THE BOLD.ORG PRIVACY POLICY

Effective date: August 29, 2024

The Bold.org Privacy Policy (“Privacy Policy”) describes how your personal information is collected, used, and shared when you visit or use the Bold.org, Inc. (“Bold”) website (https://bold.org/) (the “Site”) and when you use and engage our services (“Services”) which includes Personal Information collected via email, SMS, telephone, social media accounts, or other means. At Bold, your privacy is a top priority. By using or accessing the Site or Services, you acknowledge our practices and processing of your information as described in this Privacy Policy.

Please click here for a printable PDF version of this Privacy Policy.

Our Privacy Policy does not apply to services offered by other companies or individuals, including products or sites that may be displayed to you, or other sites linked from our Services. Our Privacy Policy does not cover the information practices of other companies and organizations who advertise our Services on other websites.

In addition, we may from time to time add new sites that may not be listed in this Privacy Policy which are also considered the Site.

Residents in California, Colorado, Connecticut, Montana, Oregon, Texas, Utah, and Virginia should refer to the body of this Privacy Policy as well as the Jurisdiction-Specific Notices section below for additional information that may be applicable to them.

Your Information That We Collect

We use the term “personal information” to refer to any information that identifies or can be used to identify you. Common examples of personal information include: name, email address, and IP address and information about a device.        

Information that you provide to us:

If you are an applicant, we collect personal information from you that includes personal identifiers (such as your name, username, email address, and address), education information (such as your school name, level of education, major, GPA, and standardized test scores), information that may be considered “sensitive” under certain laws (such as citizenship status, ethnicity, religion, age, and gender), financial information (such as your bank account or loan information, including household income, balance and transaction information--including the amount of payments, debits, and deposits--loan balance, interest rate on the loan, and your payment history), and such other information as we may require to provide our Services. Note, that we do not access your personal information directly, however, we may need to access your account as an administrator in order to provide the Services as necessary to remediate any technical bugs or other issues and to improve the Services.

If you are a donor, we collect personal information from you that includes personal identifiers (such as your name, phone number, email address), location (such as your city and state), financial information required to make donations (such as bank account information), and such other information as we may require to provide our Services. Financial information is provided directly to our service provider(s); we do not directly handle donor financial information.

If you contact us, we may collect personal identifiers (such as your name and email address), the contents of your message, and additional information such as your location, and any personal information that you provide in your contact request. We also receive information through your communications with us by email, phone or a physical mail.

We may receive your contact information (including your name, telephone number, and email address) and/or professional or business-related information (including your business address), through our interactions with you in a business-to-business capacity, such as when your business provides services to us, or when we work together on a project, or when we discuss business opportunities. We may contact you with information about our business dealings, news, and opportunities, and we may use your information in the normal course of our business operations.

Information collected from other sources:

If you post information on a webpage we establish on a social media platform, we may use the information you provide for purposes of providing a response, to promote our business and services, and otherwise in the normal course of our business operations. We may collect personal identifiers (such as your social media username) and other personal information that you have made available to us through the webpage we established on the social media platform, in accordance with the platform rules and/or applicable law. Note that the third-party operators of social media websites also receive such information, and their use of your personal information is governed by their own privacy policies.

Information automatically collected (through cookies and similar technologies):

When you visit the Site, we and our partners (such as advertising partners and analytics providers) automatically collect certain information about you and your device, including personal identifiers (such as your IP address) and Internet or other electronic network activity information (such as your web browser, and time zone). Additionally, as you browse the Site, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site. This information is collected using the following technologies:

• “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit https://www.allaboutcookies.org.
• “Log files” track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
• “Web beacons,” “tags,” and “pixels” are electronic files used to record information about how you browse the Site.

For example, we use Google Analytics to help us understand how our customers use the Site. You can read more about how Google uses your information here. You can also opt-out of Google Analytics here.

Please see our Cookie Policy for more details. With respect to any social media platforms on which we have established a webpage, please see the privacy policies and any cookie policies of the applicable social media platform as to their automated data collection practices.

How We Use Your Information

We use your personal information in ways that are compatible with the business and commercial purposes for which it was collected or authorized by you, including for the following purposes.

• To provide the Service. We use your information to provide our Services, including to help determine eligibility for scholarship opportunities and to provide such information as part of applicant profiles that are included alongside scholarship applications.
• For anti-fraud purposes and to improve our Site. We use information that we collect to help us screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimize our Site (for example, by generating analytics about how our customers browse and interact with the Site).
• To authorize access to our Sites and Services.
• To customize or tailor your experience of the Services.
• To communicate about, and administer your participation in our Services and to deliver pertinent emails.
• To improve our customer service.
• To respond to and support users regarding their use of the Sites and Services.
• To comply with all applicable legal requirements.

For applicants, when you register for an account, you will be able to create a financial dashboard within your account that permits you to connect your bank accounts and loans to initiate and permit payments. For donors, when you register for an account, you will be able to provide financial account information that permits you to make donations. Bold does not collect any financial, bank or payment information directly from you. All transactions are handled by a third party payment processor. By using Bold’s Services, you agree that Bold may share your financial, bank or payment information with the third party payment processor.

How We Share Your Information

We may share any of the categories of personal information listed above, including sensitive data, for our commercial and other business purposes as described below.

Partners (such as scholarship providers, academic institutions, consumer reward providers, data partners (including data modeling, AI and LLM training, big data, and data appending), fraud prevention and detection providers, identity services or identity graph providers, market research providers, healthtech, insuretech, and fintech providers, and bipartisan political campaigns):

• We may sell to or share your information with, and generate revenue from, scholarship providers, applicable academic institutions, and other third parties in which you have expressed interest while using the Site. Of course, you can opt-out of this sharing at any time by providing us notice that you want us to delete and no longer use your information for any or all of those purposes. For more information about opting out, please see the “Jurisdiction-Specific Notices” section below.
• We will share your information with scholarship providers, applicable academic institutions, and as otherwise necessary to provide the Service to you. If you agree to Bold to sharing your information with a scholarship provider, academic institution, or other third party partner of Bold, Bold may generate revenue in connection with sharing that information.
• Additionally, if you indicate you are interested in particular educational institutions in your profile or via other means when using Bold’s platform, Bold may sell your information to or share your information with those educational institutions from time to time. For more information about opting out of such selling and sharing, please see the “Jurisdiction-Specific Notices” section below.
• Additionally, you consent to receive marketing texts, phone calls, or email messages from Bold and its Partners (as defined in our Privacy Policy), representatives, and/or higher ed institutional partner enrollment marketing at the phone number and email address you share, and agree that that these communications may be delivered using an autodialer or other automated systems for the selection or dialing of numbers. You acknowledge that your consent to these communications is not a condition of any purchase. You also agree that all calls may be monitored or recorded for quality assurance and training purposes.

Vendors and service providers. We share personal information with vendors and service providers that process such information to perform services for us in connection with the Site, and our other business operations. We require that such vendors and services providers will only use your personal information in a manner that is consistent with this Privacy Policy. This includes technology vendors that may need access to and use of your personal information to give us additional personal information about you. These vendors are bound by law and/or contract to protect the confidentiality and security of your personal information. They only process your personal information to provide requested services for us, and only act on our documented instructions.

Analytics providers. In addition to Google Analytics, we may share your information with other analytics providers, including in an aggregated and anonymous manner, to assess the overall trends and information about our customers and to perform analytics and other work that we may need to outsource. This information will not contain any of your personal information and is only shared in an aggregated and anonymized manner.

Legal and similar disclosures. We may also share your information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.

Advertising and marketing partners. Additionally, Bold participates in partner advertising programs designed to provide a means for Bold to generate revenue and be compensated by advertising and linking to those partners’ products or services.

Merger, sale, or other asset transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, your personal information may be shared with the other parties and advisors involved under an obligation of confidentiality in connection with the negotiation of such transaction, and your personal information may be transferred as part of such a transaction (subject to compliance with applicable laws).

Please note, we may share aggregated, de-identified personal information with our partners, including our AI partners. We will maintain and use such information in deidentified form and not to attempt to reidentify the information.

Information Security

The security of your information is very important and we endeavor to process your information securely, in accordance with this Privacy Policy, and in accordance with information security requirements imposed by applicable law.

Although we take reasonable steps designed to protect your information, please be advised that no security system or means of transmitting data over the Internet can be guaranteed to be entirely secure.

Privacy Rights

Certain jurisdictions have specific legal requirements and grant privacy rights with respect to personal information, and we will comply with restrictions and any requests you submit as required by applicable law. For example, you may have the right to review, correct, and delete personal information we have about you, or to consent or withdraw consent to certain uses or sharing of personal information. You also have the right to not be discriminated against for exercising your privacy rights. If you are a resident of California, Colorado, Connecticut, Montana, Oregon, Texas, Utah, and Virginia, see our Jurisdiction-Specific Notices section below. If you are a resident of another jurisdiction and you seek to exercise your rights under the law of another jurisdiction, please contact us by using the contact information in the How to Contact Us section below.

Please note that, when you make a request, we may require that you provide information and follow procedures so that we can verify your identity (and the applicable jurisdiction). The verification steps we take may differ depending on your jurisdiction and the request. Where possible, we will attempt to match the information that you provide in your request to information we already have on file to verify your identity. If we are able to verify your request, we will process it. If we cannot verify your request, we may ask you for additional information to help us do so.

We will respond to your request within the time period required by applicable law. However, we may not always be able or required to comply with your request, in whole or in part, and we will notify you in that event.

Under certain state privacy laws, our use of cookies and similar technologies may constitute a “sale” or may constitute sharing for behavioral advertising purposes. For additional information, including opt-out rights, see the information available from the "Do Not Sell or Share My Personal Information" link on our Site homepage.

Our Retention of Your Information

We will retain your information for as long as your account is active or as needed to provide you services. If you wish to request that we no longer use your information to provide you services or updates on additional products or for any other reason described in this Privacy Policy, contact us at privacy@bold.org. Additionally, we will retain and use your information as necessary to comply with our legal or regulatory obligations, resolve disputes, and enforce our agreements.

Children’s Information

We do not knowingly or intentionally gather personal information about children who are under the age of 14. We also do not knowingly or intentionally share (targeted advertising) or sell (as those terms are defined under U.S. privacy laws) personal information about children who are under the age of 16. If you become aware that a child has provided us with personal information, a child has provided us with personal information, a parent or guardian of that child may contact us at privacy@bold.org to have the information deleted from our records. If we learn that we have inadvertently collected the personal information of a child under 14, or equivalent minimum age depending on jurisdiction, we will take steps to delete the information as soon as possible and cease the use of that information in accordance with applicable law.

Jurisdiction-Specific Notices

California Residents

Under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (the "CCPA"), California residents have specific rights regarding their personal information. This section describes Californians’ rights and explains how California residents can exercise those rights.

Personal Information Collected Related to California Residents

During the last twelve (12) months, we have collected the following categories of personal information from California consumers. Some of the categories of information collected specifically concerns our employees or contractors as opposed to consumers who purchase our products.

Please see our Cookie Policy  for information about the collection and use of personal information by third-parties who process information collected by cookies and related technologies that we permit them to use on the Site.  Except as indicated above in the “Your Information that We Collect” section, we do not seek to collect any other "sensitive personal information" (as defined in the CCPA).

Rights Specific to California Residents

Under the CCPA, a California resident has the following rights, subject to certain limitations: (1) to request that we disclose to you what Personal Information we collect, use, disclose and sell, including the right to request that we provide you the specific Personal Information we have collected about you in the prior twelve (12) months, (2) to request that we correct inadequate or out of date information, (3) to ask us to delete your Personal Information, (4) to limit the use and disclosure of sensitive personal information, (5) opt-out of the "selling" or "sharing" of personal information, and (6) not to receive discriminatory treatment by us for exercising your privacy rights conferred by the CCPA. You can opt-out from our selling and sharing of your Personal Information as described below (“Do Not Sell or Share My Information”).

You may submit a request to exercise your rights under the CCPA through one of two methods:

• Submit a request through our webform: https://bold.org/data-requests/.

• Call (720) 730-2653 to submit a request.

You may also designate an agent to exercise your privacy rights on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide a valid power of attorney, the requester’s valid government-issued identification, and the authorized agent’s valid government issued identification.

Upon receiving your request, we will confirm receipt of your request by sending you an email/confirming receipt. To help protect your privacy and maintain security, we may take steps to verify your identity before granting you access to the information. In some instances, such as a request to delete personal information, we may first separately confirm that you would like for us to in fact delete your personal information before acting on your request.

We will respond to your request as soon as reasonably practicable and consistent with any applicable laws. If we require more time, we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. You may authorize another individual or a business registered with the California Secretary of State, called an authorized agent, to make requests on your behalf through these means.  We may have a reason under the law why we do not have to comply with your request, or why we may comply with it in a more limited way than you anticipated. If we do, we will explain that to you in our response.

Colorado Residents

Colorado residents have certain rights around Bold's collection, use, and sharing of their personal information. Bold sells certain personal information as described above. Bold does not engage in profiling in furtherance of decisions that produce legal or similarly significant effects. Bold engages in “targeted advertising” as that term is defined in the Colorado Privacy Act ("CPA").

Bold collects various categories of personal information when you use the Services. A more detailed description of the information Bold collects and how we use it is provided above in the “Your Information That We Collect” section. The section above titled, “How We Share Your Information,” describes the categories of third parties with whom we share personal information, and what information may be shared under different circumstances. If you are a resident of Colorado, you have the right to (1) request to know what personal information has been collected about you, and to access that information; (2) request to correct inaccuracies in your personal information; (3) request deletion of your personal information, subject to exceptions; (4) obtain a copy of your personal information; and (5) request to opt-out of the sale of your personal information, profiling, and targeted advertising. You can learn more about how to submit a data rights request, or appeal denial of a request, by emailing privacy@bold.org.

Connecticut Residents

Connecticut residents have certain rights around Bold's collection, use, and sharing of their personal information. Bold sells certain personal information as described above. Bold does not engage in profiling in furtherance of decisions that produce legal or similarly significant effects. Bold engages in “targeted advertising” as that term is defined in the Connecticut Data Privacy Act ("CTDPA").

Bold collects various categories of personal information when you use the Services. A more detailed description of the information Bold collects and how we use it is provided above in the “Your Information That We Collect” section. The section above titled, “How We Share Your Information,” describes the categories of third parties with whom we share personal information, and what information may be shared under different circumstances. If you are a resident of Connecticut, you have the right to (1) request to know what personal information has been collected about you, and to access that information; (2) request to correct inaccuracies in your personal information; (3) request deletion of your personal information, subject to exceptions; (4) obtain a copy of your personal information; and (5) request to opt-out of the sale of your personal information, profiling, and targeted advertising. You can learn more about how to submit a data rights request, or appeal denial of a request, by emailing privacy@bold.org.

Montana Residents

Montana residents have certain rights around Bold's collection, use, and sharing of their personal information. Bold sells certain personal information as described above. Bold does not engage in profiling in furtherance of decisions that produce legal or similarly significant effects. Bold engages in "targeted advertising" as that term is defined in the Montana Consumer Data Privacy Act ("MCDPA").

Bold collects various categories of personal information when you use the Services. A more detailed description of the information Bold collects and how we use it is provided above in the "Your Information That We Collect" section. The section above titled, "How We Share Your Information," describes the categories of third parties with whom we share personal information, and what information may be shared under different circumstances. If you are a resident of Montana, starting October 1, 2024, you have the right to (1) request to know what personal information has been collected about you, and to access that information; (2) request to correct inaccuracies in your personal information; (3) request deletion of your personal information, subject to exceptions; (4) obtain a copy of your personal information; and (5) request to opt-out of the sale of your personal information, profiling, and targeted advertising. You can learn more about how to submit a data rights request, or appeal denial of a request, by emailing privacy@bold.org.

Oregon Residents

Bold.org is the controller of your personal information. Oregon residents have certain rights around Bold's collection, use, and sharing of their personal information. Bold sells certain personal information as described above. Bold does not engage in profiling in furtherance of decisions that produce legal or similarly significant effects. Bold engages in "targeted advertising" as that term is defined in the Oregon Consumer Privacy Act ("OCPA").

Bold collects various categories of personal information when you use the Services. A more detailed description of the information Bold collects, including sensitive data, and how we use it is provided above in the "Your Information That We Collect" section. The section above titled, "How We Share Your Information," describes the categories of third parties with whom we share personal information, including sensitive data, and what information may be shared under different circumstances. If you are a resident of Oregon, starting July 1, 2024, you have the right to (1) request to know what personal information has been collected about you, and to access that information; (2) request to correct inaccuracies in your personal information; (3) request deletion of your personal information, subject to exceptions; (4) obtain a copy of your personal information; and (5) request to opt-out of the sale of your personal information, profiling, and targeted advertising. You can learn more about how to submit a data rights request, or appeal denial of a request, by emailing privacy@bold.org.

Texas Residents

Texas residents have certain rights around Bold's collection, use, and sharing of their personal information. Bold sells certain personal information as described above. Bold does not engage in profiling in furtherance of decisions that produce legal or similarly significant effects. Bold engages in "targeted advertising" as that term is defined in the Texas Data Privacy and Security Act ("TDPSA").

Bold collects various categories of personal information when you use the Services. A more detailed description of the information Bold collects and how we use it is provided above in the "Your Information That We Collect" section. The section above titled, "How We Share Your Information," describes the categories of third parties with whom we share personal information, and what information may be shared under different circumstances. If you are a resident of Texas, starting July 1, 2024, you have the right to (1) request to know what personal information has been collected about you, and to access that information; (2) request to correct inaccuracies in your personal information; (3) request deletion of your personal information, subject to exceptions; (4) obtain a copy of your personal information; and (5) request to opt-out of the sale of your personal information, profiling, and targeted advertising. You can learn more about how to submit a data rights request, or appeal denial of a request, by emailing privacy@bold.org.

Utah Residents

Utah residents have certain rights around Bold's collection, use, and sharing of their personal information. Bold sells certain personal information as described above. Bold does not engage in profiling in furtherance of decisions that produce legal or similarly significant effects. Bold engages in “targeted advertising” as that term is defined in the Utah Consumer Privacy Act ("UCPA").

Bold collects various categories of personal information when you use the Services. A more detailed description of the information Bold collects and how we use it is provided above in the "Your Information That We Collect" section. The section above titled, "How We Share Your Information," describes the categories of third parties with whom we share personal information, and what information may be shared under different circumstances. If you are a resident of Utah, you have the right to (1) request to know what personal information has been collected about you, and to access that information; (2) request to correct inaccuracies in your personal information; (3) request deletion of your personal information, subject to exceptions; (4) obtain a copy of your personal information; and (5) request to opt-out of the sale of your personal information and targeted advertising. You can learn more about how to submit a data rights request, or appeal denial of a request, by emailing privacy@bold.org.

Virginia Residents

Virginia residents have certain rights around Bold’s collection, use, and sharing of their personal information. Bold sells certain personal information as described above. Bold does not engage in profiling in furtherance of decisions that produce legal or similarly significant effects. Bold engages in “targeted advertising” as that term is defined in the Virginia Consumer Data Protection Act ("VCDPA").

Bold collects various categories of personal information when you use the Services. A more detailed description of the information Bold collects and how we use it is provided above in the "Your Information That We Collect" section. The section above titled, "How We Share Your Information," describes the categories of third parties with whom we share personal information, and what information may be shared under different circumstances. If you are a resident of Virginia, you have the right to (1) request to know what personal information has been collected about you and to access that information; (2) request to correct inaccuracies in your personal information; (3) request deletion of your personal information, subject to exceptions; (4) obtain a copy of your personal information; and (5) request to opt-out of the sale of your personal information, profiling, and targeting advertising. You can learn more about how to submit a data rights request, or appeal denial of a request, by emailing privacy@bold.org.

Links to Unaffiliated Third-Party Websites

The Site may contain links to unaffiliated third-party websites. This Privacy Policy does not apply to the practices of such other websites, and we are not responsible for the actions and privacy policies of the third parties that operate or interact with those websites.

Changes to Our Privacy Policy

Please review this Privacy Policy from time to time as we may update this Privacy Policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons. We will post any privacy policy changes on this page and, if the changes are material, we will provide a more prominent notice (including, for certain services or programs, email notification or privacy policy changes).. Your continued use of our services or the Site will constitute your acceptance of any such.

How to Contact Us

For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e-mail at privacy@bold.org or by mail using the details provided below:

Bold.org, Inc., 133 Kearny #400, San Francisco CA 94108 United States

THE BOLD.ORG COOKIE POLICY

We use cookies and similar technologies (referred to herein simply as “cookies”) to facilitate and improve the performance and security of our Sites and to enhance user experience.

The Site may utilize or permit several different categories of cookies, as follows:

• Essential cookies – Some cookies may be essential for the proper operation of the Site. For example, they may facilitate page navigation or assist with security checks.
• Functional cookies – These cookies allow us to remember your preferences and allow us to make the Site experience better for you.
• Performance/analytics cookies – These cookies allow us to analyze how visitors use our Site and to measure Site performance. This allows us to provide a quality experience by customizing our offering and quickly identifying and fixing any issues that arise. For example, we might use performance cookies to keep track of what content is popular, or to learn what links between pages are most effective or why some pages are receiving error messages.
• Advertising cookies – These cookies may be used to highlight articles, other content, or services that we think will be of interest to you based on your use of the Site. They may also be utilized by third parties when a third-party content feed has been included in the Site so that you can view videos and social media streams.

Use of cookies on our Site

We do use or allow certain third parties to serve cookies on the Site. We may allow third parties to serve cookies to help identify fraudulent or automated traffic on the Site. In addition, third parties that provide content feeds may serve cookies. We may use third-party cookies to help us with market research, improving functionality, and enforcing Website terms and policies. For example, like many companies, we use Google Analytics to help us evaluate our website traffic. You can see how Google Analytics uses cookie information across various websites by visiting https://policies.google.com/technologies/partner-sites, or any successor webpage that Google may provide.

Specific third-party cookies and associated privacy practices

The Site may permit the following cookies:

Opt-outs

To opt-out of certain cookies, please see the "Do Not Sell or Share My Personal Information" link on our Site homepage. Also, your browser may allow you to disable certain cookies, or you may be able to utilize a global privacy control in connection with your browser. The third party listed for a given cookie may provide an opt out tool for that cookie. Note that disabling cookies may in some instances impact the functionality of the Site. Opt-out functionality for Google Analytics can be found here.

You may learn more about advertising networks and opt out of receiving personalized advertisements on this browser or device from advertisers who are members of the Network Advertising Initiative or who subscribe to the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising by visiting the opt-out options of each of those organizations. Links to their opt-out sites are set forth below.

Network Advertising Initiative:

• Browser Opt-Out: https://www.networkadvertising.org/choices   

Digital Advertising Alliance:

• Browser Opt-Out: https://www.aboutads.info/choices   

Note that, when you opt out of personalized advertising, you may continue to see online advertising on the Site and/or our ads on other websites and online services. Also, given that many opt-outs themselves use a cookie to effectuate an opt-out preference, you may need to opt-out again if you clear cookies on your browser.

Changes to this Cookie Policy

We may revise this Cookie Policy from time to time in order to reflect changes in our use of cookies, changes in the law, changes in our services, or best practices. We encourage you to review this Cookie Policy periodically.