Updated: December 12, 2023

ScholarSelect, LLC (doing business as SmarterSelect) and its affiliates (“SmarterSelect” “we,” “us,” or “our”) respect your privacy. This Privacy Policy describes the processing of Personal Information (defined below) that is provided, collected, or shared on the sites, applications, social media pages, or other platforms that link to this Privacy Policy (collectively, the “Site”), and in connection with providing our products and services (collectively, “Services”). It also describes your choices about the collection, sharing, and use of your Personal Information. 

SmarterSelect acts as a processor of Personal Information on behalf of its customers. As such, this Privacy Policy does not apply to the Personal Information collected by our customers. Our customers are responsible for deciding how their data is used, so please see their applicable privacy policy for more information.  SmarterSelect does not sell or share Personal Information in connection with providing our Services.

Personal Information We Collect

We may collect a range of Personal Information. “Personal Information” means information that uniquely identifies, relates to, describes, or is reasonably capable of being associated with or linked to you. 

The types of Personal Information we collect may include:

• Contact Information – If you submit an inquiry, register for an account, or provide information on our Site, we may collect your contact information. This may include your name, email address, demographic information, and phone number.  

• Location Data – While navigating our Site your mobile device or browser may share your location data, both through WIFI and GPS. We will collect this information based on the settings of your phone and browser.  

• Usage Information – When you use our Site, our servers may automatically record information, including your Internet Protocol address (“IP Address”), browser type, referring URLs (e.g., the site you visited before coming to our Site), domain names associated with your internet service provider, information on your interaction with the Site, and other such information. 

• Employment Information – If you apply for employment, we will collect your employment and work history, as well as other Personal Information related to your potential employment. This may include your education and employment history, address and contact information, demographic information, and any other information included in your resume or application.  

• Communication Information – We may collect audio, electronic, or visual information, which includes screen sharing views; any data in any files uploaded, emailed, or otherwise provided by customers; the contents of your communications with us, whether via our chat functionality, e-mail, social media, telephone or otherwise, and inferences we may make from other Personal Information we collect. You acknowledge and agree that the content of your messages to us may be recorded. 

How We Collect Your Personal Information 

• We May Collect Your Personal Information Directly From You – For example, if you register for an account on the Site or via our Services, or request or purchase products, Services, or information from us.

• We May Also Collect Personal Information From Third Parties – For example, we may work with business partners, subcontractors, advertising networks, analytics providers, and search information providers, who may provide us with Personal Information about you.

• Through Online Tracking Technologies – We and our service providers may use cookies, device identifiers, and similar technologies such as pixels, web beacons, and local storage to collect usage and browser information about how you use the Site.  We process the information collected through such technologies, which may include or be combined with Personal Information, to help operate certain features of the Site, to enhance your experience through personalization, and to help us better understand the features of the Site that you and other users are most interested in.  

Most browsers provide you with the ability to block, delete, or disable cookies, and your mobile device may allow you to disable transmission of unique identifiers and location data. If you choose to reject cookies or block device identifiers, some features of the Site may not be available, or some functionality may be limited or unavailable.  Please review the help pages of your browser or mobile device for assistance with changing your settings.

Some of our service providers or plug-ins may use cookies or other methods to gather information regarding your use of the Site and may combine the information in these cookies with any Personal Information about you that they may have. The use of such tracking information by a third party depends on the Privacy Policy of that third party. We do not respond to Do Not Track (“DNT”) signals sent to us by your browser at this time. To learn more about how DNT works, please visit http://allaboutdnt.com/.

Online Behavioral Advertising.  We use third parties and/or service providers to provide interest-based advertising services. These services may serve advertisements on our behalf that are customized based on predictions about your interests generated from your visits to websites (including this Site) over time and across different websites. The data collected may be associated with your Personal Information. These advertisements may appear on the Site and on other websites and may be sent to you via email.  

We use technology to serve ads across various websites, like Google Ads. Google uses Cookies to collect data about your visits to the Site to generate targeted advertisements to you on other websites that you visit. To opt-out of this type of advertising by Google, to customize your ad preferences, or to limit Google’s collection or use of such data, visit Google’s Safety Center and Google’s Ad Settings and follow Google’s personalized ad opt-out instructions. Opting out will not affect your use of the Site.

SmarterSelect does not advertise to individuals whose Personal Information is processed via our Services on behalf of its customers.

To obtain more information about ad networks and online behavioral advertising, visit National Advertising Initiative Consumer opt-out page or the Digital Advertising Alliance Self-Regulatory Program. Changing your settings with individual browsers or ad networks will not necessarily carry over to other browsers or ad networks. As a result, depending on the opt-outs you request, you may still see our ads. Opting out of targeted advertising does not opt you out of all ads, just those targeted to you.

• Through Analytics – We use analytics services, including Google Analytics, to assist us with analyzing our website traffic through cookies and similar technologies.  For more information on Google Analytics’ processing of your Personal Information, please see https://policies.google.com/technologies/partner-sites?hl=en-US.  You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout. 

How We Use Personal Information

To the extent permitted by applicable law, we may use Personal Information to:

• operate the Site and provide support to our business functions;

• fulfill customer requests, such as to create an account or complete customer financial transactions or purchases;

• protect against criminal activity, claims and other liabilities;

• send you information about our company, products, Services, and promotions;

• respond to reviews, comments, or other feedback provided to us;

• support and personalize the Site and our advertising efforts;

• protect the security and integrity of the Site;

• provide customer support;

• the extent required for benchmarking, data analysis, audits, developing new products, enhancing the Site, facilitating product, software and applications development, improving the Site or our Services, conducting research, analysis, studies or surveys, identifying usage trends, as well as for other analytics purposes;

• meet our contractual requirements;

• comply with applicable legal or regulatory requirements and our policies;

• respond to inquiries related to employment opportunities;

• market, advertise, and provide the Site and our Services to its users and customers; and

• the extent necessary for any other lawful purpose for which the Personal Information is collected.

• Sharing of Personal Information

We may share your Personal Information in the following circumstances:

• For Legal Obligation or Safety Reasons – When we have a good faith belief that access, use, preservation or disclosure of Personal Information is reasonably necessary to (a) satisfy or comply with any requirement of law, regulation, legal process, or enforceable governmental request, (b) enforce or investigate a potential violation of the Terms of Use, (c) detect, prevent, or otherwise respond to fraud, security or technical concerns, (d) support auditing and compliance functions, or (e) protect the rights, property, or safety of SmarterSelect, its users, or the public against harm.

• In the Case of a Merger or Sale – If and when we are involved in a merger, acquisition, or any form of transfer or sale of some or all of its business, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding. Personal Information may be transferred along with the business. Where legally required we will give you prior notice and if you have a legal right to do so, an opportunity to object to this transfer.

• To Service providers – When we hire a service provider to help operate the Site or our business, we may give access to Personal Information as necessary to perform the service for SmarterSelect.  This may include service providers that operate our Site, send our communications, or run our promotions. 

How Long Do We Keep Your Personal Information

We will retain your Personal Information for as long as necessary to fulfill the purposes for which it has been collected, as outlined in this Privacy Policy, or any longer retention period required by law.  

How We Protect Your Personal Information

We use our commercially reasonable efforts to protect the confidentiality and security of Personal Information we process. However, despite these efforts to store Personal Information in a secure operating environment, we cannot guarantee the security of Personal Information during its transmission or its storage on our systems. Further, while we attempt to ensure the integrity and security of Personal Information, we cannot guarantee that our security measures will prevent third parties such as hackers from illegally obtaining access to Personal Information. 

Your Choices and Controls

Depending on where you live, you have the right to exercise certain controls and choices regarding our collection, use, and sharing of your Personal Information. To opt-out of marketing communications please follow the instructions included in the email or text correspondence.  

Please note that, even if you unsubscribe from certain correspondence, we may still need to contact you with important transactional or administrative information, as permitted by law.  Additionally, if you withdraw your consent or object to processing, or if you choose not to provide certain Personal Information, we may be unable to provide some or all of our Services to you.

To exercise other rights with respect to your Personal Information, please contact us using the information in Section 15 below. If you are a resident of California, please see the information below in Section 11 (California Residents) for more information regarding your rights. 

International use of the Site

This Site is hosted in the United States. If you are visiting this Site from outside of the United States, please note that by providing your Personal Information it is being transferred to, stored, collected, or processed in the United States, where our data center and servers are located and operated. 

Children’s privacy 

We do not knowingly collect or solicit any Personal Information from children under the age of 16.  In the event that we learn that we have collected Personal Information from a child, we will promptly take steps to delete that information. If you are a parent or legal guardian and think your child has given us their Personal Information, you can email us at privacy@smarterselect.com or contact us using the information listed in Section 15.

Links to third-party websites

We are not responsible for the practices employed by any websites or services linked to or from the Site, including the information or content contained within them. We encourage you to investigate and ask questions before disclosing Personal Information to third parties, since any Personal Information disclosed will be subject to the applicable third party’s Privacy Policy.

California residents

This Section applies to our collection and use of “Personal Information” if you are a resident of California, as required by the California Consumer Privacy Act of 2018 and its implementing regulations, as amended by the California Privacy Rights Act (the “CPRA”). This Section describes (1) the categories of Personal Information, collected and disclosed by us, subject to CPRA, (2) your privacy rights under CPRA, and (3) how to exercise your rights.

When we use the term “Personal Information” in the context of the CPRA, we mean information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California consumer or household.  

If you would like to receive a copy of this Section in an alternate format (e.g., printable) or language, please contact us using the information provided in Section 15.

 Categories of Personal Information Collected, Used, and Shared

We have collected the following categories of Personal Information from our consumers within the last 12 months. The sources from which we obtain this information and the ways in which we use this information are set forth in Section 4 above. We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

We will retain each category of your personal information for as long as necessary to fulfill the purposes described in the “How We Use your Information” section above, unless otherwise required by applicable laws. Criteria we will use to determine how long we will retain your information include whether: we need your information to provide you with products or services you have requested; we continue to have a relationship with you; you have requested information, products, or services from us; we have a legal right or obligation to continue to retain your information; we have an obligation to a third party that involves your information; our retention or recordkeeping policies and obligations dictate that we retain your information; we have an interest in providing you with information about our products or services; and we have another business purpose for retaining your information. 

Your California privacy rights

Subject to certain exceptions, if you are a resident of California, you may have the following rights:

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a request related to your Personal Information. You may also make a request on behalf of your minor child.

You may only make a request for access or data portability twice within a 12-month period. The request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.

• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

Exercising Your Individual Privacy Rights

If you would like to exercise your rights listed above, please send (or have your authorized agent send) an email to privacy@smarterselect.com.  Please note: you will not be discriminated against in any way by virtue of your exercise of the rights listed below, which means we will not deny goods or services to you, provide a different prices or rates for goods or Services to you, or provide a different level or quality of goods or Services to you.  

Verification: We must verify your identity before fulfilling your requests.  If we cannot initially verify your identity, we may request additional information to complete the verification process. Any Personal Information you disclose to us for purposes of verifying your identity will solely be used for the purpose of verification.  If you are an authorized agent making a request on behalf of a California consumer, we will also need to verify your identity, which may require proof of your written authorization or evidence of a power of attorney.

We endeavor to respond to requests within the time period required by applicable law. If we require more time, we will inform you of the reason and extension period in writing. 

We will deliver our written response by mail or electronically, at your option.

We do not charge a fee to process or respond to your request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity and confirm the Personal Information relates to you. Making a verifiable consumer request does not require you to create an account with us 

We may deny certain requests, or only fulfill some in part, as permitted or required by law.  For example, if you request to delete Personal Information, we may retain Personal Information that we need to retain for legal purposes (e.g., tax accounting).  You have a right not to receive discriminatory treatment by any business when you exercise your California privacy rights.

The CCPA gives California Consumers the right to lodge a complaint with the California Attorney General’s office. The Attorney General’s office may be contacted at https://oag.ca.gov/contact/consumer-complaint-against-business-or-company or by telephone at: (916) 210-6276.

Changes to this Privacy Policy  

Please note that we may modify or update this Privacy Policy from time to time, so please review it periodically. We may provide you with an updated Privacy Policy if material changes are made. Unless otherwise indicated, any changes to this Privacy Policy will apply immediately upon posting to the Site.  

Contact us

If you have any questions about our practices or this Privacy Policy, please contact us at privacy@smarterselect.com.

SmarterSelect, LLC

5411 McCommas Blvd. 

Dallas, TX 75206