Privacy Policy
COMET PRIVACY POLICY
Last Updated: June 30, 2022
This Privacy Policy applies to web sites operated by Collegelama Inc., dba Comet (“Comet”), including www.applywithcomet.com and my.applywithcomet.com (together the “Comet Sites”). By visiting or using the Comet Sites, and any other linked pages, features, content, or any other services we offer from time to time in connection therewith, you acknowledge that you accept the practices and policies outlined in this Privacy Policy, and you hereby consent that we will collect, use, and share your information in the following ways.
1. GENERAL POLICY STATEMENT
Comet is a free, online guidance platform used by students to navigate the college admissions process, including tools and information to help students build their college lists, write their essays, and apply to colleges. To provide our services, we often collect detailed personal information from you. This Privacy Policy covers our treatment of the personally identifiable information (“Personal Information”) that we gather when you access or use the Comet Sites and services and explains our information collection and sharing practices, as well as the choices you can make to limit our sharing your information.
Platform features currently in-development will also allow you to share your profile with colleges that are interested in connecting with you. We give you control over whether you want to make your profile accessible to colleges and what information you wish to include in your public profile. Your Personal Information is only viewable to colleges when you choose to make your profile accessible to colleges and your profile is never visible to other users.
This policy does not apply to the practices of companies that we do not own or control, or to individuals that we do not employ or manage. Information you choose to disclose publicly on the Comet Sites (i.e., information you choose to post or share in our public forums, communities and with other users) will not be considered Personal Information.
In general, we use this Personal Information to deliver personalized services to our users. We also share your Personal Information with vendors (for example, marketing automation vendors or hosting providers) as needed to assist Comet with business operations, but in such instances, these vendors are contractually required to keep your information confidential.
We may also use information about how you interact with the Comet Sites to generate aggregated data and insights that may also be shared with our partners. We take steps to ensure that this data is always anonymous and not identifiable in any way.
2. INFORMATION WE COLLECT
Comet collects and stores information you provide to us. For example, during the registration process, we collect Personal Information such as your name, username, email address, and third-party account credentials (for example, permission to authenticate you via your Google Account or other third-party sites). If you provide your third-party account credentials to us, you are consenting to have the information in those accounts (“Third-Party Account Information”) transmitted into your account with us, and that Third-Party Account Information is covered by this Privacy Policy. We may also collect other Personal Information you provide to us through your use of our services, such as your address, phone number, date of birth, photo, financial information, other academic and demographic variables relevant to the college selection/admission process, including college applications, admissions results, financial aid offers, and reviews and feedback related to use of our products and services.
Comet does not knowingly collect or solicit Personal Information from anyone under the age of 13 or knowingly allow such persons to register. If you are under 13, please do not attempt to register for the Comet Sites or send any information about yourself to us, including your name, address, telephone number, or email address.
No one under age 13 may provide any personal information to Comet or on the Comet Sites. In the event that we learn that we have collected personal information from a child under age 13 without verification of parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13, please contact us at info@applywithcomet.com.
Whenever you interact with the Comet Sites, we automatically receive and record information on our server logs from your browser including your IP address, “cookie” information, and the page you requested. Information gathered through cookies and our web server logs may include the date and time of visits, your IP address, the pages viewed, time spent at our Comet Site, and the web sites visited just before and just after a Comet Site. This information may be appended to your profile information to provide you with better service and information and may be shared with partners as detailed in this Privacy Policy.
3. HOW WE USE THE INFORMATION WE COLLECT
We may use and share the information you supply to Comet in the following ways:
Comet uses your information to customize your experience on the Comet Sites based on your profile and interests and to deliver a more personalized guidance experience. Comet uses various methods to recognize you, including cookies and requesting your email address and password before accessing our site.
Comet may use your contact information to send you e-mail messages regarding updates to the Comet Site, such as the publication of new Comet information and content, promotional offers, or to communicate with you about your use of the Comet Sites. The frequency of these messages will vary depending upon your profile. You may opt-out of receiving these emails at any time via the unsubscribe link contained in the email message.
Comet Sites may invite you to participate in surveys, contests and other promotions relevant to the college search process. If you participate, your personally identifiable information may be shared with third party marketing partners to process entries and send you promotional material. Please consult the official rules of any contest or sweepstakes you enter on a Comet Site as specific data collection, usage, and information sharing practices may vary by contest and sweepstakes. Survey information will be used to monitor or improve the Comet Sites, but we will not share individual responses to a survey without your consent.
We may use anonymous information about how you use Comet Sites (e.g., the schools in which you are interested in, schools to which you apply, the participants you connect to on the Comet Network) to improve the functionality of Comet Sites and improve Comet’s service offerings, including using this data at an aggregate level to create data analytics offerings to analyze trends.
Comet may use the reviews and feedback you provide to us related to your use of the products and services for marketing purposes.
Comet uses third party vendors to perform operational functions related to the Comet Sites. Some of these vendors (e.g., marketing automation vendors, email vendors or hosting providers) may have access to your personally identifiable information, but only as necessary to provide services to Comet. Comet has agreements in place with these vendors requiring them to keep your information confidential and use reasonable data security measures to protect it.
Comet Sites may use third party analytics services to help improve usability and the customer experience. These services may record mouse clicks, page views, mouse movements and scrolling activity and are used by Comet to analyze trends and administer the Comet Sites.
For advertising purposes, we occasionally use information about our customers to generate a "lookalike audience" or similar audience of prospective customers through Facebook, Google, and other online advertising platforms. This allows us to target advertisements on their networks to potential customers who appear to have shared interests or similar demographics to our existing customers, based on the platforms' own data. We typically do this by uploading a list of email addresses which are used to generate the lookalike audience. Email addresses that are sent to these platforms are used for no other purpose, other than to build the lookalike audience. We do not have access to the identity of anybody in the lookalike audience, unless they choose to click on the ads. Based on this, we believe that generating lookalike audiences poses little or no threat to the privacy of our customers.
This Privacy Policy applies only to the Comet Sites. While Comet Sites may link to other third-party web sites, information you may provide on a linked site once you leave the Comet Site is not controlled by Comet and is not controlled by this Privacy Policy. You should consult the privacy policy of any linked sites before providing your information to those sites.
Comet will release your personal information if required by law, for example, if we receive a subpoena or otherwise believe in good faith that the law requires us to release your information.
If Comet sells any part of its business, Comet may transfer your information to its successor, regardless of your opt-out status.
4. PRIVACY OPTIONS
You may deactivate your account or opt-out of receiving certain types of communications contacting our customer support team at support@applywithcomet.com. If you deactivate your account, we will retain your information in our active database, but will not use it to contact you or share with partners. Comet will communicate with you only according to your listed preferences. In order to opt-out of third-party communications, you will need to contact the applicable third party. If you have any questions relating to opting-out, please contact us at support@applywithcomet.com,You can update your personal information by contacting us at support@applywithcomet.com.You may close your account on a Comet Site by sending an email to support@applywithcomet.com and we will remove your personal information from our active database. Once your account is closed, we will discard your personally identifiable data, but we may retain certain data for internal business purposes, such as analysis of non-personally identifiable data or as may be required by applicable law.
5. OUTSIDE OF THE UNITED STATES
Comet Sites are operated in the United States. If you are located outside of the United States, any information you provide to us will be transferred to the United States. By using the Comet Sites or by providing us with your information, you consent to this transfer.
6. DATA SECURITY PROCEDURES
Comet has reasonable security measures in place to keep the information you provide to us safe from unauthorized access. However, no method of information transfer over the Internet is 100% secure and we cannot guarantee the security of your information during its transmission or storage in our systems. We will assume that anyone who has the required login/password information for your account is you, so please keep this information confidential. Vendors and contractors who perform operational services for Comet Sites and have access to your personally identifiable information are required to keep the information confidential.
If you have any questions about security issues, please e-mail us at info@applywithcomet.com.
7. CALIFORNIA ONLINE PRIVACY PROTECTION ACT("CALOPPA") DISCLOSURES REQUIRED BY 2013 AMENDMENT
Information provided in this Section 7 pursuant to CalOPPA is in addition to the disclosures contained in other sections of this Privacy Policy, which also address some CalOPPA requirements.
Do Not Track ("DNT") Signals - Web browsers offer you an option to send "Do Not Track" signals to websites you visit. Comet Sites may use third-party ad servers, retargeting services and web analytics systems, such as Google, to provide advertising on our sites, analyze aggregate web usage statistics and provide us the ability to display advertisements to you when you have left our site. Comet does not respond to DNT Signals as it does not track you when you leave a Comet Site. Comet's third party service providers, who provide ad serving, retargeting services and web analytics services to Comet, may not respond to DNT signals. If a user comes to a Comet Site directly with a DNT signal enabled on such user's browser, Comet does not look for the DNT signal or respond to it.
Third Party Collection of Personally Identifiable Information - Other than as specified in this Privacy Policy, we generally do not allow third parties to collect your personally identifiable information provided on the Comet Sites. In some cases, however, our third-party service providers may collect information through the Comet Site in order to assist Comet in operating its web sites and services. Section 3 of this Privacy Policy contains additional information on how we share your information with third party service providers.
8. CHANGES TO THIS PRIVACY POLICY
We may amend this Privacy Policy from time to time and will change the Last Updated date on this policy when we do so. Use of information we collect now is subject to the Privacy Policy in effect at the time such information is used. If we make changes in the way we use Personal Information, we will notify you by posting an announcement on the Comet Sites or sending you an email. You are bound by any changes to the Privacy Policy when you use the Comet Sites after such changes have been first posted.
9. QUESTIONS
If you have any questions regarding our privacy policies, please send a message to info@applywithcomet.com.Alternatively, you may contact us at our offices:
Comet
4701 Patrick Henry Dr Bldg 25
Santa Clara, CA 95054
Attn: Chief Technology Officer