PrivateFolio LLC
Privacy Policy
Last Updated: July 15, 2015
Welcome to PrivateFolio!
We know that you care how information about you is used and shared, and we appreciate your trust that we will do so carefully and sensibly. This Privacy Policy discloses the privacy practices and policies of PrivateFolio LLC (“PrivateFolio”, “we”, “us” or “our”) for www.PrivateFolio.com and its sub-domains (the “Website”) and all related tools and services, including any downloadable applications, we make available to you from time to time (the “Services”). The Services include our on-line platform to solicit, upload, manage, and deliver academic and professional credentials and other documents that may be useful for applications, professional advancement, and other opportunities.
This Privacy Policy covers information that we collect through the Website and our Services, as well as information that we collect about you when our Services are used, whether you are a Candidate, a Reference, a Recipient (as each is defined in the Terms of Service) or simply a visitor to our Website. This policy does not apply to the practices of companies that PrivateFolio does not administer, including Recipients, or to individuals that PrivateFolio does not employ. PrivateFolio is not responsible for how Recipients or other users collect or use information when you interact with them. You should always review, and if necessary adjust, your privacy settings on any applicable third-party websites and services that you connect to in connection with our Services. Your access and use of the Services is subject to this Privacy Policy and to our separate Terms of Service https://www.privatefolio.com/terms_of_service. Capitalized terms used but not defined in this Privacy Policy have the meaning assigned to them in the Terms of Service.
PrivateFolio enables you to submit or otherwise deliver your Dossiers to third party Recipients. References may use our Services to submit letters of recommendation on behalf of Candidates. PrivateFolio acts as an intermediary for Candidates to communicate with References and Recipients, and we will not provide your Dossier with third parties unless you tell us to do so. More generally, you control your Personal Information on our Services, and we will not share your personal information with a third party unless you tell us to do so and as set forth in this Privacy Policy.
If you choose to submit your Dossier to a third party, such information may be transferred to the Recipient by PrivateFolio or through a third party delivery service. After your information has been transferred to a Recipient, your information subject to only those privacy protections that the Recipient has committed to. Thus, absent express limitations, a Recipient uses your personal information in other ways that are not described in this Privacy Policy.
Notice of Information We Collect And How We Use It.
Our primary purpose in collecting Personal Information (as defined below) is to provide you with a safe, smooth, efficient, and customized experience using our Services. This allows us to provide services and features that most likely meet your needs, and to customize our Services to make your experience easier and more productive. "Personal Information" means information that specifically identifies an individual (such as a name, address, or e-mail address, etc.) or other information about that individual that is directly linked to Personal Information. Personal Information does not include "aggregate" information, which is data we collect about the use of our Services that PrivateFolio does not use to identify such individual. We collect and store information, including Personal Information, that you provide to us when registering or when using the Services. Some such information is required in order for you to register as a user of our Services. You can choose not to provide us with certain information, but by doing so, you may not be able to take advantage of many of our features and functionality. We use Personal Information to deliver the Services to you, to improve the delivery of our Services, which may include advertising, and to develop analytics and aggregated data that allow us and our partners to improve our Services and correspond with you.
We also collect and store non-personally identifiable information that is automatically generated when you use the Services. We use this information to do internal research on our users’ demographics, interests, and behavior to better understand, protect and serve you and our community.
In general, our collection and use of information is as follows:
• PrivateFolio collects Personal Information you knowingly choose to submit to us during registration, such as your name, and email address, which we use for the following general purposes: identification and authentication of a user, improvement to the Services, contact, research, and reporting of aggregated, anonymous data.
• PrivateFolio collects Personal Information about the products and services you purchase through our Services;
• PrivateFolio automatically receives and records information on our server logs from your browser, including your IP address, cookies, and the pages you request. IP addresses are automatically reported by your browser each time you view a web page. Your IP address is stored by PrivateFolio when you register with PrivateFolio. IP addresses may be used for various research purposes, and/or delivering unique functionality to our service.
• We may allow users to post content on the Services such as Candidate Portfolios. Content that you post to such public areas at your own risk.
Cookies
By using our Services, you indicate your consent for PrivateFolio and our affiliates to send cookies to your computer in order to uniquely identify your browser and improve the quality of our services; you may turn off cookies in your browser though, in doing so, some or all of our Services may not work. A “cookie” is a piece of alphanumeric data stored on a visitor’s hard drive that enables us to improve your access to our Website and identify repeat visitors to our Services. We use the non-personally identifiable information, such as your browser version, IP address, referring domains, pages visited, your mobile carrier, device and application IDs, the nature of your use of the Website and cookie information, to improve our Website delivery, including advertising, and to develop analytics and aggregated data that allow us and our partners to utilize our Service and reach out to you via our Services or otherwise. If you wish to restrict or block the cookies which are set by PrivateFolio, or by any other website, you can do this through your browser settings. The Help function within your browser should tell you how to do so. For information on how to delete cookies on the browser of your mobile phone as applicable you will need to refer to your handset manual.
Some of our business affiliates (e.g., advertisers, helpdesk provider) may use cookies on our Website. Additionally, we have no access to or control over these cookies used on third party websites or links. The acceptance and storage of cookies can be managed through your browser’s security settings.
Log Files
Like many websites, we may automatically gather certain information about our Website traffic and store it in log files. This information includes Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information, which does not identify individual users, to analyze trends, to administer the Website, to track users’ movements around the Website and to gather demographic information about our user base.
We may link this automatically collected data to Personal Information for the purpose of preventing fraud and to better understand our customers’ use of the site.
We may use a third-party tracking service that uses log files and cookies, see below, to track non- Personal Information about visitors to the Website in the aggregate. This service captures usage, location, and volume statistics to help us better understand trends in site usage. We may use a third-party tracking service that uses log files and cookies, see “Notice of Information We Collect and How We Collect It” above, to track non- Personal Information about visitors to the Website in the aggregate. This service captures usage and volume statistics as well as geographical location data to compile usage reports and maps for optimization and troubleshooting purposes. We will not support “do not track” signals or other mechanisms except as expressly provided on our Website from time to time.
Clear Gifs (Web Beacons/Web Bugs)
We may employ, and our third party advertising partners may employ, a software technology called clear gifs, also referred to as web beacons or web bugs, that help manage content on the Website by tracking what content is effective. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of Web users. In contrast to cookies, which are stored on a user’s computer hard drive, clear gifs are embedded invisibly on Web pages and are about the size of the period at the end of this sentence. We may tie the information gathered by clear gifs to our customers’ personally identifiable information.
We may use clear gifs in our HTML-based emails to let us know which emails recipients have opened. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns. If you would like to opt-out of these emails, please see “Choice and Opt-out.”
Mobile Use
If you visit or use our Website on a mobile device, we may collect information from your device, including device ID, your mobile carrier, and your physical (GPS) location. We may store and use that information for security purposes (for example, for user verification) or for other marketing and research purposes. We do not share your location information with third parties. Depending on your device, you may turn off location services by going to your device settings.
Once you have established your account on your mobile device or computer, we collect information we receive from your mobile device or computer, such as your device’s type, number and the serial number of its chip. We also collect all payment card and transaction information, as described under “Notice of Information We Collect And How We Use It” above.
Use of the Website on a mobile device may allow your mobile carrier or other access provider to view data that appears on the device as a result.
Information We Collect To Respond To Your Choices and Requests
Registration.
In order to use many of our Services, you must first complete the registration form and provide an email address and password (“Login Credentials”). During registration, you are required to complete the registration form and create a user name and password and are required to give truthful contact information (such as name and email address) in accordance with our Terms of Service. We use this information to contact you about the Services in which you have expressed interest.
We may combine the information you submit under your account with information from other services or third parties in order to provide you with a better experience and to improve the quality of our Services. For certain services, we may give you the opportunity to opt out of combining such information.
Interactions with Other Websites and Services.
We may permit you to log in to our Services using sign-in services such as Facebook Connect, or other similar services. These services will authenticate your identity and provide you the option to share certain personal information with us (such as your name and email address) to pre-populate our sign-up form. Services like Facebook Connect also give you the option to post information about your activities on the Services to your profile page to share with others within your social network.
If you log in with Facebook Connect or another similar third-party service, we may use the information we receive from such third party to populate your PrivateFolio Platform profile.
Public Profiles
If you choose to create a public profile on the Website, we may collect other users’ comments about you in any feedback area.
Orders; Billing Account
If you purchase or subscribe to a fee-based Service or other products or services from us, we request certain Personal Information from you on our transaction form. We may require you to provide contact information (such as name, email, and shipping address) and financial information (such as account number, expiration date if paying through a third party payment processing service). We may use an outside payment processing company to bill or process payments for goods or services.
We use this information for billing purposes and to fill your orders. If we have trouble processing an order, we will use this information to contact you.
Surveys or Contests
We may provide you the opportunity to participate in contests or surveys on our Services. If you participate, we will request certain Personal Information from you. The requested information typically includes contact information (such as name and mailing address) and demographic information.
We use this information to notify contest winners and award prizes, to monitor site traffic, or to personalize our Services (in the case of anonymous information collected in surveys).
We may cooperate with third parties to offer you surveys, contests, products and services through our Services. When you participate in such surveys or contests, or purchase related products and services, you authorize us to share information about you, including Personal Information, with such third parties. If you have any questions or concerns regarding how such third parties use your information, please consult the applicable third party’s privacy policy. You agree that we will not be responsible or liable for any loss or damage incurred in connection with our cooperation with such third parties, their activities on our Services, and the sharing of your information with such third parties.
Tell-A-Friend
If you choose to use our referral service to tell a friend about our Website, we will ask you for your friend’s name and email address. We will automatically send your friend a one-time email inviting him or her to visit the Website. PrivateFolio stores this information for the sole purpose of sending this one-time email and tracking the success of our referral program.
Your friend may contact us at help@privatefolio.com to request that we remove this information from our database.
Information We Collect From Third Parties About Users
If you provide us with Personal Information about others, or if others give us your personal information, we will use that information only for the specific reason that it was provided to us. We will not share a user’s Personal Information with a third party without such user’s permission. If you are a Reference, a Candidate may provide us your name and email address. We will consider any Personal Information about you collected as part of the registration process to be your Personal Information.
Registered Users may also submit Confidential Dossier Information about Candidates, including letters of recommendations by References as part of a Candidate’s Dossier (such information is “Confidential Dossier Information”). References who provide the Confidential Dossier Information hereby acknowledge that such information is the Personal Information of the applicable Candidate, and the Candidate will be the party controlling that information, even though it may contain information about the Reference. Notwithstanding the foregoing, a Candidate will not be able to see Confidential Dossier Information about him or her but will be able to direct the disclosure to certain Recipients. The Reference providing Confidential Dossier Information may be able to see the Recipient to which Candidate directs such Confidential Dossier Information.
Communication from Us or our Services
We will send emails in response to, or concerning, services that you have requested (for example, asking you to confirming an upload request we have received for your account, notifying you that a delivery has shipped, providing a receipt for payment, etc.). Because these communications are essential for providing services requested by users, you may not opt-out of these communications. However, if you do not wish to receive them, you have the option to deactivate your account or to not use the associated services.
Service-Related Announcements
We will send you strictly service-related announcements on rare occasions when it is necessary to do so. For instance, if our Service is temporarily suspended for maintenance, we might send you an email.
Generally, you may not opt-out of these communications, which are not promotional in nature. If you do not wish to receive them, you have the option to deactivate your account.
Customer Service
Based upon the Personal Information you provide us, we will send you a welcoming email to verify your username/email and password. We will communicate with you in response to your inquiries, to provide the services you request, and to manage your account. We may communicate with you by email, and you may contact customer service at help@privatefolio.com.
Profile
We may store information that we collect through cookies, and log files, and/or clear gifs, and/or third party sources to create a “profile” of your preferences. We may tie your Personal Information, or your purchasing history, to information in the profile, in order to provide tailored promotions and marketing offers and to improve the content of the Website for you.
We share your profile with third parties in aggregate form only.
ID and Address Verification
We may use third party software to verify your identity and address, in order to confirm your billing information and identity, and we may use third party software to verify the email address and physical address of those to whom you request to deliver materials.
Enhancement of Profile Information
We may purchase marketing data from third parties and add it to our existing user database, to better target our advertising and to provide pertinent offers in which we think you would be interested. To enrich our profiles of individual customers, we tie this information to the Personal Information they have provided to us.
Conditions Under Which We Share Information
Aggregate Information (Non-Personally Identifiable)
We may share aggregated demographic information about our user base with our affiliates, such as those who help us provide certain services to you or those who may want to provide services. This information does not identify individual users. Affiliates may include analytics services that help us understand our users base or mailing services that help us deliver documents.
Information you choose to display in your public profile may also be aggregated and made publicly available.
Except as discussed in this Privacy Policy, we do not share Personal Information with third parties.]
Agents
We use an outside shipping company to fulfill mail orders, and a credit card processing company to bill you for goods and services. These companies do not retain, share, store or use Personal Information for any other purposes. Your interaction with any third party payments service, such as PayPal or Authorize.net, is subject to the terms and conditions provided by such third party.
Helpdesk
We use cloud-based customer support software provided by a third party (Freshdesk) to help us deliver customer support to our users. Freshdesk may record user level data such as email address and customer service inquiries. However, Freshdesk has no direct relationship with the individuals whose personal data it processes, and information collected by Freshdesk will never be sold to or shared with other companies or organizations for commercial purposes or as otherwise outlined in the Freshdesk Privacy Policy (http://freshdesk.com/privacy).
Service Providers
We use other third parties to provide mailing services purchased through our Website. When you sign up for delivery of documents via the mail delivery, we will share information regarding the materials you are sending and the address you are sending them to as necessary for the third party to provide that service.
In addition to the above, we may share your Personal Information in situations described below:
- We may collect and share Personal Information made available by users on their Portfolio.
- We may release your Personal Information to authorized agents who are employed by us to perform tasks on our behalf and need to share information with them to provide products, services and offers to you.
- We believe it is necessary to investigate potential violations of our Terms of Service, to enforce the Terms of Service, to comply with law or to protect ours or others rights, property, or safety.
- If we or our business are acquired, your non-personal information and your Personal Information would be transferred to the buyer as part of that transaction, provided that the conditions of this Privacy Policy would continue to apply.
Third Party Advertisers
Currently we do not disclose Personal Information for direct marketing purposes to any third parties, nor do we have plans to do so. However, in order to request a confirmation that we have not disclosed your Personal Information to any third parties for the purpose of direct marketing, please send an email to help@privatefolio.com or write to us at: PrivateFolio LLC , 2336 Wisconsin Ave NW #32358, Washington DC 20007 or call us at the following toll-free number: (855) 976-1245. We are only required to respond to one request per customer each year.
The ads appearing on our Services are delivered to users by our advertising partners. We share Website usage information about users with our advertising partners for the purpose of targeting our Internet banner advertisements on our Website.
Our advertising partners may use cookies and clear GIFs on our Services, which allows them to recognize a user’s cookie when a user visits the Website or Services. The information that our advertising partners collect and share through this technology is not Personal Information.
For more information about our third-party advertisers, or to learn more about the choices available to you regarding this anonymous information, please contact help@privatefolio.com.
Other Third Parties
The core services that we provide enable you to deliver documents to third parties such as universities and other organizations that may be entertaining applications for employment. We only share documents that you explicitly request be sent to such parties. Because these documents may contain confidential letters of recommendation and educational records such as transcripts their use may be governed by the Family Educational Rights and Privacy Act (FERPA). As such, we include the following notice to all parties to whom you have documents delivered: “note that under the Family Educational Rights and Privacy Act (FERPA) you have a legal responsibility as a staff or faculty member to maintain the confidentiality of educational records in your possession.” Also, for any confidential letters of recommendation that you solicit through our Website, we require you to waive all rights of access to the letter otherwise provided by the Family Educational Rights and Privacy Act.
Legal Disclaimer
We reserve the right to disclose your Personal Information as required by law and when we believe that disclosure is necessary to protect our rights; to comply with a judicial proceeding, court order, or legal process served on us or the Website; or in connection with an actual or proposed corporate transaction or insolvency proceeding involving all or part of the business or asset to which the information pertains.
Choice and Opt-out
In general, we will only contact you via email, and only in response to, or concerning, a service that you have requested. Because these communications are essential for providing services requested by users, there is no option to opt out of these communications. For certain emails, such as the delivery of application documents, if the recipient believes the email was sent in error, there is a link in the email that will allow the recipient to register this error.
Access to or Changing Your Information.
If your Personal Information changes you may correct, update, or delete it by making the change on your “My Account” page or by updating or deleting documents contained in your “Portfolio” and “Dossier.” We will normally retain your account information even if you have not renewed your account. However, if you would like us to permanently delete your account information you may request that we do so by emailing our Customer Support at help@privatefolio.com and, to the extent permitted by law, we delete your account information within 30 days.
Please keep in mind that whenever you voluntarily make your Personal Information or other private information available for viewing by third parties online – for example on your Portfolio – that information can be seen, collected and used by others besides us. We cannot be responsible for any unauthorized third-party use of such information.
You may not be able to access Confidential Dossier Information submitted to the Services about you. References or other Registered Users who have provided us with Confidential Dossier Information, may not be able to control this information once it has been submitted to our Website or to whom it is disclosed. However, you may be permitted to request its deletion by contacting us. Such a request will not affect any previously disclosed information.
Third party links.
Our Website may contain links to other third party websites. These third party websites have separate and independent privacy policies. We have no responsibility or liability for the content and activities of these linked sites. This Privacy Policy applies only to information collected by the Services. Nonetheless, we seek to protect the integrity of our Services and welcome any feedback about these websites.
Information You Post to Other Sites
Please keep in mind that whenever you voluntarily make your Personal Information or other private information available for viewing by third parties online - for example on blogs, discussion forums, or other community posting or social networking sites - that information can be seen, collected and used by others besides us. We cannot be responsible for any unauthorized third-party use of such information.
Information Security
PrivateFolio is committed to protecting the security and privacy of your information stored by us. All data gathered on our Website is stored by us in a secure, password protected database. Only we and our hosting provider have access to this database. We will protect Personal Information by reasonable security safeguards against loss or theft, as well as unauthorized access, disclosure, copying, use or modification. While all standard security protections are implemented by us and our hosting providers, we cannot guarantee the physical or electronic security of the servers and databases on which this Website is hosted. We require our partners who receive your information to agree to security requirements consistent with this Privacy Policy.
Important Note for Visitors from Outside the United States
The Services are intended to be used by consumers in the United States. Any personal or other information that is collected through the Services is transferred to and processed in the United States for the purposes described above. PrivateFolio also may subcontract the processing of your data to, or otherwise share your data with, affiliates or third parties in the United States or other countries. The data-protection laws in these countries may be different from, and less stringent than, those in your country of residence. By using the Services, you expressly consent to such transfer and processing.
Minors
Our Services are not directed to people under 13 years of age. If you become aware that your child has provided us with Personal Information without your consent, please contact us at help@privatefolio.com. We do not knowingly collect Personal Information from children under 13. If we become aware that a child under 13 has provided us with Personal Information, we take steps to remove that information and terminate the applicable account.
Terms of Service
Please also visit our Terms of Service, establishing the use, disclaimers, and limitations of liability governing the use of our Website and Services.
Your Consent
By using the Website or our Services, you consent to our latest Privacy Policy.
Changes to our Privacy Policy
We may update this Privacy Policy to reflect changes to our information practices. If we make a material change to our Privacy Policy that will retroactively apply to information that we have collected from you, we will notify you at the e-mail address specified in your account (if any) and by means of a notice posted on our Website. We encourage you to periodically review the Privacy Policy posted on our Website for the latest information about our privacy practices. We will treat your continued use of the Services following such notice as your acceptance of the changes. However, to the extent required by law, we will seek your consent prior to applying material changes to this Privacy Policy. If you have questions or concerns regarding our Privacy Policy, please contact us at: help@privatefolio.com.
Contact Us
If you have any questions or suggestions regarding our privacy policy, please contact us at:
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