Privacy Policy

Last update on August 15, 2022

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are, how and why we collect, store, use, and share your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint.

The College Pads Pro website, Services, apps, and their interactive properties are delivered (“the Services”), owned, operated, and distributed by us (referred to in this Privacy Policy as “we” and through similar words such as “us,” “our,” etc.). This Privacy Policy outlines the personal information that we may collect, how we use and safeguard that information, and with whom we may share it. We collect, use and are responsible for certain personal information about you. When we do so we are subject to various laws in the United States, and we are responsible as controller of that personal information for the purposes of those laws.

THE SERVICES ARE OFFERED FROM THE UNITED STATES (“US”). For individuals located outside of the US, please note that we are a US-based company. If you use the Services, all information, including personal information, will be transferred to us in the US and used as described in this Privacy Policy.

1. Key Terms. It would be helpful to start by explaining some key terms used in this policy:

We, us, our

College Pads Pro

2. Personal Information We Collect About You. We may collect and use the following personal information that identifies, relates to, describes, is reasonable capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:

Categories of Personal Information	Specific Types of Personal Information Collected
Identifiers	real name date of birth alias online identifier postal address Internet Protocol address email address account/usernames social security number driver’s license number passport number license plate number other similar identifiers
Information that identifies, relates to, describes, or is capable of being associated with, a particular individual,	signatures photographs, telephone number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, residence history renter or property insurance marital status family and household information (e.g. immediate relatives, household members, and their corresponding personal identifiers and information that relates to them) tax ID (e.g. FEIN) criminal record tax records (e.g. IRS forms W-1099, W-1040, tax transcripts, etc). credit score and history
Commercial information	search history content of maintenance of requests and/or complaints, or other user generated data from using the Services
Internet or other electronic network activity information	property search history browsing history while using the Services
Geolocation data	current location

This personal information is required to provide the Services to you. If you do not provide the personal information we ask for, it may delay or prevent us from providing the Services to you.

3. How Your Personal Information is Collected. We collect most of this personal information directly from you—through our website and apps as you use the Services. However, we may also collect information:

From publicly accessible sources (e.g., criminal records);
Directly from a third party (e.g., sanctions screening providers, credit reporting agencies, or customer due diligence providers);
From a third party with your consent (e.g., your bank); and,
From cookies on our website.

4. How and Why We Use Your Personal Information. Under data protection law, we can only use your personal information if we have a proper reason for doing so:

To comply with our legal and regulatory obligations;
To perform the Services;
To prevent and detect fraud against you or any third party;
For our legitimate interests or those of a third party; or
Where you have given consent.

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

The table below explains what we use (process) your personal information for and our reasons for doing so:

What we use your personal information for	Our reasons
To provide Services to you.	For the performance of our contract with you or to take steps at your request before entering into a contract.
To prevent and detect fraud against you or any third party.	To minimize fraud that could be damaging for us and for you.
Conducting checks to identify our customers and verify their identity Other processing necessary to comply with professional, legal and regulatory obligations that apply to our business.	To comply with our legal and regulatory obligations.
Responding to subpoenas or other lawful requests.	To comply with our legal and regulatory obligations
Ensuring business policies are adhered to, e.g. policies covering security and internet use	To make sure we are following our own internal procedures so we can secure your personal information.
Operational reasons, such as improving efficiency, training and quality control	To be as efficient as we can so we can deliver the best service for you.
Statistical analysis to help us manage our business in relation to our performance, customer base, product range or other commercial measures	To improve the Services.
Updating and enhancing customer records	To provide the Services to you.
Credit reference checks and background checks via external reference agencies	To provide the Services to you.

5. Promotional Communications. We may use your personal information to send you updates by email, text message, telephone or post about our products and Services, including exclusive offers, or promotions.

We have a legitimate interest in processing your personal information for promotional purposes. This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.

We will always treat your personal information with the utmost respect and never sell it to any other organization, except as part of a corporate merger, acquisition, or sale.

You have the right to opt-out of receiving promotional communications at any time by:

Contacting us at support@collegepadspro.com
Using the “unsubscribe” link in emails or “STOP” number in texts; or

Who We Share Your Personal Information With. We routinely share personal information with:

Our affiliates, including companies within the PropertyTek Group. Affiliate means any entity or individual that directly or indirectly controls, is controlled by, or is under common control as us.
Service providers we use to help deliver the Services to you, such as (but without limitation) payment service providers, credit agencies, maintenance companies, property management companies, and property owners.
Other third parties we use to help us run our business, such as website and cloud hosting services;

We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use the personal information we collect from you to provide services to us and to you. We may also share personal information with external auditors, e.g. in relation to ISO[ or Investors in People] accreditation and the audit of our accounts.

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. We will typically anonymize the information, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

6. Personal Information We Sold or Disclosed for a Business Purpose. In the preceding 12 months, we have disclosed for a business purpose to one or more third parties the following categories of personal information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:

Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers);
Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, social security number, photographs, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, criminal history, bank account number, credit card number, debit card number, or any other financial information;
Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction our Services); and,
Geolocation data.

7. Where Your Personal Information is Held. Information may be held at our offices and those of our service providers.

These third parties are based in the United States.

8. How Long Your Personal Information Will Be Kept. We will keep your personal information while you have an account with us or while we are providing [products AND/OR services] to you. Thereafter, we will keep your personal information for as long as is necessary:

To respond to any questions, complaints or claims made by you or on your behalf;
To show that we treated you fairly; or
To keep records required by law.

We will not retain your personal information for longer than necessary for the purposes set out in this policy.

9. Your Rights Under the CCPA. You have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to exercise free of charge:

Disclosure of Personal Information We Collect About You	You have the right to know: The categories of personal information we have collected about you; The categories of sources from which the personal information is collected; Our business or commercial purpose for collecting or selling personal information; The categories of third parties with whom we share personal information, if any; and The specific pieces of personal information we have collected about you. Please note that we are not required to: Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained; Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information; or Provide the personal information to you more than twice in a 12-month period.
Personal Information Used for a Business Purpose	In connection with any personal information we may disclose to a third party for a business purpose, you have the right to know: The categories of personal information about you that we sold and the categories of third parties to whom the personal information was sold; and The categories of personal information that we disclosed about you for a business purpose. You have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to opt-out of the disclosure of your personal information; however, if you do so we will be unable to provide the Services to you. If you exercise your right to opt-out of the disclosure of your personal information, we will be unable to provide you the Services. You may contact us at [] for assistance terminating your account.
Right to Deletion	Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will: Delete your personal information from our records; and Direct any service providers to delete your personal information from their records. Please note that we may not delete your personal information if it is necessary to: Complete the transaction for which the personal information was collected; Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity; Debug to identify and repair errors that impair existing intended functionality; Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us; To properly manage and administer our organization; Comply with an existing legal obligation; or Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.
Protection Against Discrimination	You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA. This means we cannot, among other things: Deny services to you; Charge different prices or rates for services, including through the use of discounts or other benefits or imposing penalties; Provide a different level or quality of services to you; or Suggest that you will receive a different price or rate for services or a different level or quality of services. Please note that we may charge a different price or rate or provide a different level or quality of services to you, if that difference is reasonably related to the value provided to our business by your personal information.

10. Keeping Your Personal Information Secure. We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorized way. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality. We continually test our systems, and we follow industry standards for information security. We also have procedures in place to deal with a suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

Users of the Services are responsible for maintaining the security of any password, user ID or other forms of authentication involved in obtaining access to password-protected or secure areas of the Services. In order to protect you and your information, we may suspend your use of any of the Services, without notice, pending an investigation, if any breach of security is suspected.

11. Third Party Advertisers. We may allow other companies, called third-party ad servers or ad networks, to serve advertisements within the Services. These third-party ad servers or ad networks use technology to send, directly to your device, the advertisements and links that appear on the Services. They automatically receive your device ID and IP address when this happens. They may also use other technologies (such as cookies) to measure the effectiveness of their advertisements and to personalize the advertising content you see. You should consult the respective privacy policies of these third-party ad servers or ad networks for more information on their practices and for instructions on how to opt-out of certain practices. This Privacy Notice does not apply to them, and we cannot control their activities.

12. International Data Transfer. If you are located outside the United States, in particular, if you are located in Switzerland, the United Kingdom, or the European Economic Area (“EEA”), please note that we and our servers are located in the United States. We do not market to or solicit customers from outside the US; therefore, users of the Services should not expect to avail themselves of the rights provided under the EU’s General Data Protection Regulation (“GDPR”). If you use the Services, all information, including personal information, will be transferred to us in the US. By using the Services, you unambiguously consent to the transfer of your personal information and other information to the US and elsewhere for the purposes and uses described in this Notice.

13. Children’s Privacy. The Services are not intended for children under the age of 18, and we do not knowingly collect the personal information of children under the age of 18.

14. External Links. The Services may contain links to other websites maintained by third parties. Please be aware that we exercise no control over linked sites and we are not responsible for the privacy practices or the content of such sites. Each linked site maintains its own independent privacy and data collection policies and procedures, and you are encouraged to view the privacy policies of these other sites before providing any personal information. You hereby acknowledge and agree that we are not responsible for the privacy practices, data collection policies and procedures, or the content of such third-party sites, and you hereby release us from any and all claims arising out of or related to the privacy practices, data collection policies and procedures, and/or the content of such third-party sites.

15. Cookies and Device Data. When you use the Services, we may record unique identifiers associated with your device (such as the device ID and IP address), your activity within the Services, and your network location. We use aggregated information (such as anonymous user usage information, cookies, IP addresses, browser type, clickstream information, etc.) to improve the quality and design of the Services and to create new features, promotions, functionality, and products by storing, tracking, and analyzing user preferences and trends. Specifically, we may automatically collect the following information about your use of Services through cookies and other technologies:

domain name;
browser type and operating system;
web pages you view;
links you click;
IP address;
the length of time you visit the Sites, Portals, and/or Websites;
the referring URL or the webpage that led you to the Sites.

We may also collect information regarding application-level events, such as crashes, and associate that temporarily with your account. In some circumstances, we may combine this information with personal information collected from you (and third-party service providers may do so on our behalf).

In addition, we may use “cookies,” clear gifs, and log file information that help us determine the type of content and pages to which you link, the length of time you spend at any particular area of the Services, and the portion of the Services you choose to use. A cookie is a small text file that is sent by a website to your computer or mobile device where it is stored by your web browser. A cookie contains limited information, usually a unique identifier and the name of the site. Your browser has options to accept, reject or provide you with notice when a cookie is sent. Our cookies do not execute any code or virus; and they do not contain any personal information. Cookies allow us to serve you better and more efficiently, and to personalize your experience with the Services. We may use cookies for many purposes, including (without limitation) to save your password so you don’t have to re-enter it each time you use the Services, and to deliver content (which may include third-party property listings or other relevant \advertisements) specific to your interests.

We may use third-party service providers to help us analyze certain online activities and/or to analyze aggregated data provided by customers. For example, these service providers may help us measure the performance of our online campaigns or analyze user activity. We may permit these service providers to use cookies and other technologies to perform these services for us. We do not share any personal information about our customers with these third-party service providers, and these service providers do not collect such information on our behalf. Our third-party service providers are required to comply fully with this Privacy Notice

16. How to Exercise Your Rights. If you would like to exercise any of your rights as described in this Privacy Policy, please:

Email us at support@collegepadspro.com.

Please note that you may only make CCPA-related data access or data portability disclosure request twice within a 12-month period.

If you choose to contact us directly by website/email/phone/in writing, you will need to provide us with:

Enough information to identify you, specifically your full name, address and account number;
Proof of your identity and address (e.g., a copy of your driving license or passport); and
A description of what right you want to exercise and the information to which your request relates.

We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information, or is someone authorized to act on such person’s behalf.

Any personal information we collect from you to verify your identity in connection with you request will be used solely for the purposes of verification.

17. Changes to This Privacy Notice. This privacy notice was published on August 5, 2022 and last updated on August 5, 2022.

We may change this privacy notice from time to time– when we do, we will inform you via account notification.

18. How to Contact Us. Please contact us by email at support@collegepadspro.com

19. Do You Need Extra Help? If you would like this notice in another format (for example: audio, large print, braille) please contact us (see “How to contact us” above).