Privacy Policy

Introduction

We are a social network and online platform for students. People use our services to discover where to continue their education after high school and to connect with others. Our Privacy Policy applies to any Member or Visitor to the covered Services.

Our registered users (“Members”) share their academic profiles and identities, engage with their network, exchange knowledge and insights, post and view relevant content, learn and find academic and career opportunities. Content on some of our services is available to non-members (“Visitors”).

Data Controllers
You are entering into the User Agreement with fosterway, Inc, who will be controller of your personal data provided to, or collected by or for, our Services.

Services
This Privacy Policy applies to fosterway, Inc and other fosterway-related sites, apps, communications and services (“Services”), including off-site Services.

If you use our Services, you consent to this Privacy Policy, including our Cookies Policy.

Consent
If you use our Services, you consent to the collection, use and sharing of your personal data under this Privacy Policy (which includes other documents referenced in this Privacy Policy) and agree to the User Agreement.

If you use our Services after an update to this Privacy Policy, you consent to the changed policy.

Change
We may modify this Privacy Policy. If you object to any changes, you may close your account. Your continued use of our Services after we publish or send a notice about our changes to this Privacy Policy means that you are consenting to the updated Privacy Policy.

1. Information We Collect

1.1 Information You Provide To Us

You provide data to create an account with us.

Registration
To create an account you provide data including your name, email address and/or mobile number, and a password. If you register for a premium Service, we may ask you for payment (e.g., credit card) and billing information.

You create your fosterway profile (a complete profile helps you get the most from our Services).

Profile
You have choices about the information on your profile, such as your high school, education, work experience, skills, photo, city or area and endorsements. Profile information helps you to get more from our Services, including helping recruiters and academic opportunities find you. It’s your choice whether to include sensitive information on your profile. Please do not post or add personal data to your profile that you would not want to be publicly available.

You give other data to us, such as by syncing your address book or calendar.

Posting and Uploading
We collect personal data from you when you provide, post or upload it to our Services, such as when you fill out a form, respond to a survey (e.g., Members’ grades), apply for or save a school, program, sport or send invitations. If you opt to import your address book, we receive your contacts (including contact information your service provider(s) or app automatically added to your address book when you communicated with addresses or numbers not already in your list). If you sync your email or calendars with our Services, we will collect your “email header” and calendar meeting information (e.g. times, places, attendees and contacts).

1.2 Information From Others

Others may post or write about you.

Content and News
You and others may post content that includes information about you on our Services (as part of blog posts, feed updates and comments, videos). We collect public information about you, such as academic, athletic, or professional-related news and accomplishments (e.g., patents granted, awards, athletic performance, academic recognition, conference speakers, projects, etc.) and make it available as part of our Services (e.g. suggestions for your profile, or notifications of mentions in the news).

Others may sync their contacts or calendar with our Services.

Contact and Calendar Information
We receive personal data about you when others import or sync their address book or calendar with our Services, or send messages using our Services (including invites or connection requests).

Customers and partners may provide data to us.

Partners
We receive personal data about you when you use the services of our customers and partners, such as prospective post-secondary schools, employers and applicant tracking systems providing us school or job application data.

1.3 Service Use

We log your visits and use of our Services, including mobile apps.

We log usage data when you visit or otherwise use our Services, including our sites, app and platform technology (e.g., our off-site plugins), such as when you view or click on content (e.g., learning video) or ads (on or off our sites and apps), perform a search, install one of our mobile apps, share articles or apply for schools or programs. We use log-ins, cookies, device information and internet protocol (“IP”) addresses to identify you and log your use.

1.4 Cookies, Web Beacons and Other Similar Technologies

We collect data through cookies and similar technologies.

We use cookies and similar technologies (e.g., web beacons, pixels, ad tags and device identifiers) to recognize you and/or your device(s) on, off and across different Services and devices. You can control cookies through your browser settings and other tools.

1.5 Your Device and Location

We receive data from your devices and networks, including location data.

When you visit or leave our Services (including our plugins or cookies or similar technology on the sites of others), we receive the URL of both the site you came from and the one you go to next. We also get information about your IP address, proxy server, operating system, web browser and add-ons, device identifier and features, and/or ISP or your mobile carrier. If you use our Services from a mobile device, that device will send us data about your location. Most devices allow you to prevent location data from being sent to us and we honor your settings.

1.6 Messages

If you communicate through our Services, we learn about that.

We collect information about you when you send, receive, or engage with messages in connection with our Services. For example, if you get a fosterway follow request, we track whether you have acted on it and will send you reminders. We also use automatic scanning technology on messages.

1.7 Workplace and School Provided Information

When your school, association or employer buys a premium Service for you to use at school or work, they may give us data about you.

A school or an employer (or other person or entity procuring our Services for your use) may provide us information about their students, employees or contractors who make use of these Services.

1.8 Sites and Services of Others

We get data when you visit sites that include our plugins, ads or cookies or log-in to others’ services with your fosterway account.

We receive information about your visits and interaction with services provided by others when you log-in with fosterway or visit others’ services that include our plugins, ads, cookies or similar technologies.

1.9 Other

We are improving our Services, which means we get new data and create new ways to use data.

Our Services are dynamic and we often introduce new features, which may require the collection of new information. If we collect materially different personal data or materially change how we use your data, we may modify this Privacy Policy.

2. How We Use Your Data

We use your data to provide, support, personalize and develop our Services.

How we use your personal data will depend on which Services you use, how you use those Services and the choices you make in your profile settings. We use the data that we have about you to provide, support, personalize and make our Services (including ads) more relevant and useful to you and others.

2.1 Services

Our Services help you connect with others, find and be found for academic, athletic, work and business opportunities, stay informed, get training and be more productive.

We use your data to authenticate you and authorize access to our Services.

Stay Connected
Our Services allow you to stay in touch, in communication and up to date with colleagues, partners, clients, and other professional contacts. To do so, you will “follow” other users or professionals who you choose, and who also wish to “follow” you.

We will use data about you (such as profiles you have viewed or data provided through address book uploads or partner integrations) to suggest connections for you and others (e.g. Members who share your contacts) and enable you to invite others to become a Member and connect with you. You can also opt to allow us to use your precise location or proximity to others to suggest other nearby Members for you to follow. It is your choice whether to invite someone to our Services or send a follow request. When you invite someone to follow you, your invitation may include your name, photo and contact information. We may send invitation reminders to the person you invited.  Others will be able to view the users you follow and the users who follow you.

Stay Informed
Our Services allow you to stay informed about news, events and ideas regarding academic and other topics you care about, and from other users you respect. We use the information about you to recommend relevant content across our Services, suggest skills you may have to add to your profile and skills that you might need to pursue a school, program or job. We use your content, activity and other data, including your name and picture, to provide notices to our network and others. For example, we may notify others that you have updated your profile, posted a news item, took a social action, followed new users or were mentioned in a news post.

Career
Our Services allow you to explore academic institutions, programs, careers, evaluate educational opportunities, and seek out, and be found for, career opportunities. Your profile can be found by those looking to recruit, admit, hire (for a job or a specific task) or be hired by you. We will use your data to recommend schools, programs, or jobs, show you and others who attend a school, are enrolled in a program, work at a company, in an industry, function or location or have certain skills, interests, credentials or connections. You can signal that you are interested in changing schools, programs, jobs and share information with guidance counselors or admissions professionals or job recruiters. We may use your profile and activity to recommend schools, programs or jobs to you and you to recruiters, schools or employers.

Productivity
Our Services allow you to collaborate with friends and colleagues, search for potential clients, customers, partners and others to do business with. Our Services allow you to communicate with other students and professionals and schedule and prepare meetings with them. Subject to your settings, we may scan messages to provide “bots” or similar tools that facilitate tasks such as scheduling meetings, draft responses, summarize messages or recommend next steps.

2.2 Communications

We may contact you through email, notices posted on our websites or apps, messages to your fosterway inbox, and other ways through our Services, including text messages and push notifications. We may send you messages about the availability of our Services, security, or other service-related issues. We also may send messages about how to use the Services, network updates, reminders, school, program or job suggestions or promotional messages from us and our partners.

We also enable communications between you and others through our Services, including for example invitations and messages between users.

2.3 Advertising

We may serve you tailored ads both on and off of our Services. You cannot opt out of seeing ads.

We target (and measure the performance of) ads to Members, Visitors and others both on and off of our Services through a variety of ad networks and exchanges, using the following data, whether separately or combined:

Data from advertising technologies on and off of our Services, like web beacons, pixels, ad tags, cookies, and device identifiers;
Member-provided information (e.g., contact information, school, title and industry);
Data from your use of our Services (e.g., search history, feed, content you read, who you follow or is following you, connections, groups participation, page visits, videos you watch, clicking on an ad, etc.), including as described in Section 1.3;
Information from others (e.g. advertising partners, publishers and data aggregators);
Information inferred from data described above (e.g., using graduation year to infer age or names to infer gender).

We may show you ads called sponsored content which look like similar non-sponsored content. If you take an action (such as like, comment or share) on these ads, your action is associated with your name and viewable by others, including the ad provider.

Info to Advertisers
We do not share your personal data with any third-party advertisers or (other than hashed or device identifiers, to the extent they are personal data in some countries) ad networks for their advertising without your separate permission. However, if you click on an ad, the ad poster will know you visited the page that you clicked on. Also, advertising partners can associate personal data collected by the advertiser directly from you with our cookies and similar technologies. In such instances, we seek to contractually require such advertisers to obtain your explicit, opt-in consent before doing so.

2.4 Marketing

We promote our Services to you and others.

We use data and content about Members for invitations and communications promoting membership and network growth, engagement and our Services.

2.5 Developing Services and Research

We develop our Services and conduct research.

Service Development
We use data, including public feedback, to conduct research and development for the further development of our Services in order to provide you and others with a better, more intuitive and personalized experience, drive membership growth and engagement on our Services, and help connect students and schools to each other and to foster academic, professional, and economic opportunity.

Other Research
We seek to create economic opportunity for members of the global student population and workforce and to help them be more productive and successful. We use the data available to us to research social, economic, academic and workplace trends such as school enrolment, admissions standards and competition, jobs availability and skills needed for these schools, programs, jobs and policies that help bridge the gap in various industries and geographic areas. In some cases, we may work with trusted third parties to perform this research, under controls that are designed to protect your privacy. We publish or allow others to publish economic insights, presented as aggregated data rather than personal data.

Surveys
Polls and surveys may be conducted by us and others through our Services. You are not obligated to respond to polls or surveys and you have choices about the information you provide.

2.6 Customer Support

We use data to help you and fix problems.

We use the data (which can include your communications) needed to investigate, respond to and resolve complaints and Service issues (e.g., bugs).

2.7 Aggregate Insights

We use data to generate aggregate insights.

We use your information to produce aggregate insights that do not identify you. For example, we may use your data to generate statistics about our users, their profession or industry, the number of ad impressions served or clicked on, or the demographic distribution of visitors to a site.

2.8 Security and Investigations

We use data for security, fraud prevention and investigations.

We use your data (including your communications) if we think it’s necessary for security purposes or to investigate possible fraud or other violations of our User Agreement or this Privacy Policy and/or attempts to harm our Members or Visitors.

3. How We Share Information

3.1 Our Services

Any information you include on your profile and any content you post or social action (e.g. likes, follows, comments, shares) you take on our Services will be seen by others.

Profile
Your profile is fully visible to all Members and customers of our Services. Your settings, degree of connection with the viewing Member, the subscriptions they may have, their usage of our Services, access channels and search types (e.g., by name or by keyword) impact the availability of your profile and certain fields.

Posts, Favourites, Follows, Comments, Messages
Our Services allow viewing and sharing information including through posts, follows, favourites and comments.

When you share a post (e.g., an update, video or blog), the default (which you can change) is to share it publicly. Others who are not your followers will be able to find (including through search engines) and see your post.

When you like, comment on or share another’s post, others will see it, including the person who initiated the post.
Any information you share through schools’, companies’ or other organizations’ pages on our Services will be viewable by it and others who visit those pages.
When you follow a person or organization, you may be visible to others and that “page owner” as a follower. We provide aggregate insights about the followers and viewers to the respective page owners.
We may let senders know when you act on their message, subject to your settings where applicable.

Academic Accounts
Your school may offer you access to our academic Services. They can also buy access for you to our online learning products. Your school can review and manage your use of such academic Services.

3.2 Others’ Services

Excerpts from your profile may appear on the services of others (e.g., search engine results, mail and calendar applications, social media aggregators, talent and lead managers). “Old” profile information may remain on these services until they update their data cache with changes you made to your profile.

3.3 Related Services

We share your data across our different Services and fosterway-affiliated entities.

We will share your personal data with our affiliates to provide and develop our Services. We combine information internally across the different Services covered by this Privacy Policy.

3.4 Service Providers

We may use others to help us with our Services.

We use others to help us provide our Services (e.g., maintenance, analysis, audit, payments, fraud detection, marketing and development). They will have access to your information as reasonably necessary to perform these tasks on our behalf and are obligated to not to disclose or use it for other purposes.

3.5 Legal Disclosures

We may need to share your data when we believe it’s required by law or to protect your and our rights and security.

It is possible that we will need to disclose information about you when required by law, subpoena, or other legal process or if we have a good faith belief that disclosure is reasonably necessary to (1) investigate, prevent, or take action regarding suspected or actual illegal activities or to assist government enforcement agencies; (2) enforce our agreements with you, (3) investigate and defend ourselves against any third-party claims or allegations, (4) protect the security or integrity of our Service (such as by sharing with companies facing similar threats); or (5) exercise or protect the rights and safety of fosterway, our Members, personnel, or others. We attempt to notify Members about legal demands for their personal data when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand.

3.6 Change in Control or Sale

We may share your data when our business is sold to others.

We can also share your personal data as part of a sale, merger or change in control, or in preparation for any of these events. Any other entity which buys us or part of our business will have the right to continue to use your data.

4. Your Choices & Obligations

4.1 Data Retention

We keep most of your personal data for as long as your account is open.

We retain the personal data you provide while your account is in existence or as needed to provide you Services. Even if you only use our Services when looking for a school or program and then don’t return for a while, we will attempt to retain your information and keep your profile open until you decide to close your account. In some cases we choose to retain certain information in a depersonalized or aggregated form.

4.2 Rights to Access and Control Your Personal Data

You can access or delete your personal data. You have many choices about how your data is collected, used and shared.

We provide many choices about the collection, use and sharing of your data, from deleting or correcting data you include in your profile and controlling the visibility of your posts to communication controls

4.3 Account Closure

We keep some of your data even after you close your account.

If you choose to close your fosterway account, your personal data will generally stop being visible to others on our Services within 24 hours. We generally delete closed account information within 30 days of account closure, except as noted below.

We retain your personal data even after you have closed your account if reasonably necessary to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse, enforce our User Agreement, or fulfill your request to “unsubscribe” from further messages from us. We will retain personalized information after your account has been closed.

Information you have shared with others (e.g., through messaging, updates or posts) may remain visible after you closed your account or deleted the information from your own profile or mailbox, and we do not control data that other Members copied out of our Services. Your profile may continue to be displayed in the services of others (e.g., search engine results) until they refresh their cache.

5. Other Important Information

5.1. Security

We monitor for and try to prevent security breaches. Please use the security features available through our Services.

We implement security safeguards designed to protect your data. We regularly monitor our systems for possible vulnerabilities and attacks. However, we cannot warrant the security of any information that you send us. There is no guarantee that data may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.

5.2. Contact Information

You can contact us or use other options to resolve any complaints.

If you have questions or complaints regarding this Policy, please contact fosterway online at support@fosterway.com or through the mobile app.