Privacy Policy

Last updated: October 18, 2022

Respect for your privacy and the security of your information are among our top priorities at AstrumU, Inc. (“AstrumU”).  This privacy policy (“Privacy Policy”) describes AstrumU’s policies and procedures on the collection, use, sharing and disclosure of your information when you use any of AstrumU’s services, including through the AstrumU.com website, our mobile application, or any future AstrumU platform (collectively, the “Services”).  Information you publish(ed) elsewhere is not governed by this Privacy Policy.  Capitalized terms that are used but not defined in this Privacy Policy shall have the meanings given to them in our Terms of Service. 

Any references in this Privacy Policy to “student,” where you are a veteran/soldier but not also a student, the term “student” shall be understood to refer to you, as a veteran or soldier.  In such cases, any references to colleges/universities or partner institutions shall be understood to refer to the U.S. military or the applicable branch or department thereof.   

 

Personal Information That We Collect

Information You Provide

We ask for certain information such as your full name, student ID number, phone number, and email address when you register for an AstrumU account, or if you correspond with us.  We also retain any data you send us through the Services, and collect information you post to the Services.  

In connection with the Services, you may provide or upload transcripts, awards, assessments, or resumes. You may also provide responses to surveys, which may include first name, last name, email address, phone number, seniority level, rank, time in military, medals, awards, military occupational specialty, age, education level, marital status, address, desired location, desired position, or similar kinds of information. 

Information We Receive About You from Your College, University, Employer or Military Agency or Department

We partner with colleges, universities, and military agencies to provide their students/soldiers with career-path recommendations, professional development, internship, or employment opportunities. Colleges, universities, and military agencies may provide us with the following information about you:

  • Personal information:  full name, ethnicity, gender, zip code, family educational background, birthdate

  • Educational information, including high school or college information (school name and location, GPA, and standardized test score)

  • Post-secondary course history 

  • Post-secondary grades

  • Post-secondary major/minor

  • Extracurricular activities

  • Other professional, experiential, and academic experiences 

  • Financial aid-related information

  • Information about your military service (e.g., awards, evaluation reports, or other records)

Information We Collect Automatically 

When you visit our website or create an account within the Services, we collect Internet protocol (IP) addresses, browser type, connection type, settings, operating system, Internet service provider (ISP), referrer URL, exit URL, the pages viewed (e.g., HTML pages, graphics, etc.), length of time viewed, operating system, date/time, downloads, and geolocation. We collect this information automatically when you visit and interact with the Services, click links within the Services, engage with our content, or open our emails. We use cookies, pixels, flash cookies or other tracking technology. We use this information to identify you and to analyze how you use the Services, to improve your experience, to remember your settings, to evaluate the performance of content, or marketing campaigns, to tailor content or marketing to you, to evaluate or analyze trends, to administer contests, sweepstakes, or promotions, for operational or security purposes such as to administer and deliver the Services, and/or to improve our Services.  

Analytics Data

We may collect analytics data, or use third-party analytics tools and services, to help us measure traffic and usage trends for the Services.  These tools collect information sent by your browser or mobile device, including the pages you visit and other information that assists us in improving the Services.  

Communications and Marketing Data

We may contact you about our Services, or additional Services you might be interested in, unless you opt-out by sending an email to unsubscribe@astrumu.com.

Non-Personally Identifiable Information

We may aggregate and/or anonymize information collected through the Services and/or our application so that such information cannot be linked back to you or any other individual.  We may use aggregated, anonymized, and other non-personally identifiable information for any lawful purpose, including for marketing, insights and reporting, and research purposes, and our use and disclosure of such information is not subject to any restrictions under this Privacy Policy.

What Do We Do with Your Data?

We use the personal data we collect to provide, support, secure, monitor and improve the Services. We also use the personal data that we collect to personalize your experience and maximize opportunities to connect you with potential employers or provide additional educational opportunities.  This includes:

  • Identifying job and internship opportunities with potential employers (which notification may be through the AstrumU platform or by email).  

  • To connect you to potential employers if you accept the invitation to connect to an opportunity with that employer.  If you elect/opt-in to pursue a particular job or internship, the following information will be viewable by that employer:  first and last name, college or university you attend(ed), your major, and any work history and military service related information. You may also elect to share your GPA (and other documents and information – such as your LinkedIn profile information and resume/CV) at this time by adjusting your profile settings, but the default setting is to not share your GPA. 

  • Personalizing your experience of our application.  For example, we or our partners may suggest employers, occupations, courses/educational programs and/or skill recommendations to you based on your profile information and the preferences you provide to us.

  • To provide you with information about educational, professional development opportunities, or other opportunities with our third-party partners, if you opt in to receive information from such third parties.

We also use personal data for the following purposes: 

  • To monitor and analyze trends, usage, engagement, and other activities in connection with the Services or our content.

  • To provide certain features or functionality to you, like enabling you to share content, or enabling downloads.

  • To analyze the Services and content, support or trouble shoot issues related to the Services, or for other internal business purposes.

  • To send you administrative or technical notices, updates, security alerts, or support messages, and to respond to your comments, questions, or other messages or requests.

  • To detect, investigate, and prevent fraudulent transactions or other illegal or harmful activities. 

  • To protect our or our third-party partner’s rights and property.

  • To protect the security or integrity of our Services.

  • To comply with regulatory and legal obligations.

  • For other purposes that may be disclosed to you at the time of collection.

How We Share Information

We share your personal data with members of our trusted network — specifically, employers, third-party partners, and our college/university and non-profit institution partners with which you are enrolled or registered as a beneficiary, in each case with your consent.

Your profile information, including information you submit, and information submitted by a university/military agency, will be viewable through our application, only with your consent, by your college/university, by prospective employers, and by our non-profit institution partners. 

As noted above, if you choose to apply for a job or internship, we will share information about you with the potential employer. You may also elect to provide additional information (such as your LinkedIn profile information and/or your resume/CV) to potential employers. 

We may share your information with third-party service providers for our business purposes, including the purpose of providing the Services to you.  Third-party service providers will be required to comply with this Privacy Policy or operate under a similar privacy policy.

If you opt-in to receive services or communications from our third-party partners (including by text message), we will share information about you, including information that you provide us or information that is provided by a university, college, or the military, with our third-party partners so that they may communicate with you and provide information that may be of interest to you such as courses, professional development or skills development recommendations. After you’ve opted in for such communications, you may opt-out by contacting us or the applicable third party. If you interact with the website or services provided by such third party, they may collect additional information about you, which is subject to the third-party partner’s privacy practices. 

We may also share your personal data in ways not described above, so long as we have your consent. 

When We Are Required to Share Your Information

AstrumU will disclose your information where required to do so by law or subpoena or if we reasonably believe that such action is necessary to (a) comply with the law and the reasonable requests of law enforcement; (b) to enforce our Terms of Service or to protect the security, quality or integrity of our Services; and/or (c) to exercise or protect the rights, property, or personal safety of AstrumU, our users, or others.

What Happens in the Event of a Change of Control

We may buy or sell/divest/transfer AstrumU (including any shares in AstrumU), or any combination of its products, services, assets and/or businesses.  Your information collected through the Services and/or our application may be among the items sold or otherwise transferred in these types of transactions and you hereby consent to such transfer or assignment.  We may also sell, assign or otherwise transfer such information in the course of corporate divestitures, mergers, acquisitions, bankruptcies, dissolutions, reorganizations, liquidations, similar transactions or proceedings involving all or a portion of the company.

How We Store and Protect Your Information

Storage and Processing

Your information collected through the Services will be stored and processed in the United States.  AstrumU may transfer information that we collect about you, including personal information, to affiliated entities, or to service providers in other countries or jurisdictions around the world.  

Keeping Your Information Safe

AstrumU cares about the security of your information and uses commercially reasonable safeguards to preserve the integrity and security of all information collected through the Services.  To protect the security of the personal data that we collect, we take reasonable steps, such as requesting a unique password, email, or ID number, to verify your identity before granting you access to your account.  You are responsible for maintaining the secrecy of your unique password and account information.  We take reasonable security measures to protect the security of all personal data; however, there is always some risk that an unauthorized third party may find a way around our security systems or that transmissions of your information over the Internet may be intercepted.  Your privacy settings may also be affected by changes to the functionality of third-party websites and services that you add to the Services, such as social networks.  AstrumU is not responsible for the functionality or security measures of any third party.

Other Protections

When student information shared by our partners includes records that are subject to the terms and conditions of the Family Educational Rights and Privacy Act of 1974, as amended (“FERPA“), AstrumU is considered a “School Official” (as that term is used in FERPA regulations) and will comply with all applicable FERPA requirements.  When soldier or veteran information is shared with us directly by a U.S. military branch or department, such records may be subject to the terms and conditions of the Privacy Act of 1974, as amended, and AstrumU will comply with all applicable requirements thereunder.

COPPA/CAL-COPPA Regulation

AstrumU does not knowingly collect or solicit any information from anyone under the age of 13 or knowingly allow such persons to register as users.  The Services and their content are not directed at children under the age of 13.  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 privacy@astrumu.com.

Your California Privacy Rights

If you are a California resident, the California Consumer Protection Act (CCPA) provides you with additional rights regarding our use of your personal data.  The rights outlined in this section do not apply to information exempted under the CCPA, including aggregated data, applicant information, or to individuals who are not residents of California. 

CCPA Rights

To the extent provided under the CCPA, and subject to applicable exceptions, California residents have the following rights with respect to the personal data that we collect:

  • The right to request the categories of personal data we have collected, the sources from which we collected the personal data, the categories of third parties with whom we share personal data, and the business or commercial purpose for collecting or selling (if applicable) personal data,

  • The right to request a copy of the personal data that we have collected during the past 12 months,

  • The right to opt out of sales of personal data (if applicable), 

  • The right to request that we delete the personal data that we have collected, and

  • The right to exercise the rights described above free from discrimination as prohibited by the CCPA.

Categories of Personal Information That We Collect

For the purpose of CCPA, we collect the following categories of personal data: 

  • Identifiers:  real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver’s license number, or other similar identifiers.

  • Personal Information Categories Listed in California Customer Records Statute:  name, address, telephone number, driver’s license or state identification card number, education, employment, or employment history.

  • Protected Classification Characteristics Under California or Federal Law:  age, race, color, ancestry, national origin, citizenship, religion or creed, marital status, physical or mental disability, sex, veteran, or military status.

  • Commercial Information:  records of products or services that you purchase from us or our partners. 

  • Internet or Other Similar Network Activity:  browsing history, information on your interaction with the Services.

  • Geolocation (not precise geolocation).

  • Professional or Employment Related Information:  current or past job history or performance evaluations.

  • Non-Public Education Information:  education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

  • Inferences Drawn from Personal Information:  profiles reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

We obtain the above information directly from you when you sign up for our Services, indirectly from you through your interactions with the Services, or from third-party partners such as universities, colleges, or military agencies when they sign up for the Services. We use your personal information in the manner disclosed in this Privacy Policy and share your information in the manner disclosed in this Privacy Policy.

Categories of personal information that we have not collected in the past twelve months: 

  • Biometric Information 

  • Sensory Data

We do not “sell” personal information as the term “sell” is traditionally understood. However, if you opt in to receive text communications from us about educational programs, we share your information with third-party partners. These third-party partners recommend educational programs to you based on your profile with us. We receive compensation from these third-party partners. To the extent that our sharing of information with these third-party partners is considered a sale, you have the right to opt-out. You may submit a request to opt-out of by clicking Do Not Sell or Share My Personal Information.  

Exercising Your CCPA Rights

California residents may exercise CCPA rights by contacting us by phone or email as indicated in the Contact Information section below. Your rights may only be exercised by you or by your designated agent. You may submit a CCPA request to know no more than twice within a 12-month period. 

Your request must include enough information to allow us to reasonably verify that you are the person about whom we collected personal information or an authorized representative, which may include: (1) verifying your account information if you have an account within the Service, or (2) requesting two forms of identification that are reliable for verification purposes, unless the request includes sensitive information and, in which case, we may require three forms of verification and a signed declaration. The information included in your request must allow us to properly understand, evaluate, and respond to it.

We cannot respond to your request if we cannot verify your identity or authority to make the request and confirm that the personal information relates to you.  If we cannot verify your identity or authority, we will not fulfill your request. We will only use personal data provided in the request to verify the requestor’s identity or authority to make it.

You may submit a request through a designated agent. You must instruct that agent that they will need to state that they are acting on your behalf when making the request, have reasonably necessary documentation, and be prepared to provide the necessary personal information to identify you in our database.

Financial Incentives

Financial incentives are programs, benefits, or other offerings, including payments to consumers as compensation, for the disclosure, deletion, or sale of personal information about them. We do not offer financial incentives in exchange for information.  

California Shine the Light Disclosure

Under California Civil Code sections 1798.83- 1798.84, California residents are entitled to ask for a notice identifying the categories of personal customer data which we share with our affiliates and/or third parties for their own direct marketing purposes and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to the address in the Contact Information section below.

Nevada Resident Privacy Rights

If you are a resident of Nevada, you have the right to opt out of the sale of certain information to third parties who intend to license or sell that information. You can exercise this right by contacting us at privacy@astrumu.com with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address.

Links to Other Websites and Services

We are not responsible for the practices employed by websites or services linked to or from the Services, including the information or content contained therein.  Please remember that when you use a link to go from the Services to another website, our Privacy Policy does not apply to third-party websites or services.  Your browsing and interaction on any third-party website or service, including those that have a link or advertisement on our website, are subject to that third party’s own rules and policies.  In addition, you agree that we are not responsible for, and we do not have any control over, any third parties that you authorize to access your personal data.  If you are using a third-party website or service (like Facebook or Twitter) and you allow such a third party access to your personal data, you do so at your own risk.  This Privacy Policy does not apply to information we collect by other means (including offline) or from other sources other than through the Services.

ReadySet and SkillSet

If you are a student who has opted-in to AstrumU, the following disclaimer shall apply:

Our Predictive Individual Learner (PIL) scoring system is based on a proprietary data model, which includes information from a number of independent third-party data sources; however, we do not guarantee the accuracy or usefulness of its results and you are solely responsible for how you use them.  Data with respect to employment compensation are self-reported by graduates of their respective academic institutions and are not verified by the employers.  All information and data provided on any websites owned or operated by AstrumU or in any of AstrumU’s communications are for informational purposes only, and are not an endorsement, guarantee or other recommendation, whether favorable or unfavorable, regarding a particular institution, academic course or program, or job or career path; and do not represent any type of promise or prediction of future performance, employment, career objective, or salary to be achieved.  SPECIFICALLY, THE INFORMATION WE PROVIDE MAY NOT BE RELIED UPON AS A GUARANTEE OF EMPLOYMENT OR LEVEL OF COMPENSATION UPON COMPLETION OF ANY ACADEMIC COURSE OR PROGRAM.  We make no representation or warranty about, and accept no legal liability whatsoever arising from or regarding any of the information provided by AstrumU, all of which is subject to change without notice and is provided free of charge and for informational purposes only.

Account Closure

Students may opt-out of our application by emailing optout@astrumu.com to deactivate their accounts, upon which students will no longer be visible to employers or to our college/university or non-profit institution partners, and they will no longer receive any communication from AstrumU unless they reactivate their accounts.

Deactivation of Account and Deletion of Your Data

You can choose to deactivate your account so that you are no longer viewable on the Services or you can make your account private.  You may also request that AstrumU delete information about you; however we may be obligated as a service provider to your college/university to retain certain data about you.  This means that if they re-send us your data to process on their behalf, we will retain it unless they request that we delete it.  You can request deactivation or deletion by sending a message to privacy@astrumu.com or by contacting your college/university to ask them to delete your information.

Changes to This Privacy Policy 

Whenever this Privacy Policy is changed in a material way, all users will receive an email with notification of the changes prior to the changes becoming effective.  Your use of the Services after the effective date of the modified Privacy Policy constitutes acceptance by you of any changes made to it. 

Contact Information

AstrumU, Inc.
737 Market Street 
Kirkland, WA 98033

privacy@astrumu.com

(425) 985-9258