1. Appily and Our Commitment to Your Privacy

Who Is Appily? Appily (“Appily”, “us,” “we,” and “our”), is a d/b/a for Cappex.com, LLC, a wholly-owned subsidiary of EAB Global, Inc. (“EAB”), which operates www.appily.com, a data-driven enrollment resource partnering with colleges, universities, counselors, scholarship administrators, EAB, employers, marketing partners and advertisers to support students and families in their journey to college.

Appily’s Commitment to Privacy.  EAB is deeply committed to maintaining the privacy and security of personal information we collect.

Scope of this Privacy Notice.  This Privacy Notice governs our processing of personal information in connection with our Appily service.  This Privacy Notice does not relate to anonymized, aggregated, or de-identified data, or any other information that does not allow us to identify you.

Data Controller.  Appily is the data controller in relation to the data processing activities described in this Privacy Notice.

Updates to this Privacy Notice. From time to time, this Privacy Notice may be updated to reflect changes to our products and services, the way we operate, or to meet new legal and regulatory requirements. You will find the latest version of this Privacy Notice here.

2. Personal Information That We Collect

The type of personal information we collect about you depends upon your relationship with us. The other sections in our Privacy Notice apply to all our activities.

Prospective Students

We collect personal information about prospective students who use the Appily College Search and Tours services in the following manner:

• Directly from you: We collect certain personal information directly from you when you register for the Appily services, including your name, date of birth, email address, telephone number, GPA and test scores, your academic and career preferences, and information relating to financial aid.  You also may provide personal information to us in connection with your use of the Appily services, for example, if you complete surveys or polls or communicate with academic institutions.

• Indirectly from you: We collect information about the pages you visit and how you access and use our services using cookies and third-party analytics tools (e.g., log files, event data, tracking pixels, GPS data, clear gifs and scripts). This information includes information about the device(s) you use to access the service including unique device identifiers, IP address, operating system, browser, internet service provider, referring/exit pages, clickstream data and cookies. Depending on your device settings, we may also collect information about your geographical location. Learn more about our use of cookies, plugins, analytics or similar tools in our Cookie Notice.

• Sensitive Information.  We may obtain information relating to your ethnicity, gender or gender identity, religion, and information relating to your health, such as any disabilities, where we are permitted to do so by law or where you give your consent.

• Third Party Integrations, Links and Features. You may connect third party integrations to your Appily account(s) (e.g., Google SSO), which may ask for certain permissions to send information to your Appily account. Appily’s use and transfer of information received from Google APIs will adhere to the Google API Services User Data Policy. Appily also provides links to certain third parties that offer scholarships. These third party features operate independently from us. The privacy practices of the relevant third parties, including details on the information they may collect about you, are subject to the privacy statements of these parties, which we suggest you review. To the extent any linked online service or third-party feature is not owned or controlled by Appily, we are not responsible for these third parties’ information practices.

3. How We Use the Personal Information That We Collect

EAB collects, retains, processes, uses, and transfers your personal information for the following purposes:

• Providing the Appily service.  We use personal information that we collect in order to verify the identity of users, provide the Appily services that you request, communicate with users of the Appily services, customize your Appily experience, manage relationships with users of the Appily services, provide support and troubleshooting services, and improve the Appily services. 

• Analytics.  We use personal information that we collect in order to analyze use of the Appily services and expected interest in the relevant academic institution being considered, enhance the services, develop new products or services, and to perform market, trend and statistical research and analysis. 

• Record Keeping.  We use personal information that we collect for our internal record keeping purposes, and for accounting, audit and other internal functions. 

• Marketing. When you have given your consent for us to do so, we may contact you to provide marketing materials about the Appily services, EAB’s other products and services or third party products or services.

• Interest-Based or Targeted Advertising. Appily may obtain information about your online activities to provide you with advertising about products and services that may be tailored to your interests. This type of advertising is commonly referred to as interest-based advertising or targeted advertising. You may see our ads on other websites because we use third-party ad services. These services track your online activities over time and across multiple third-party websites and apps by collecting information through automated means, including through the use of cookies, web server logs, web beacons and other similar technologies. The ad services use this information to show you ads that may be tailored to your individual interests. The ad services may collect information including data about your visits to websites that serve Appily advertisements, such as the pages or ads you view and the actions you take on the websites or apps. This information may be used for purposes of conversion tracking. This process also helps us track the effectiveness of our marketing efforts. To learn how to opt out of interest-based or targeted advertising, please visit www.aboutads.info/choices, www.networkadvertising.org/choices/, and http://preferences-mgr.truste.com/. If you are a California resident, please see the California Appily Privacy Notice here for more information about your right to opt out of the “sale” or “sharing” of your personal information in this context.

• Compliance with Law and Internal Policies.  We use the personal information that we collect in order to comply with applicable legal requirements and our internal policies and procedures.  We also may use personal information to conduct internal investigations relating to use of the Appily services, or to establish, exercise or defend legal claims. 

4. How We Share the Personal Information That We Collect

We may share the categories of personal information we obtain about you (as described above) with the categories of third parties third parties listed in this section. We may share your personal information with:

• The colleges, universities, scholarship providers and other parties related to the college admissions, financial aid and employment process that you intentionally identify or approve on the service.

• The university or academic institution of which you are attending a virtual tour.

• EAB and its affiliates in order to perform the Appily services.

• Service providers that perform services on our behalf.

  • We may share personal information with service providers that perform services on our behalf such as hosting providers, analytics providers, helpdesk providers, data cleanliness providers, and direct marketing services providers.  In accordance with applicable law, we have entered into legally binding agreements requiring them to use or disclose personal data only as necessary to perform services on our behalf or comply with applicable legal requirements.

• Third-party web analytics services.

  • Appily may collect personal information about your online activities on websites and connected devices over time and across third-party websites, devices, apps, and other online features and services for analytics purposes. We may use third-party analytics services, such as Google Analytics and Adobe Analytics.  The information we obtain may be disclosed to or collected directly by these providers and other relevant third parties who use the information, for example, to evaluate use of the Appily service or help administer the Appily service.  To learn more about Google Analytics, please visit https://www.google.com/policies/privacy/partners/.  To learn more about Adobe Analytics, please visit https://www.adobe.com/privacy.html.

• Appily may from time-to-time share your information with advertisers and other marketing partners who are interested in marketing to your unique demographic in exchange for fees or other consideration. This type of sharing may constitute a sale under applicable law. This could include colleges, universities, scholarship providers and other parties related to the college admissions and financial aid process, parties who sell products and services that may be of interest to you or other data aggregators that use the data for a variety of purposes. These third parties may share your personal information with other marketers or data aggregators. If you do not want us to sell your information as described in this paragraph, we encourage you to opt out of these sales of your information here.
• In addition, we may disclose personal information about you (a) if we are required or permitted to do so by law or legal process, for example due to a court order or a request from a law enforcement agency, (b) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, (c) in connection with an investigation of suspected or actual fraudulent or other illegal activity, or (d) in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution, or liquidation).

5. Children’s Privacy

EAB’s products and services are not intended for children under the age of 13, and we do not knowingly collect any information from children. If we learn that we have collected or received personal information from a child under 13, we will delete that information upon request. Please contact us at [email protected] if you believe we have inadvertently collected personal information from a child under 13.

6. Your Rights and Choices

If you are a California resident, for more information about your privacy rights, please see our Privacy Notice for California Residents here.

If you are a resident of Colorado, Connecticut, Utah or Virginia, you may have the right to request:

that we provide you with access to the personal information collected about you;

that we provide a copy of your personal information to you in a portable format;

that we correct or update your personal information that is inaccurate, incomplete or outdated and that you are not otherwise able to update via your profile;

that we delete your personal information;

to opt out of the sale of your personal information to third parties; or

to opt out of the processing of your personal information for purposes of targeted advertising.

You may also have the right to appeal our decision with respect to a request you have submitted here.

If you wish to exercise any of the rights described above in relation to your personal information, please submit a request to Appily by clicking here. Prior to fulfilling your request, we will take reasonable steps to verify your identity. To submit an opt-out request as an authorized agent on behalf of a consumer, please click here.

To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request. If you choose to exercise any of these rights, you have the right to not receive discriminatory treatment by us.

7. Security

We employ a variety of physical, administrative, and technological safeguards designed to protect personal information against loss, misuse, and unauthorized access or disclosure.

8. Contact Us

If you have any questions or concerns about our Privacy Notice or data privacy practices, contact us at [email protected] or write to us at the following address.

EAB Global, Inc. 
Attn: General Counsel

2445 M Street, NW
Washington, DC 20037