Privacy Policy INTRODUCTION Noodle Partners, Inc. (“Noodle” or “we” or “us”). Noodle manages online academic programs (“Program”) for our partner colleges and universities (“University”). Because Noodle values your privacy, we have created this Privacy Policy to explain how we collect information from and about you when you use our websites and applications (including the websites and applications associated with academic programs we manage for colleges and universities) and their features and services, whether appearing on a website, a mobile application, or any other device or technology (“Noodle Technology”) and how we may disclose and use that information. This Privacy Policy applies to Noodle’s collection and use of personally identifiable information, which is information that can be used to identify or contact a specific person, such as a full name or email address, as well as our practices for handling non-personally identifiable information, such as user preferences and services usage information. By using Noodle Technology, you agree to the terms and conditions of this Privacy Policy. If you do not agree with the terms of this Privacy Policy, please leave this site immediately and do not use or access Noodle Technology. COLLECTION OF INFORMATION We collect information to provide services to all of our users and to improve our services. We limit the collection of information to only that which is absolutely necessary to carry out our legal or business obligations. We store the information we collect with unique identifiers tied to the browser, application, or device you’re using. We may collect the following information from and about you: First Name and Last Name Email Address Phone Number Zip Code Program of Interest Level of Education Attained Whether or not you’ve taken an Admissions Exam Years of work experience Information from Social Media and Other Sites You may have the option to access Noodle Technology through a social media service (e.g., Facebook) or another third-party site. If you access Noodle Technology in this way, we may collect information about you from that service or site, which may include the username associated with that service or site, your name, profile picture, email address, gender, birthday or friends lists, your likes, preferences, searches, comments and posts, and any other information or content of yours collected by that service or site. All information from and about you that is collected from social media services and third-party sites in this manner may be used and disclosed by Noodle in accordance with this Privacy Policy. Application Data Should you start an application for a Program, the application information may be collected by Noodle or the University. If collected directly by a University, then the University’s Privacy Policy applies to the collection of application data. The University will share some or all of the application data with Noodle. If the application information is collected by Noodle, then we will share the application data with the University. Activity Information When you access and interact with Noodle Technology, we may collect certain information about those visits, such as your searches and preferences as well as technical information about your computer and its operating system, your internet browser, your internet protocol address, your navigation path (including your navigation on Noodle Technology and the domain names of the sites from and to which you link), and other information about your software and hardware. If you access Noodle Technology from a mobile or other device, we may collect certain information including the unique device identifier assigned to that device, geolocation data, your wireless service provider, operating system, browser type and other transactional information for that device. Cookies and California Do Not Track Disclosures Cookies are small bits of data that a site or its service provider transfers to your computer through your browser that enables the site or service provider to recognize your browser and remember certain information about you. We may use cookies and other tracking technologies (such as pixel tags, ad tags and web beacons) to collect information to help us understand your interactions with Noodle Technology, such as pages you have visited, content you have viewed, search queries you have run and advertisements you have seen. Third parties that support Noodle Technology by serving advertisements or providing services, such as allowing you to share content or tracking aggregate usage statistics, (e.g., Google Analytics tracking and Google AdWords) may also use these technologies to collect similar information. Noodle does not control these third-party technologies and their use is governed by the privacy policies of the third parties using such technologies. Your browser may permit you to disable these technologies. If you would like to delete cookies or instruct your web browser to disable tracking please visit the help pages on your web browser. However, doing so may prevent you from using certain parts of Noodle Technology. Please note that Noodle does not respond to “Do Not Track” settings configured in your web browser.. Information from Other Sources We may supplement the information we collect through Noodle Technology with information from other sources, such as information that you submit to Noodle directly by email, telephone or other means (e.g., information you provide to Noodle’s customer service team) and publicly available information from social media services, commercially available sources and information from our affiliates or business partners. USE AND DISCLOSURE When information collected from or about you does not identify you as a specific person, Noodle may use that information for any purpose or share it with third parties who may use it for any purpose. When information collected from or about you is personally identifiable (your “Personal Information”), Noodle and our service providers may use and disclose that information in the following ways: To provide and personalize the Noodle Services We use your Personal Information to provide our service and their features to you, including: to improve those services and their features; to personalize and to improve your experience with Noodle Technology by delivering content you will find relevant and interesting, to provide you with customer support, and to respond to inquiries. To provide you with customer support Noodle may share your Personal Information with the University, who may contact you to provide you with more information about the Program, assist you with the application process or answer your questions. To share with the University Noodle will share your Personal Information with the University, who may use it: To allow service providers to assist us in providing and managing our services Noodle may make your Personal Information available to certain third party service providers solely for the purpose of helping us with our business operations, such as data processing and marketing and technology service providers. To allow social sharing functionality By logging in with or connecting your Noodle Technology account with a social media service or third-party site, you are authorizing us to share your Personal Information with the social media service or third-party site provider and other users and your friends on that service or site and you understand that use of such shared information by the social media service or third-party site provider will be governed by its privacy policy. If you do not want your Personal Information shared in this way, please do not connect your social media service or other third-party account with your Noodle Technology account and do not participate in social sharing on the Noodle Technology. To deliver relevant information and advertisements Noodle and our service providers may use your Personal Information to deliver relevant information to you when you use Noodle Technology or another service. As noted above, third-party networks may use cookies and similar technologies to collect and track information such as demographic information, inferred interests, aggregated information, and activity, including but not limited to information about your visits to websites to display advertisements more tailored to your interests and to provide you the most relevant advertising. If you wish to know more about this practice or would like to know more about your options, you can visit the Network Advertising Initiative (“NAI”) web-site. The NAI is a cooperative of online advertising companies who are committed to responsible practices and consumer protection. To contact you Noodle may periodically send you promotional materials or notifications related to the Program or services. These emails are meant to be useful to you while helping us improve our user experience. However, if you want to stop receiving promotional materials, you can follow the unsubscribe instructions at the bottom of each email. If you want updates but prefer to keep your email inbox uncluttered, you should check out our Twitter feed and Facebook page. There are certain service notification emails that you may not opt-out of, such as notifications of changes to Noodle Technology or policies. To share with our Noodle Affiliates Noodle may share your Personal Information with our affiliates for the purposes described in this Privacy Policy. To protect the rights of Noodle and others There may be instances when Noodle may disclose your information, including situations where Noodle has a good faith belief that such disclosure is necessary in order to: (i) protect, enforce, or defend the legal rights, privacy, safety, or property of Noodle; (ii) protect the safety, privacy, and security of users of Noodle Technology or members of the public; (iii) protect against fraud or for risk management purposes; (iv) comply with the law or legal process; or (v) respond to requests from public and government authorities. To complete a merger or sale of assets If Noodle sells all or part of its business or makes a sale or transfer of its assets or is otherwise involved in a merger or transfer of all or a material part of its business, Noodle may transfer your Personal Information to the party or parties involved in the transaction as part of that transaction. LEGAL BASIS FOR PROCESSING YOUR PERSONAL INFORMATION We collect and process information about you only where we have a legal basis for doing so under applicable law. The following are the legal bases for collecting and processing your Personal Information: When you give us your consent to do so, this includes: Where consent is required by law, and where we ask for your consent to process your Personal Information for a stated purpose. Where we rely on your consent to process your Personal Information, you may withdraw your consent at any time. You will not suffer any detriment for withdrawing your consent. If you withdraw your consent, this will not make the processing which we undertook before you withdrew your consent unlawful. To meet contractual obligations or obligations related to a contract, this includes: Providing our services and their features to you. Providing you with customer support. Responding to your communications and requests. Communicating with you. Creating an account and profile for you. For Noodle Partners’ legitimate interests, this includes: Developing and operating our business. Maintaining and improving our products and services. Operating our site and providing our services. Conducting market research, audits, and other business operations. For purposes which are required by law, this includes: Complying with any regulations, procedures, and laws which apply to us. Investigating misuse of your account. GDPR PRINCIPLES Noodle Partners complies with the principles of the GDPR and adheres to that Personal Information shall be: Processed lawfully, fairly and in a transparent manner in relation to the person. Collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes. Adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed. Accurate and, where necessary, kept up to date. Kept in a form which permits identification of persons for no longer than is necessary for the purposes for which the Personal Information is processed. Processed in a manner that ensures appropriate security of the Personal Information. USER CONTROL OF PERSONAL INFORMATION Personally identifiable Information Please do not submit to us or post on Noodle Technology any personally identifiable information that you do not want us to collect. In particular, we ask that you do not send us, and you do not share any sensitive information, such as social security numbers, on or through Noodle Technology. Please keep in mind that, although you are not required to provide any personally identifiable information that we request, in many cases, if you do not provide us with the requested information, we may not be able to provide you with certain services or respond to any questions you may have. Receiving electronic communications from us If you no longer want to receive emails from us on a going-forward basis, you may opt-out of receiving these emails by following the unsubscribe instructions in the email. We will process your request within a reasonable time after receipt. However, we are not responsible for removing your personally identifiable information from the lists of any third party who has previously been provided your information in accordance with this Privacy Policy or your consent. Canceling your account While your account is active, we retain your Personal Information. If you cancel your account by following the instructions set forth in the Terms of Use or if we terminate your account for any other reason, we may continue to retain your Personal Information for reasons including, but not limited to, complying with our legal obligations or our internal security policies, meeting regulatory requirements, for fraud detection, improving our site and services, or enforcing this Privacy Policy. Remember that even after your account is cancelled, copies of some information from your account may remain viewable in some circumstances, for example, where you have shared information with a third-party application or web site or where you have posted your Personal Information publicly on the Noodle Technology. In addition, because of the nature of caching technology, your account may not be instantly inaccessible to others, and there may be a delay in the removal of the content from elsewhere on the Internet and from search engines. SECURITY The security of your information is very important to us. Noodle implements a variety of security measures to maintain the safety of your Personal Information. However, due to the inherent open nature of the Internet, no data transmission over the Internet or any wireless network can be guaranteed to be secure. As a result, while we take measures to protect your Personal Information, we cannot ensure or guarantee the security of any information you send to us or that we store on our servers. Your use of Noodle Technology demonstrates your assumption of this risk. DATA TRANSFERS Your information will be processed by us primarily in the United States and, if you live outside the United States, your information will be transferred there. Some of our data process providers may maintain servers around the world, and your information transferred to servers located in other countries. Data protection laws vary among countries, with some providing more protection than others. Regardless of where your information is processed, we apply the same protections described in our Privacy Policy. LINKED SERVICES Noodle Technology may contain links to third-party services and sites. Noodle is not responsible for the privacy practices or content of such third-party services and sites and unaffiliated companies. Once you leave our Noodle Technology websites and apps or click a link to a third-party website or app, you will be bound by, and should review, the applicable privacy policy of the other site or service. SOCIAL MEDIA Noodle Technology may contain links to our presence on various social media platforms. We do not operate or control these platforms. You should be aware that personally identifiable information which you voluntarily include and transmit online in a publicly accessible blog, social network or otherwise online may be viewed and used by others. We are unable to control these uses of your personally identifiable information, and by using such services you assume the risk that the personally identifiable information provided by you may be viewed and used by third parties. RESIDENTS OF THE EEA If you reside or are located in the European Economic Area (“EEA”) you have the right, under certain circumstances, to request that we: Erase your Personal Information without undue delay. Provide you with your personal information in a structured, commonly used and machine-readable format. Rectify any inaccurate Personal Information concerning you. Restrict the way we process your Personal Information. Inform you about what Personal Information we collect about you. Don’t subject you to a decision based solely on automated processing. Do not process your Personal Information and that we do not provide your Personal Information to third parties. Noodle Partners Inc. may be the data processor, which means that we are responsible for responding to your requests in relation to how your Personal Information is used. If you have any privacy concerns or if you would like to exercise any of your statutory rights described above please let us know by contacting us at this email address privacy@noodle.com, you may use this same email address to contact Noodle’s Data Protection Officer. We will address your request or inquiry without undue delay. CALIFORNIA RESIDENTS CONSUMER PRIVACY ACT DISCLOSURES Under the California Consumer Privacy Act (CCPA), California consumers are entitled to disclosures regarding the collection and use of their Personal Information. This section describes your CCPA rights and how to exercise those rights. Collection and Disclosure of Personal Information In the past 12 months, we have collected, and may have disclosed to third parties for our business purposes, the following categories of Personal Information relating to California residents: First Name and Last Name Email Address Phone Number Zip Code Program of Interest Level of Education Attained Whether or not you’ve taken an Admissions Exam Years of work experience Information from social media and other sites Application Data Usage Data Other Personal Information described in the section above titled “Collection of Information” may have been collected. The categories of sources from whom we collected this Personal Information are: Categories of sources from whom we collect Personal Information are described above under the section titled “Collection of Information.” Purposes of collecting Personal Information: We collect the Personal Information described above to provide services to all of our users, to improve our services, and for our business purposes. We limit the collection of information to only that which is absolutely necessary to carry out our legal or business obligations, and for the purposes described under the section titled “Use and Disclosure.” The categories of third parties to whom we disclose Personal Information for our business purposes are: Affiliates of Noodle Partners for the purposes described in this policy. Third party service providers solely to assist us in providing and managing our services, such as data processing, marketing, and technology. To third parties to protect the rights of Noodle Partners and others. Rights of California Consumers under the CCPA If you are a California resident you have a right to request that we provide you with the following information from 12 months prior to your request: The categories of personal information that we have collected about you. The categories of sources from which the personal information was collected. The business or commercial purpose for collecting personal information about you. The categories of third parties with whom we shared your personal information. The specific pieces of personal information we have collected about you and may have shared. You have the right to request that we delete any Personal Information we may have collected about you, unless the CCPA recognizes an exception. The CCPA prohibits discrimination against any consumer for exercising any of the rights described above. You have the right for us to disclose and deliver the requested information to you free of charge within 45 days of us receiving a verifiable consumer request. Sale of Personal Information Under the CCPA a consumer shall have the right, at any time, to direct a business that sells personal information about the consumer to third parties not to sell the consumer’s Personal Information. Noodle Partners does not sell and has not sold any Personal Information we collect about you. How to exercise your rights If you have any privacy concerns or if you would like to exercise any of your rights under the CCPA please let us know by contacting us at this email address privacy@noodle.com. Please provide your full name, contact information, and a detailed description of your request. You may use the email above to contact Noodle’s Data Protection Officer. We will address your request or inquiry without undue delay. OTHER IMPORTANT INFORMATION Protection for Children Noodle Technology is not targeted to children, and we do not knowingly collect personally identifiable information from children younger than 13 years of age. If we become aware that personally identifiable information from a child younger than 13 years of age has been collected without the consent of such child’s parent or guardian, we will delete such information from our database without requesting permission to do so. Education Records The Family Educational Rights and Privacy Act of 1974 (“FERPA”) governs the privacy of students with respect to their education records, defined as any record directly related to a student and maintained by an educational institution or a party acting for the institution. Noodle’s policy is to comply with FERPA, which applies to all educational institutions that receive funds under any program administered by the Secretary of Education. You may have various rights that arise under FERPA. FERPA grants students the following rights: The right to control the disclosure of their education records. The right to inspect and review their education records within 45 days of making a request. The right to request an amendment of inaccurate or misleading portions of their education records. The right to file a complaint with the U.S. Department of Education regarding non-compliance with FERPA. Education records received by Noodle either from a student or another party are the property of the University. Noodle cannot release any education records to students or third parties and students must go through the University’s procedures. Please contact the University to exercise any of the rights described above. If you would like more information about Noodle Partner’s FERPA policy please contact us at this email address privacy@noodlepartners.com. QUESTIONS, CONCERNS, AND COMPLAINTS CONTACT INFORMATION If you have any privacy related questions or concerns please contact us at privacy@noodle.com. You may also write to us to Noodle Partners, Inc. 860 Broadway, 6th Floor, NY NY 10003. If you reside or are located in the EEA and you have any complaints as to how we handle your Personal Information, please contact us at the email above. You also have a right to lodge a complaint with a supervisory authority in the European Union member state that you reside in. Updates to Privacy Policy We may modify this Privacy Policy. Please look at the date below to see when this Privacy Policy was last revised. Any changes to this Privacy Policy will become effective when we post the revised Privacy Policy on the Noodle Technology. Policy changes will apply only to information collected on and after the date of the change. This Privacy Policy was last revised on January 1, 2020. QUESTIONS Contact us!