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1. NOTICE
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This Privacy Policy applies to properties owned and operated by The Common Application, Inc. (“Common Application”, “We”, “Us”, “Our”), which include www.commonapp.org, apply.commonapp.org, and recommend.commonapp.org, (“Web Site”) and our mobile app (the "App") (collectively, “Properties”). This Privacy Policy (“Policy”) describes how Common Application collects and uses the personal information you provide through our Properties. It also describes the choices available to you regarding our use of personal information about you and how you can access and update this information.

Please note that Common Application is a not-for-profit organization based in the USA. Any personal information you provide or we collect is transmitted to, and stored in, the USA, and will also be shared with our member Colleges and Universities, at your direction, including in countries where laws may be less protective of personal information about you than in your home country.

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2. This policy will let you know about:
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  • Changes to this Policy 
  • Data Rights and Control 
  • What personal information does Common Application collect from or about you?
    • Website Visitors 
    • Applicants 
    • Parents/Guardians of Applicants 
    • College/University Administrators 
    • School Officials 
    • Recommenders 
  • Processing of data obtained via cookies and other tracking technologies
  • How does Common Application use personal information? 
  • How does Common Application share personal information?
  • What are your choices regarding collection, use, and distribution of information? 
  • What is Common Application's policy on retention and allowing you to access, update, correct, or delete personal information about you?
  • Participation in Partner Programs 
  • What kind of security precautions are in place? 
  • Your European Economic Area, United Kingdom, and Swiss Privacy Rights
  • Social Media Widgets and Integrated Services 
  • Additional information and how you can contact us regarding this Policy 
  • Emails that you send us 

Please read carefully this Policy before providing us with any information. This Policy only addresses Common Application's privacy practices concerning information collected from our Properties. This Policy also does not cover the privacy or information practices of those web sites that may be linked to or referenced by the Properties or the information practices of Colleges and Universities.

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3. Changes to this Policy
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Changes to this Policy will be posted on this page. We reserve the right to modify this Policy at any time, so please review it periodically to learn of updates.

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4. Data Rights and Control
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Users (defined below) retain ownership of and an interest in all data (including Personal Information) provided to the Properties. However, Common Application has the right to use all data provided to the Properties (including Personal Information) in accordance with its Terms of Use and this Privacy Policy. Once a user decides to share Personal Information with a member College or University through the Properties, the member controls that Personal Information and can use it in accordance with its own privacy policy and applicable laws.

Who Provides or Accesses Data? Rights Associated with Data Data Control
Web site Visitors, Applicants, Parents/Guardians of Applicants, School Officials, Recommenders (“Users”) Users retain all right title and interest in and to Personal Information entered into the Properties. Common Application provides the ability to Users to restrict the use of Personal Information by contacting Common Application at privacy@commonapp.org.
Common Application User grants to Common Application a license to process Personal Information entered into the Properties on behalf of its member institutions and for Common Application’s own purposes as described in this Policy. Common Application may use Personal Information processed through the Properties for any purpose described in our Terms of Use or this Policy.
Member College or University (through College/University Administrators)

Members gain a limited interest in a User’s Personal Information when that User becomes a prospective student by adding the member to “my school list.”

When a User submits an application to a member, Common Application shares that User’s Personal Information with that member. Common Application also continues to retain its rights in that User’s Personal Information as described above.

Members control the use of User Personal Information shared with the member through the Properties.
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5. What personal information does Common Application collect from or about you?
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Summary: 

Common Application collects various information from applicants, parents/guardians, recommenders, educational institutions, and member Colleges or Universities. This information is collected when you register for Common Application; complete an online form, including any application forms; provide a recommendation; and interact with us for other purposes. Common Application also collects technical information about your visit when you access our Properties. 

Common Application collects personal information from various types of individuals. The following summarizes the personal information we collect from the different audiences for our services. 

Who We Collect the Information From What Common Application Collects Common Application’s Relationship to the Information
Website Visitors When you access our Properties, we may gather information such as device operating system version, device type and system response times (mobile device), Internet Protocol (IP) addresses, browser type, Internet Service Provider (ISP), referring/exit pages, date/time stamp, and/or clickstream data. See the “Processing of data obtained via cookies and other tracking technologies” section for information we automatically gather when you access our Properties. Common Application uses this information for its own purposes as described in this Policy.
Applicants

If you are a student applicant, certain personal information is collected from you when you fill out your "profile" as part of the registration and application process, an online User Registration form, the Common Application and any application supplements, and/or other applicant forms. This information includes your name, home and mailing address, email address, telephone number, citizenship, date and place of birth, payment information, and Social Security number. Common Application also collects the username and password you create during registration.

We may also collect personal information about you from recommenders and educational institutions you have attended, including information about your academic achievements and performance, recommendations and impressions of you, and any other information these parties choose to provide us in connection with your application(s).

Common Application processes this information for and on behalf of its member Colleges and Universities.
Parents/Guardians of Applicants If you are a parent or legal guardian of an applicant, we may collect personal information about you from the applicant, including your name, relationship with the applicant, address, telephone numbers, and/or email address. Common Application processes this information for and on behalf of its member Colleges and Universities.
College/University Administrators If you are an administrator at one of our member Colleges or Universities who uses the Common Application to receive student admission application data, we collect your name and email address to permit you to retrieve data of student applicants who have applied to your college or university using the Common Application. The personal information of the administrator is also shared with certain third party vendors to enable member administrators to gain access to a student applicant's payment status information. Common Application processes this information for and on behalf of its member Colleges and Universities.
School Officials If you are an official or employee at an educational institution, when you register an account with our Properties, we collect information about you and your position at your school, including your name, your position and/or title, school code information, and your contact information including email address, phone number(s), and mailing address(es) and zip code. Common Application processes this information for and on behalf of its member Colleges and Universities, and also uses this information for its own purposes as described in this Policy, including to promote our services to these officials.
Recommenders If you wish to submit recommendations for or on behalf of an applicant’s applications to one or more member Colleges or Universities, you must register an account with our Properties and provide information about yourself, including information about you and your position and relationship with the applicant, including your name, your position and/or title, any school code information, and your contact information including email address, phone numbers, and mailing address(es) and zip code. Common Application processes this information for and on behalf of its member Colleges and Universities, and also uses this information for its own purposes as described in this Policy, including to promote our services to these officials.
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6. Processing of data obtained via cookies and other tracking technologies.
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Summary: 

Common Application uses cookies and similar technologies to automatically gather certain technical information, such as your browser type, IP address, and operating system. This information may be linked to other information Common Application collects about you for the purposes of providing the services you request and to safeguard our systems and your information. 

Common Application and its partners use cookies or similar technologies to analyze trends, administer the web site, analyze users’ movements around the Properties, and to gather demographic information about our user base as a whole. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our Properties. As is true of most web sites and apps, we gather certain information automatically and store it in log files. 

Information collected automatically may include Internet Protocol (IP) addresses, browser type, Internet Service Provider (ISP), referring/exit pages, device type and system response times, operating system, date/time stamp, and/or clickstream data. We link this automatically collected data to other information we collect about you. We do this to: 

  • Confirm that our Properties work properly on your device so we can provide you with services you request. 
  • Promote our legitimate interests in safeguarding and ensuring the smooth operation of our IT systems, including our Properties, and to help safeguard personal information about you. 

We may work with third parties that collect data about your use of the Properties and other sites or apps over time for non-advertising purposes. Common Application uses Google Analytics and other third-party services to improve the performance of the Properties. For more information about how Google Analytics collects and uses data when you use our Properties, visit www.google.com/policies/privacy/partners/, and to opt out of Google Analytics, visit tools.google.com/dlpage/gaoptout/.

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7. How does Common Application use personal information?
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Summary: 

Common Application uses the information it collects about applicants for various purposes, including to process your application to member Colleges and Universities; to allow Colleges and Universities you apply to for admission to communicate with you; and for research and statistical uses. 

General. Common Application uses personal information for any lawful purposes, including without limitation the following: 

  • As necessary to provide, administer, and improve our Properties and services;
  • As necessary to respond to inquiries;
  • To provide you with information relating to your use of the Properties and our services;
  • To create anonymous, aggregated data for research purposes; 
  • To communicate with you to further our legitimate interests in promoting our services; 
  • To monitor compliance with applicable legal obligations, terms, agreements, and policies; 
  • To comply with the law, maintain the security of our Properties and services, and to protect our rights and the rights of third parties; and/or 
  • With your consent or as otherwise disclosed at the time information is collected.

Applicants. We may use the information we collect from applicants for any lawful purposes, including in the following ways: 

  • To process your application(s) to our member Colleges and Universities that require the information to assess your suitability for admission, communicate with you about your application, and meet institutional reporting requirements and obligations to safeguard students. If you do not provide the information our members require, we will be unable to process your application.
  • To allow you to pay fees required for your application to our member Colleges or Universities, by linking you to the Higher One web site which collects your payment related information. 
  • To validate the mailing address that you provide to further our legitimate interests in obtaining accurate information and preventing misuse of the Common Application and our Properties. 
  • To allow our members to meet their institutional reporting requirements regarding certain protected characteristics including gender, race, ethnicity, sexual orientation. 

Parents and Legal Guardians. To allow us to communicate with parents or legal guardians for minors so we and our member Colleges and Universities can get evidence of parent or guardian permission for the relevant applicant to provide us with their personal information.

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8. How does Common Application share personal information?
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Summary: 

Common Application may disclose information as permitted in this Policy, for its commercial purposes or otherwise with your consent or as notified at the time of collection. Common Application shares applicant information with certain third parties, including service providers used for web services and payment processing. Common Application also shares information with certain third parties for their direct marketing purposes. 

General.

  • Common Application functions as a conduit of information between the student applicant and/or their parent(s) or legal guardian(s) and recommenders, the applicant’s secondary school(s), the various member Colleges and Universities selected by the applicant, and any Partner Programs selected by the applicant. 
  • We share personal information about you with third parties in the ways that are described in this Policy. 
  • We share personal information with service providers that we, or our member Colleges and Universities, have engaged to provide services to us or to them. 
  • We may disclose personal information in connection with a change in structure, such as if Common Application is involved in a merger, acquisition, or sale of all or substantially all of its assets or experiences a bankruptcy event.
  • Common Application shares information with third parties such as partner programs and member Colleges and Universities for their own direct marketing purposes. 
  • Common Application also shares information when we believe that disclosure is necessary to protect our rights, the rights of our members, for detection or prevention of fraud or misuse associated with the Properties, and/or to comply with law or legal obligation (including to meet national security or law enforcement requirements).

We also share personal information about you with your consent or as otherwise disclosed at the time of data collection or sharing. 

Applicants. Common Application shares personal information about applicants with member Colleges and/or Universities to allow them to assess applicants’ suitability for admission, communicate with applicants, and meet institutional reporting requirements. Note that even if an applicant never submits an application through the Common Application, the Colleges and/or Universities in which the applicant has indicated interest will still have access to the applicant’s personal information as part of the applicant’s pre-application data prior to the application being submitted. Such Colleges and/or Universities may use this information, for example, to contact applicants even prior to the time an application is submitted to provide information about their institutions and admission processes and deadlines. See "What are the applicant’s choices regarding collection, use and distribution of personal information, including your rights to ‘opt-in’ or ‘opt-out’," to find out more about how this works, and what information is shared and how you can limit such sharing. 

We also share applicant names, phone numbers, and home addresses with Experian QAS, one of our service providers, to confirm the accuracy of the mailing address that you entered and to enhance the anonymized, aggregated data that we and our partners are developing. Experian QAS does not store this personal information.

Applicant payment card information is shared with a payment card processor in order to make payment of admission application fees to the selected Colleges and/or Universities. 

We may also share personal information about you with other third party organizations allowing us and/or them to generate aggregate data which we and/or the third party may publish, 

combine, or enhance with other aggregate data obtained from other sources, and/or share or distribute the aggregate data.

We may provide personal information about you to Partner Programs (all located in the USA), but only when you request that we do so. Find out more about our Partner Programs in the “Participation in Partner Programs” section of this Policy. 

Subject to any rights afforded by law, Common Application also reserves the right to disclose information collected from an applicant, when we have reason to believe that accessing and/or disclosing this information or taking such action is necessary to prevent, identify, contact or bring legal action against someone who may be violating any of our on-line user agreements or policies or who may be causing injury to or interference with (either intentionally or unintentionally) Common Application rights or property, other Common Application users, members or schools, or to help protect anyone else that could be harmed by such activities.

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9. What are your choices regarding collection, use, and distribution of information?
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Summary: 

Common Application offers registrants a choice mechanism through which registrants can indicate whether they would like to receive communications from Common Application and member Colleges and Universities. Common Application also offers its App users the ability to provide choice regarding push notifications. 

Applicants and Parents/Guardians. You will not be able to utilize our services unless you complete an on-line User Registration form. When you first register with Common Application, you are given the option to choose to receive communications from member Colleges and Universities and have certain personal information released to our member Colleges and Universities on your "My Colleges List" prior to submission of your application to that selected member College or University. 

Should you "opt in," you can later change your mind and "opt out" for any member College or University by using the "Unsubscribe" link located at the bottom of the email you receive from that member College or University. Alternatively, you may "opt out" for all member Colleges and Universities by changing the setting located on your "Account Maintenance" page. You can access the “Account Maintenance” page by clicking on the Settings icon in the upper right hand corner of your application after logging in. 

Should you choose to "opt in," a limited amount of the personal information that you provided us will be released to your designated member Colleges and Universities prior to submission of your application to those selected members. The personal information shared will include your name, permanent home address, ethnicity, sex, citizenship, date of birth, phone number(s), email address, and Social Security number. In addition, your "opting-in" will allow member Colleges and Universities to use your information to contact you at any time and/or to text you at your cell phone number. 

Should you choose to "opt out," a more limited amount of personal information about you is released to your selected member Colleges and Universities to allow such Colleges and Universities to track the demographics of their prospective applicant pool as well as the ability to respond to inquiries from applicants who have indicated an interest in their institution. The personal information shared will include your name, city, state, zip code, country, sex, citizenship, and date of birth. 

Once registered, while you are free not to provide any personal information requested on the Common Application form, any application supplement or other applicant form, to do so may cause the member College and/or University that you select to reject the application, supplement or other applicant form as incomplete. This may delay the application admission process or result in a rejection of the submission regardless of payment. Users should communicate with their designated College and/or University directly if any admission application is delayed or rejected or otherwise results in an outcome that does not satisfy the applicant's expectations. The Common Application is not involved in and cannot be held responsible for any admission outcome of any specific applicant. 

When you register with Common Application, you are also required to express your communications preferences to receive communications from Common Application. These communications may include emails, phone or text messages or physical mailings to your address. These communications may go beyond the technical support of application submission to include information on financial aid, tips, and broader topics that Common Application feels would benefit you. If you later decide that you would like to “opt out,” please contact the applicant Solutions Center with your request, using the “Instructions & Help” link from your applicant account, or by clicking on the gear icon from your applicant account and changing your communication preference. If you “opt out,” we may still contact you with messages regarding your account with us, including registration and submission confirmation texts, physical mail, and/or emails, to contact you to help answer a technical support question that you may have posed to us regarding your use of the Properties.

Through our App, we send you push notifications from time-to-time in order to update you about the admission application process. If you no longer wish to receive these types of communications, you may turn them off at the device level. To send these notifications, we collect certain information about your device such as operating system and user identification information. 

School Officials and Recommenders. If you “opt out” of the online recommendation system via the email invitation initiated by the applicant, you will not receive any College/University specific information concerning the applicant’s admissions process; however, we may use your email address, cell phone number, and/or mailing address to send you registration and submission confirmation communications, text messages or emails, or we may need to contact the user/recommender to help answer a technical support question that you may have posed to us regarding your use of the Properties and to provide you with other information relevant to the student’s admission application process. Additionally, any member colleges may communicate with you regarding the applicant, using the information you or the applicant provide. 

College/ University Administrators. Common App Member Colleges and Universities may register administrators via the Common App Member Portal. Those registered administrators will be able to access all member information in the member portal including, the membership Agreement, and applicable membership information. Member Colleges and Universities may change or remove any administrator at any time via the Member Portal.

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10. What is Common Application's policy on retention and allowing you to access, update, correct, or delete your personal information?
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Summary: 

Common Application offers you the ability to access, update, correct, and delete or ask us to no longer use the information Common Application holds about you. 

Common Application keeps personal information about you for as long as it is necessary to provide you with the Common Application service or we have another legitimate reason to retain it, including for longitudinal studies using aggregate data. When determining how long to retain your personal information, our considerations include our legal obligations and other mandatory record keeping requirements and the likelihood of you needing access to the personal information we hold for purposes related to your previous use of the Common Application or App. 

Upon request, we will provide you with information about whether we hold any of your personal information.

If you wish for us to delete or no longer use any of your personal information that you submitted to us, you may email us with such a request at privacy@commonapp.org and, where and to the extent required by law and subject to our legal obligations and other mandatory record keeping requirements, your personal information will be deleted or no longer used within thirty (30) business days after receiving your request. 

You may access, edit, and update your registration and contact information by using your User Name (your email address) and password to sign into your account. To edit or update any information that was erroneously provided by the applicant but was already submitted and can no longer be changed or re-submitted through our Properties, you must contact the College/University or payment card processor directly to alert them to the erroneous information.

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11. Participation in Partner Programs
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Summary: 

Common Application offers certain partner programs with which we may share applicant personal information. 

Applicants are also given the opportunity to choose whether they want us to share personal information for the purpose of participating in certain partner programs. The Common Application has relationships with the following partner programs:

  • The College Board Scholarship Search (“Scholarship Search”), formerly known as the Michael and Susan Dell Foundation Scholar Snapp program, https://signup.collegeboard.org/scholarship-search/.
  • Strive for College, https://striveforcollege.org/
  • If an applicant is utilizing our service through any of our partners (Naviance (add link), Maia Learning (add link), etc.), any personal information that we received about you from these partners will be deleted upon the request of the applicant’s high school or school district to which the applicant is attending, to the extent the school or school district has control over that information. 
  • With respect to our partnership with Liaison (aka “SlideRoom” or the “SlideRoom Service”), we may share with Liaison certain personal information of an applicant or employee of a member College or University if that applicant seeks to use the SlideRoom Service to submit as part of their admission application various content, works, or materials for eventual submission to a member College or University. Note that any personal information that we share with Liaison will be governed by the terms of the SlideRoom privacy policy displayed on their web site at www.slideroom.com so please be sure to read and understand that policy in order to determine how personal information is being used by Liaison in connection with the services that they provide
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12. What kind of security precautions are in place?
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Summary: 

Common Application employs safeguards designed to protect personal information and offers suggestions through which users of its Properties may secure their information. 

We employ physical, administrative, and technical safeguards designed to promote the security of our systems and protect the confidentiality, integrity, availability, and resilience of personal information. Those safeguards include: the pseudonymization and encryption of personal information where we deem appropriate; taking steps to back up personal information; and periodic testing, assessment, and evaluation of the effectiveness of our safeguards. 

However, no method of safeguarding information is completely secure. While we use measures designed to protect personal information, we cannot guarantee that our safeguards will be effective or sufficient. In addition, you should be aware that data transmission via the Internet is not always secure, and we cannot warrant that the information you transmit utilizing the Properties is or will be secure. 

For example, we encrypt data transmission when you submit the Common Application and/or any supplements or other applicant forms to designated member Colleges or Universities, when you access your user registered account information from our Properties, and when we share certain of your personal information with our third-party partners for the purpose of participating in applicable programs with your permission. 

Your User Registration information is password-protected. We recommend that you do not divulge your password to anyone, that you sign out of your Common Application registration account and close your browser window when you have finished your work, and that you do not copy and paste links from within the online application into an email or share with others on a public forum.

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13. Your California Privacy Rights
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Summary: 

Common Application offers California residents the right to request certain information under California law about the sharing of their personal information with third parties. 

California Civil Code section 1798.83 entitles residents of California to request information about the third parties with whom Common Application has shared personal information in the immediately preceding calendar year and if those third parties ever used such information for direct marketing purposes. California residents may submit one request per calendar year. Common Application will provide a response in the form of a report that details: (a) of the categories of information Common Application shared, and (b) the name and address of the third parties with whom Common Application shared such information. 

California residents may submit their request by scrolling to the Section entitled "Additional information and how you can contact us regarding this Policy" and following directions for accessing the Help Center.

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14. Your European Economic Area, United Kingdom, and Swiss Privacy Rights
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Summary: 

Common Application offers users from a European Union country, Iceland, Liechtenstein, Norway, the United Kingdom, or Switzerland certain rights afforded to them under the General Data Protection Regulation and similar laws. 

If you are based in a European Union country, Iceland, Liechtenstein, Norway, the United Kingdom, or Switzerland (collectively, the “EU”), you may have rights over your personal information we handle about you, including but not necessarily limited to: 

  • The right to access, receive, or correct personal information about you 
  • The right to have personal information about you erased (where there is no longer legal or necessary grounds to process or store such personal information) 
  • The right to have personal information about you transferred to another party 
  • The right to restrict, or otherwise object to, the processing of personal information about you at any time where such personal information is not accurate, where the processing is unlawful, where such personal information is no longer needed, or where there are no longer legitimate grounds to process the personal information 
  • The right to object to processing of personal information about you if the lawful basis for processing is based on our or a third party’s legitimate interests or a reason of public interest or we use the personal information for direct marketing 
  • The right to withdraw your consent to the collection, handling, storage, and/or processing of personal information about you at any time 
  • The right to complain to us and/or the appropriate EU supervisory authorities if you believe any of your rights are being violated

The right to know if you are being “profiled” or “monitored” or if certain decisions are being made automatically based on personal information about you 

The lawful collection and processing of personal information about you is necessary for us to provide you with use of the Common Application Properties and we seek to provide you with affirmative options where practicable so that you may decide if you want us to process some or all of your data for a particular purpose. We strive to make certain that all of the data that we request is necessary in order to provide you with our service or to otherwise accomplish the stated purpose. Further, all of the opt-in consents that are presented to you are intended to fully inform you whether you want us to process your data, the purpose behind processing your data and who, if anyone, we will be sharing your data with in order to accomplish that purpose. 

Please note that if you are an individual who is based in the EU and between the ages of 13 to 16, we will not process any of the personal information that you may have submitted to us until we have promptly received the express consent from your parent or legal guardian. If this consent is not promptly provided to us, data that you may have submitted during the account creation process will be periodically purged from our system in order to make certain that we are not retaining any of your data. 

Should you decide to exercise a right under this section regarding data that you submitted to us or if you wish to withdraw any one or all of your consents for processing, please send your instruction to privacy@commonapp.org

If you have any questions or concerns about your rights under the GDPR or the steps that we have taken to comply with the GDPR, please contact us at privacy@commonapp.org.

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15. Social Media Widgets and Integrated Services
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The Properties include social media features ("Features") such as the Facebook Like button and widgets or interactive mini-programs that run on the Properties. These Features may collect your IP address, which page you are visiting on the Properties, and may set a cookie to enable the Features to function properly. The Features and widgets are either hosted by a third party or hosted directly on the Properties. Your interactions with, and the data collected by, each Feature are governed by the privacy policy of the company providing it. 

The Google API Service is used to provide a student access to their Google Drive files, if they choose to use the integrated service. No data about the user’s Google account is stored or shared by the Common Application.

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16. Additional information and how you can contact us regarding this Policy
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We encourage you to review the Frequently Asked Questions for additional information and instructions about any questions that you may have regarding this Policy. 

If you have questions or concerns regarding this Policy, you should first contact the following Common Application representative by email, phone, or mail at the address below: 

Privacy Compliance 
The Common Application, Inc.
3003 Washington Blvd., Ste. 1000 
Arlington, VA 22201 
privacy@commonapp.org 
(703) 378-9788 

You may also click “Help Center” at www.commonapp.org to communicate any questions, comments, feedback, or complaints regarding this Policy or the use of personal information by the Common Application.

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17. Emails That You Send Us
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Please note that any emails, text messages, or other communications that you send us or to which we have been given legal access may be copied, forwarded, or distributed to our personnel and members within our sole discretion and/or as otherwise permitted by law and this Policy.

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Description
This Privacy Policy describes how Common Application collects and uses the personal information you provide through our Properties. It also describes the choices available to you regarding our use of your personal information and how you can access and update this information.