Services. We may use
third-party analytics services to assist us in better understanding
our www.IHaveaPlanIowa.org users. For example, we use these
services to track and analyze certain Automatically-Collected
Information, such as feature usage. We only ever provide these
service providers with (or allow these service providers to collect
on our behalf) Automatically-Collected Information. We use the
information collected from these service providers to make
www.IHaveaPlanIowa.org better and easier to use. The information we
receive from these third parties may be re-associated with your PII
after we receive it back from these third parties. These third
parties are not authorized to use the information in any other way
and are required to keep it the information confidential.
SECURITY MEASURES TO PROTECT INFORMATION; DISCLAIMER
XAP uses industry standard physical, electronic, and procedural
security measures to protect against the loss, misuse, and
unauthorized access, disclosure, alteration, and destruction of PII
and Automatically-Collected Information we collect and store. For
example, www.IHaveaPlanIowa.org encrypts the PII you enter when it
is in route from your browser to the www.IHaveaPlanIowa.org 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.
www.IHaveaPlanIowa.org is WC3 compliant and performs properly on
all major operating system platforms as well as all major modern
internet browsers specifically including, but not limited to,
Windows, Macintosh, Linux, iOS, Chrome, Safari, Firefox, Edge,
Internet Explorer, and the build-in Internet browsers for iOS and
Android.
PII residing on the www.IHaveaPlanIowa.org 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 www.IHaveaPlanIowa.org system or to provide
requested customer support to users of www.IHaveaPlanIowa.org. Each
XAP employee who has access to the PII residing on the
www.IHaveaPlanIowa.org server has agreed in writing to respect the
privacy of all such PII. XAP trains employees to protect customer
information and only authorize 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 permission; we may
disable access to your account in order to prevent an unauthorized
third party from accessing your account.
While we take industry-standard security measures to protect the
privacy of your PII, we cannot guarantee that your PII will never
be compromised. No Internet or wireless network transmission is
ever 100% secure, and no security system can prevent all security
breaches. We do not and cannot guarantee that there will be no
unintended disclosures of your PII or that unauthorized third
parties will not defeat our security measures or use nonpublic
information for improper purposes.
COOKIES
We collect and store Automatically-Collected Information through
a standard feature found in browser software called a "cookie." A
cookie is a small file that a website transfers to a user's
computer or other operating device, which may then be stored on the
computer's or operating device's hard drive. www.IHaveaPlanIowa.org
uses cookies to remember you and personalize your web-viewing
experience by keeping track of your session when using
www.IHaveaPlanIowa.org. Cookies enable you to maintain continuity
as you move from page to page on www.IHaveaPlanIowa.org and to
avoid the nuisance of being asked to provide the same information
repeatedly. Cookies also allow us to make sure that only your
browser can exchange information regarding your account with our
servers. Cookies also provide us Automatically-Collected
Information about www.IHaveaPlanIowa.org features used and
activities conducted while using www.IHaveaPlanIowa.org. We may use
cookies to aggregate data about user traffic on and user
interaction with www.IHaveaPlanIowa.org so we can offer better
experiences and tools in the future. The cookies we use are called
session cookies, meaning they are set when you use
www.IHaveaPlanIowa.org and are erased when you end your session on
www.IHaveaPlanIowa.org or completely close your browser. The XAP
cookies we use do not remain on your hard drive after you end your
session on www.IHaveaPlanIowa.org or completely close your
browser.
Third-Party Cookies
We use third-party services provided by Google Analytics to
track and analyze your www.IHaveaPlanIowa.org activity. In order to
gather this Automatically-Collected Information, we use a Google
Analytics cookie on www.IHaveaPlanIowa.org. 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/
We also have third-party widgets on www.IHaveaPlanIowa.org, such
as widgets provided by YouTube, PollDaddy and Screencast. When you
use these third-party widgets by using features of our site, the
widgets may place cookies associated with these widgets on your
computer or other operating device.
Don't want cookies?
Most browsers are initially set to accept cookies. If you don't
want cookies, you can set your browser to disable or refuse cookies
or to alert you when cookies are being used. Please refer to your
browser for information on how to disable and control cookies. You
should note, however, that various www.IHaveaPlanIowa.org services
and features might not function properly when cookies are not
utilized.
LINKS
www.IHaveaPlanIowa.org 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 but not limited to visiting an official
college website. These sites and resources have privacy statements
that may differ from that of www.IHaveaPlanIowa.org, 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 or otherwise continuing to use that website. XAP is
not responsible for the privacy practices or the content of any
websites to which www.IHaveaPlanIowa.org links or for the conduct
of persons operating those websites. XAP does not have control over
such external sites and resources. XAP shall not be liable for any
content, advertising, products, or other materials on or available
from such sites or resources. In addition, XAP shall not be
responsible or liable, directly or indirectly, for any damage or
loss caused or alleged to be caused by or in connection with use of
or reliance on any such content, advertising, products, or
materials on or available through any such site or resource.
MODIFYING YOUR INFORMATION
You may update on www.IHaveaPlanIowa.org any PII you previously
provided. To modify PII: (i) Sign in to www.IHaveaPlanIowa.org,
(ii) access either your account or an application containing the
information you want to change, (iii) modify that information using
standard word-processing techniques, and (iv) save the change. If
you want to remove PII that is in a required field, you will need
to contact XAP at 1-800-GO-TO-XAP (1-800-468-6927) and request that
your account be deleted. XAP will respond, when permitted by law,
within thirty (30) days.
Please recognize that if you delete information, it will
no longer be available on www.IHaveaPlanIowa.org. Similarly, when
accessed over www.IHaveaPlanIowa.org, PII that has been updated or
otherwise modified will appear in its then-current form, rather
than in the form in which it may have been submitted at some
earlier time.
RETENTION, DELETION AND STORAGE
We retain all PII and Automatically-Collected Information in our
databases to fulfill the purpose for which the information was
collected.
Data Deletion
While your educational institution or organization maintains a
license to usewww.IHaveaPlanIowa.org, your account will be retained
by XAP for five (5) years following your last log in. After five
(5) years of inactivity your account will be permanently deleted
pursuant to XAP's data deletion policy. If you wish to have your
account deleted earlier than following five (5) years of
inactivity, you may contact XAP at 1-800-GO-TO-XAP (1-800-468-6927)
and request that your account be deleted. XAP will respond to your
request, when permitted by law, within thirty (30) days.
If use of www.IHaveaPlanIowa.org is terminated by your
educational institution or organization, your account will be
retained for two (2) years. Should your educational institution or
organization decide to renew their www.IHaveaPlanIowa.org license
during that two (2) year period, your account and all related
information will be available to you. At the end of the two (2)
year period, all www.IHaveaPlanIowa.org accounts will be
permanently deleted pursuant to XAP's data deletion policy.
Notwithstanding the above policies, upon termination of an
agreement, or otherwise at the discretion of aneducational
institution or organization licensing www.IHaveaPlanIowa.org, the
educational institution or organization may request that XAP delete
all accounts. XAP will permanently delete all accounts, as
directed, within thirty (30) days of receipt of the request.
Note that if you have chosen to submit data to a postsecondary
institution XAP is unable to delete or otherwise retract that
information from the receiving institution.
Following deletion of your account, XAP may maintain anonymized
or aggregated data, including usage data and
Automatically-Collected Information, for analytics purposes
only.
AMENDING THIS PRIVACY STATEMENT
XAP may amend this Privacy Statement from time to time. We will
post any new Statement here, and you should review this Statement
regularly to make sure you are aware of its terms. You can
determine if this Statement has been revised since your last visit
to www.IHaveaPlanIowa.org by referring to the "last updated" date
at the top of this Statement. If XAP makes any substantial changes
to this Privacy Statement, XAP may also notify you (i) by posting a
message on the www.IHaveaPlanIowa.org homepage for at least thirty
(30) days; or (ii) by providing direct notice to you via your
contact information or by requiring that you agree to the revised
Statement to next time you log into your account on
www.IHaveaPlanIowa.org. Once posted to
www.IHaveaPlanIowa.org, the new Privacy Statement will apply to all
data previously submitted and subsequently submitted to
www.IHaveaPlanIowa.org, unless such use is prohibited by
law.
UNENFORCEABILITY
If any part of this Statement is determined to be invalid,
illegal, or unenforceable under applicable law, then the invalid,
illegal, or unenforceable provision will be deemed to be superseded
by a valid, legal, and enforceable provision that most closely
matches the intent of the original provision, and the remainder of
this Statement will continue in full force and effect.
QUESTIONS?
If you have any questions about this Privacy Statement and the
privacy practices on this site, you may contact us at support@xap.com.