Higher Ed Points Program – Privacy Policy

Committed to Your Privacy

Higher Ed Points Inc., the administrator of the Higher Ed Points Program (the “Program”), takes your privacy seriously. Our privacy policy is to disclose to you what information we may gather and how we may use it, give you choice over what personal information we use for different purposes, other than statutory requirements, and provide you access to the information we have in order to allow you to review or correct your information as appropriate. This policy is our commitment to your privacy. We have adopted and subscribe to the privacy principles of the Canadian Personal Information Privacy and Electronic Documents Act. Please read the following policy to understand how your personal information will be treated as you make full use of our Program and its many evolving offerings.

We continue to expand our service offerings to the public and the technology we use continues to change. But, no matter how our business changes, we will always do our best to protect your privacy. This policy will be reviewed for appropriateness from time to time as our users and requirements change, and therefore this policy may change from time to time, so please check back periodically.

What Information We Collect:

Like most organizations, we collect and use personal information about our customers and visitors to our website(s). Personal information means any information about an identifiable individual. We collect your personal information online to provide you with the most personalized web experience possible, and from you directly through our interactions with you at our site(s). Our aim is to provide you with relevant services, and the information we gather is used to that end.

Personal information will only be collected by fair and legal means. Our collection of personal information will be limited to that necessary for the purposes we have identified to you. You will be asked for your consent to the collection and use of your personal information. By your continued use of our website, products and services, and provision of your personal information, you are deemed to continue to provide your permission to this collection and use of information for the purposes set out herein.

Information collected may include: contact information such as your name, phone number(s), email address, birth date, educational or other participating institution name/address, student or loan account number, and information related to the type of service(s) being offered in the Program.

How we use the information we collect:
We collect information from you directly through our website(s).

We collect information in order to:

(a) verify your identity, to contact and to communicate with you;
(b) answer your questions about registration, the Program and any Higher Ed Points service offered;
(c) manage and administer the Program, including the administration of the member’s account;
(d) manage and process requests for the conversion of points (or other reward accumulation) and transfer of monetary value to a designated account at an educational or other participating institution, and for other services which may be obtained in the Program;
(e) communicate with you regarding Program information and offers;
(f) have a better understanding of your preferences, needs and interests;
(g) develop, enhance, market and/or provide products and services to meet those needs;
(h) offer and to allow our partners to offer you rewards, benefits, products, goods and services under the Program and related programs;
(i) enable you to participate in promotions and contests; and
(j) obey the laws and regulations in force and ensure the security and processing of information.

In addition, from our website, we collect information such as statistics, domain names and/or IP addresses to help diagnose technical problems, administer our website and to provide you with information on products or services that might be of interest to you.

We retain the content of emails that you send us, your email address, and our responses, in order to manage the services provided to you and address any questions you may have.

We use the contact information and areas of interest information, as appropriate, in the normal course of our business to build your account with us, send you requested information, provide you with our products or services, personalize the delivery of site content to you or contact you when necessary. Personal information is required in order to identify you as a member or customer and to provide you with access to our products and services and other products and services we feel might be of interest to you.

In order to provide you with the services you request and with our best service, it may be necessary for us, and our affiliated loyalty program suppliers and/or our Participating Institutions, to share the personal information you have provided with each other. Also, this site has several necessary technological suppliers who assist in providing the services or products associated with this site. As part of the operations of the site, these companies may have access to your personal information.

Personal information is processed and stored in secure and confidential databases in Toronto, Ontario.

Aggregate data

We may also use personal information and data collected to generate statistics and aggregate reports for internal use, such as new product development and marketing, and for sharing with affiliates, subsidiaries, licensees, content suppliers, successors and advertisers. These statistics and aggregate reports will not contain any personally identifiable information; your identity is kept anonymous.

Cookies

Cookies are pieces of information that a website transfers to your computer’s hard drive for record-keeping purposes. Our use of cookies allows us to personalize your online interaction with us by alerting you to information, products or services we think would be of interest to you. The use of cookies is an industry standard and many major websites use them to provide useful features to their customers. Cookies in and of themselves do not personally identify users, although they do identify a user’s computer. With most Internet browsers you can erase cookies from your computer hard drive, block all cookies, or receive a warning before a cookie is used. Please refer to your browser instructions or help screen to learn more about these functions.

Limiting the Use of Information

We will not use personal information for purposes other than those for which it is collected, for legitimate practices, or for uses consistent with previous uses or with specified purposes, except with your consent or as required by law. We will retain personal information only as long as is necessary for the fulfillment of the purposes for which it was collected or as a requirement for government and/or legislative purposes. Further we will not use or share the personal information provided to us in ways unrelated to the purposes for which it was collected or to legitimate practices, without also providing you with an opportunity to opt-out or otherwise prohibit such unrelated uses. You may withdraw your permission at any time after you have given it, provided that there are no contractual restrictions or legal requirements to prevent this.

From time to time, we will notify users of new products, services and partnerships. If you do not wish to receive marketing or promotional communications in electronic, printed or verbal format, simply send us an e-mail at unsubscribe@higheredpoints.com with “Unsubscribe” in the subject line.

Disclosing Information Collected

We may disclose personal information without your consent where such disclosure is required by law, regulation or government request, required to comply with a warrant or court order, is related to an offence that has been or is about to be committed, is required due to an emergency, is made for the purpose of collecting a debt owed by you, is made to our lawyers or other agents in the course of representing us, is protecting our rights or property and that of our users, partners, agents, suppliers, licensors or merchants, or is necessary or appropriate to site operation.

Business Transfers

As we continue to develop our business, we may acquire additional companies. In such transactions, customer information is generally one of the transferred business assets. Also, in the unlikely event that we transfer substantially all of its assets, customer information will be one of the transferred assets.

Safeguarding Information

We have security measures in place to protect the loss, misuse and alteration of the information under our control. We have adopted appropriate safeguards to ensure that personal information is secure against disclosure, loss or theft or unauthorized access, copying, use or modification. Such safeguards include physical measures, such as restricting access to offices and filing cabinets, organizational measures, such as limiting access to personal information on a ‘need to know’ basis and technological measures such as using passwords and encryption. Our employees and agents are aware of the importance of maintaining the confidentiality of personal information.

As the Internet is not a totally secure medium, we cannot guarantee that our safeguards will always be totally effective particularly in cases of fraudulent conduct or fraudulent concealment, provision by third parties of incorrect data, willful actions by third parties to corrupt or tamper with the database and/or the data and other such actions or occurrences.

Links to Other Sites

We would like to remind you that we provide additional links to resources we believe may be useful to you. These links will lead you to sites operated by different organizations with different privacy practices. We are not responsible for the privacy practices or the content of such web sites.

How to Contact Us

Upon written request and reasonable notice, individuals will be given information about their personal information held by us. You will be provided with an opportunity to confirm the accuracy and completeness of your personal information and have it amended.

Our goal is to protect your privacy. If you have any questions, comments or concerns about these privacy policies, please contact our Privacy Officer at:

Privacy Officer
Higher Ed Points Program
E-mail: PrivacyOfficer@higheredpoints.com

September 10, 2015
© 2015 Higher Ed Points Inc. All rights reserved.