- The personally identifiable information we collect from you through our Website;
- How we use the information;
- With whom we share the information and why;
- Your choices regarding deletion, collection, use, and distribution of the information;
- The security procedures in place to protect the information under our control;
- How you can correct any inaccuracies in the information.
- Compliance with the Children’s Online Privacy Protection Act of 1998
- General Provisions
- Collection of Information
- Type of Information Collected
- Use of Personal Information Collected
- Information Ownership and Use
- IP Address
- Connect 2 Business and Link 2 College
- Referrals and Special Offers
- Unauthorized Usage
- Limitations on Data Collection
- Opt-In/Opt-Out; Changing Personal Information
- Third Party Information Collection
- U.S. – EU Safe Harbor Privacy Statement
This website complies with the Children’s Online Privacy Protection Act of 1998 (“COPPA”). Accordingly, Kuder does not knowingly collect personal information directly from any child under 13 years of age, without either (1) the authorization of the child’s parent or guardian, or (2) authorization from the school where the child is enrolled as a student, wherein such authorization designates Kuder to act as an agent of the school for the collection of a child’s personal information for the use and benefit of the school, and the school has warranted to Kuder that it has obtained any consent of the child’s parent or guardian necessary to comply with COPPA. Such authorization is granted through the school’s acceptance of Kuder’s KCPS Terms and Conditions of Restricted Use License or another agreement executed by both Kuder and the particular school.
With respect to students under the age of 13, access by a third party to the data collection aspects of and the personal information collected through this Website is made available only to a student’s Authorized Educational Institution and, if applicable, any Jointly Administering Educational Institutions or Agencies (as those terms are defined below under “Use of Personal Information of Children Under 13”). Such Authorized Educational Institutions and, if applicable, Jointly Administering Educational Institutions or Agencies obtain such access only through their acceptance of Kuder’s KCPS Terms and Conditions of Restricted Use License or another agreement executed by both Kuder and the particular entity. Accordingly, each Authorized Educational Institution and, if applicable, any Jointly Administering Educational Institution or Agency utilizing the personal information collected by this Website has: (a) acknowledged that Kuder is acting as an agent of the Authorized Educational Institution in the collection of data from students under the age of 13, and (b) warranted that its use of such data will at all times comply with the Children’s Online Privacy Protection Act of 1998.
There may be instances where a child under the age of 13 desires to directly register to use this Website and a school at which the child is enrolled has not contracted with Kuder to act as an agent for the collection of personal information from the child as set forth above. IN SUCH INSTANCES, CHILDREN UNDER 13 YEARS OF AGE MAY NOT REGISTER TO USE THIS WEBSITE WITHOUT KUDER FIRST RECEIVING AUTHORIZATION FROM A PARENT OR GUARDIAN. Parents of children under the age of 13 desiring to directly register to use this Website should contact Kuder’s Webmaster regarding the procedures for providing appropriate parental consent by written communication to Kuder, Inc., Attn: David Rawson, 302 Visions Parkway, Adel, Iowa, 50003, via telephone at (800) 314-8972, or via email at email@example.com.
If Kuder receives a direct request from a child under 13 to use the Website, and Kuder has not received authorization from a parent or guardian, Kuder will utilize the child’s information solely for a one-time response to the child.
Kuder also encourages parents to counsel their children regarding providing information online and to supervise their online activities.
Kuder collects the following personal information regarding children under the age of 13: Name, address, school, age, gender, ethnicity, date of birth, e-mail addresses, and career assessment data, as well as a student’s four-year plan. The personal information collected relates to a child’s career planning preferences, interests and assessments. This personal information is collected directly from the child or the child’s parent, teacher or school administrator. Kuder also utilizes cookies on this Website to assist children, parents, teachers and school administrators in accessing and utilizing the services provided through this Website. For more detailed information regarding how cookies are used on this Website, see “Cookies” under “General Provisions” below. However, any cookies utilized by Kuder are not linked to any personal information of a child under the age of 13. Pursuant to COPPA, Kuder is prohibited from conditioning a child’s participation in an online activity on the child providing more personal information than is reasonably necessary to participate in such activity.
WITH RESPECT TO A CHILD UNDER THE AGE OF 13, KUDER COLLECTS AND PROCESSES THE CHILD’S PERSONAL INFORMATION TO PROVIDE THE PERSONAL INFORMATION TO (1) THE PARTICULAR SCHOOLS CONTRACTING FOR ITS COLLECTION AND WHICH HAVE AUTHORIZED KUDER TO ACT AS THEIR AGENT IN COLLECTING SUCH INFORMATION FOR THE USE AND BENEFIT OF THE SCHOOLS AND WHICH HAVE WARRANTED TO KUDER THAT THEY HAVE OBTAINED ALL PARENTAL CONSENTS NECESSARY TO COMPLY WITH COPPA (“AUTHORIZED EDUCATIONAL INSTITUTION”) AND (2) IF APPLICABLE, CERTAIN POST-SECONDARY EDUCATIONAL INSTITUTIONS OR SCHOOL DISTRICTS OR SYSTEMS WHICH HAVE AGREED TO JOINTLY ADMINISTER THE KCPS ALONG WITH THE AUTHORIZED EDUCATIONAL INSTITUTION FOR THE PURPOSE OF FURTHERING THE EDUCATIONAL INTERESTS OF THE APPLICABLE AUTHORIZED EDUCATIONAL INSTITUTION IN ITS STUDENTS OR FOR MAKING AVAILABLE POST-SECONDARY EDUCATIONAL OPPORTUNITIES AND RELATED INFORMATION TO THE STUDENTS BASED ON THEIR CAREER ASSESSMENT RESULTS AND INTERESTS (“JOINTLY ADMINISTERING EDUCATIONAL INSTITUTIONS OR AGENCIES”). IF APPLICABLE, STUDENTS OR PARENTS MAY REQUEST THE IDENTITY OF ANY JOINTLY ADMINISTERING EDUCATIONAL INSTUTTIONS OR AGENCIES IN THE MANNER SET FORTH IN THE KCPS TERMS AND CONDITIONS OF RESTRICTED USE LICENSE.
KUDER WILL NOT PROVIDE PERSONAL INFORMATION RELATING TO ANY CHILD UNDER THE AGE OF 13 TO ANY PARTY OTHER THAN AUTHORIZED EDUCATIONAL INSTITUTIONS OR, IF APPLICABLE, JOINTLY ADMINISTERING EDUCATIONAL INSTITUTIONS OR AGENCIES. ALL OF THE THIRD PARTY EDUCATIONAL INSTITUTIONS OR, IF APPLICABLE, JOINTLY ADMINISTERING EDUCATIONAL INSTITUTIONS OR AGENCIES, TO WHICH INFORMATION IS DISCLOSED HAVE AGREED TO MAINTAIN THE CONFIDENTIALITY, SECURITY AND INTEGRITY OF THE INFORMATION.
KUDER MAY ALSO USE SUCH PERSONAL INFORMATION RELATING TO A CHILD UNDER THE AGE OF 13 FOR KUDER’S INTERNAL VALIDATION AND NORMING PURPOSES, OR TO SEND THE CHILD NEWSLETTERS, SERVICE UPDATES OR PROMOTIONAL MATERIALS REGARDING THE WEBSITE AND KUDER’S PRODUCTS AND SERVICES.
AGGREGATE DEMOGRAPHIC INFORMATION WHICH DOES NOTCONTAIN PERSONALLY IDENTIFIABLE INFORMATION OF CHILDREN UNDER THE AGE OF 13 MAY ALSO BE PROVIDED TO SCHOOLS, GOVERNMENTAL AGENCIES OR DEPARTMENTS OR OTHER ORGANIZATIONS RELATED TO THE APPLICABLE AUTHORIZED EDUCATIONAL INSTITUTION, CERTAIN FEDERAL, STATE OR LOCAL GOVERNMENTAL AGENCIES OR DEPARTMENTS PROVIDING CAREER PLACEMENT SERVICES OR SIMILAR SERVICES, OR KUDER’S PARTNERS OR ADVERTISERS, FROM TIME TO TIME.
IF YOU ARE THE PARENT OF A CHILD UNDER THE AGE OF 13 WHO HAS PROVIDED PERSONAL INFORMATION THROUGH THIS WEBSITE AND WOULD LIKE TO PREVENT THE PERSONAL INFORMATION FROM BEING TRANSMITTED TO AUTHORIZED EDUCATIONAL INSTITUTIONS AND/OR JOINTLY ADMINISTERING EDUCATIONAL INSTITUTIONS OR AGENCIES AS SET FORTH ABOVE, PLEASE CONTACT THE KUDER WEBMASTER IF QUESTIONS ARISE (302 Visions Parkway Adel, IA 50003 800.314.8972 firstname.lastname@example.org)
THE PARENTS OF A CHILD UNDER 13 YEARS OLD CAN REVIEW AND ELECT TO HAVE DELETED THE CHILD’S PERSONAL INFORMATION, AND MAY REFUSE TO PERMIT FURTHER COLLECTION OR USE OF THE CHILD’S PERSONAL INFORMATION. FURTHER, THE PARENT MAY CHOOSE TO CONSENT TO KUDER’S INTERNAL USE OF THE PERSONAL INFORMATION AND, AT THE SAME TIME, PROHIBIT THE OPERATOR FROM DISCLOSING THE INFORMATION TO THIRD PARTIES, INCLUDING THE AUTHORIZED EDUCATIONAL INSTITUTIONS OR JOINTLY ADMINISTERING EDUCATIONAL INSTITUTIONS OR AGENCIES DESCRIBED ABOVE. THE PROCEDURE FOR REVIEWING, DELETING, REFUSING FURTHER COLLECTION OF, OR RESTRICTING CONSENT FOR THE USE OF PERSONAL INFORMATION OF A CHILD UNDER THE AGE OF 13 COLLECTED BY THIS WEBSITE IS SIMPLE AND STRAIGHTFORWARD: SIMPLY CONTACT 302 Visions Parkway Adel, IA 50003 800.314.8972 email@example.com)
KUDER HAS TAKEN SEVERAL STEPS TO INSURE THE PRIVACY, SECURITY AND INTEGRITY OF ALL PERSONAL INFORMATION COLLECTED ON THIS WEBSITE. KUDER ONLY COLLECTS PERSONAL INFORMATION FROM INDIVIDUALS UNDER THE AGE OF 13 AS DESCRIBED ABOVE UNDER “COLLECTION OF PERSONAL INFORMATION FROM CHILDREN UNDER 13.” AS REQUIRED BY LAW, KUDER COLLECTS ONLY PERSONAL INFORMATION ABOUT A STUDENT UNDER 13 YEARS OF AGE REASONABLY NECESSARY TO ALLOW THE STUDENT TO PARTICIPATE.
Kuder collects personal information from users of the Website and the KCPS on behalf of and for the use of a third party that has contracted with Kuder for the collection of such information by its acceptance of Kuder’s KCPS Terms and Conditions of Restricted Use License or execution of another agreement with Kuder, which may include, without limitation, a school at which the user is enrolled, a school district or school system in which the user is enrolled, or other educational institution, a federal, state or local agency or department, or other organization with which the user is affiliated or through which the user’s access to the Website is granted (an “Affiliated Organization”). Additionally, if applicable, Kuder may collect and process the user’s personal information to provide access to the personal information to certain entities sponsoring the Affiliated Organization’s and the user’s participation in the KCPS and which have accepted Kuder’s KCPS Terms and Conditions of Restricted Use License or executed another agreement with Kuder (a “Sponsoring Organization”). In the case where an Affiliated Organization is an Authorized Educational Institution, then the applicable Sponsoring Organization may constitute a Jointly Administering Educational Institution or Agency (as those terms are defined above under “COMPLIANCE WITH THE CHILDREN’S ONLINE PRIVACY PROTECTION ACT OF 1986 — Use of Personal Information of Children Under 13”). If applicable, users may request the identity of any Sponsoring Organizations in the manner set forth in the KCPS Terms and Conditions.
Access by a third party to the data collection aspects of and the personal information collected through this Website is made available only through a user’s applicable Affiliated Organization or, if applicable, a Jointly Administering Organization. Affiliated Organizations and, if applicable, Jointly Administering Organizations, obtain such access only through their acceptance of Kuder’s KCPS Terms and Conditions of Restricted Use License or another agreement executed by both Kuder and the particular Affiliated Organization or, if applicable, a Jointly Administering Organization. Each Affiliated Organization or, if applicable, Jointly Administering Organization, utilizing personal information collected on this Website has acknowledged that Kuder is acting as an agent of the Affiliated Organization in the collection of such information.
Kuder collects the following personal information regarding users of this Website: name, address, school or organization with which the user is affiliated, age, gender, ethnicity, date of birth, e-mail addresses, and career assessment data. Kuder may also collect information regarding a student user’s four-year plan. The personal information collected relates to a user’s career planning preferences, interests and assessments. This personal information is collected directly from the user, but may also be collected from the user’s parent, teacher, school administrator, or organizational representative, as applicable.
Kuder collects and processes a user’s collected personal information to provide the personal information to the particular Affiliated Organization contracting for its collection and which has authorized Kuder to act as its agent in collecting such information and, if applicable, any Sponsoring Organization, as specified above. Kuder will not provide personal information relating to users to any party other than the applicable Authorized Organization and, if applicable, any Sponsoring Organization. Additionally, Kuder may use a user’s personal information for Kuder’s internal validation and norming purposes or to deliver to users newsletters, service updates or other promotional materials relating to the Website or Kuder’s products and services. Furthermore, Kuder may provide aggregate demographic information which does not contain personally identifiable information relating to users to schools, governmental agencies or departments, or other organizations related to the applicable Affiliated Organization, certain federal, state or local governmental agencies or departments providing career placement services or similar services, or Kuder’s partners or advertisers, from time to time.
While Kuder does not presently utilize third party advertising companies on its Website, Kuder may provide such advertising in the future. However, Kuder will not provide any personally identifiable information to such third party advertisers relating to any user of the Website, including children under the age of 13. Any such information relating to a user of the Website will only be provided in the aggregate, without personally identifiable information, such as names, addresses, or other contact information, like telephone numbers or e-mail addresses.
In order to use this Website, a user must first complete the registration form. During registration users are required to give their name, contact information (such as address and e-mail address) as well as certain demographic information (such as gender, age, date of birth, and ethnicity). This information is used to contact you and provide you services through our Website. We encourage you to provide this information so we can provide you with a more personalized experience on our Website.
If you are directly purchasing our KCPS products and services, we may request information from you through our order and registration process in order to process your payment for the applicable products and services. At the time of purchase, you must provide contact information, like name, email address, and billing or shipping address, and financial information, like credit card number and expiration date. This information is used for billing purposes and to fill your orders. If we have trouble processing an order, this contact information is used to get in touch with you.
Kuder uses IP addresses for analyzing trends, administering the Website, tracking a user’s movement, and gathering broad demographic information for aggregate use. IP addresses are not linked to personally identifiable information.
Although we may share aggregate demographic data regarding users of the Website with our partners as discussed above, this data does not contain and is not linked to any personal information identifying any individual person.
We may use an outside credit card processing company to bill you for any products and services purchased by you. These companies do not retain, share, store or use personally identifiable information for any secondary purposes.
We may sometimes partner with another company to provide specific services. If and when you elect to sign up for these services through the Website, we will share your name, or other contact information, that is necessary for the companies to provide these services to you. These companies are not allowed to use personally identifiable information except for the purpose of providing these services.
Certain businesses and colleges may from time to time contract with Kuder for the opportunity to post information on our Website about the different careers or programs they offer.
In addition, some of these businesses and colleges have asked Kuder to send messages to users meeting certain criteria on their behalf. Kuder will send these messages to users meeting the applicable criteria but will not provide any user’s personal information to the business or college at such time.
We may use your personal information to send you our newsletter or other promotional communications relating to our products and services. If you no longer wish to receive our newsletter or promotional materials, you may opt-out of receiving these communications by contacting Kuder in the manner specified below under “Opt-In/Opt-Out” below.
Kuder may from time to time implement a referral program. If you use our referral program to inform a friend about our Website, we will ask you for the friend’s name and e-mail address. Kuder will automatically send the friend a one-time e-mail inviting them to visit the Website. Kuder stores this information for the sole purpose of sending this one-time e-mail. The friend may contact Kuder in the manner specified under “Opt-In/Opt-Out” below to request the removal of this information from Kuder’s database.
This Website utilizes several security measures to prevent the loss, corruption or unauthorized dissemination of the information collected on this Website. Regardless of the security measures undertaken, however, no website operator can guarantee the security or privacy of data collected. Accordingly, despite our efforts to constantly monitor and upgrade our security measures, there will always remain a slight possibility that the data may become compromised. If at any time you become aware of any problems with Kuder’s security procedures, please contact the webmaster immediately at firstname.lastname@example.org so that we may review and correct any problems.
If at any time Kuder becomes aware of any unauthorized usage of this Website, including any unauthorized political, commercial, malicious, destructive or illegal use, Kuder may, at its discretion, purge the information and/or report any such activities to the relevant authorities. If you become aware of any such unauthorized usage of the Website, please contact the webmaster immediately at email@example.com.
In furtherance of Kuder’s effort to comply with the Children’s Online Privacy Protection Act of 1998, Kuder only collects data from such children under the age of 13 as described above under “COMPLIANCE WITH THE CHILDREN’S ONLINE PRIVACY PROTECTION ACT OF 1998.”
Kuder may also send Website and service announcement updates to users of the Website. Users are not able to unsubscribe from service announcements, which contain important information about the Website and Kuder’s service.
You have the option to ‘opt-out’ of having your information used for purposes not directly related to our Website by contacting Kuder in one of the manners specified below. If you opt-out, Kuder will use your personal information strictly for purposes directly related to the Website and for Kuder’s internal validation and norming purposes, and for no other purpose and will not provide that personal information to its partners or advertisers. You may also correct or update your personally identifiable information from time to time by contacting Kuder in one of the manners specified below.
302 Visions Parkway
Adel, Iowa 50003
You can also do this by contacting Kuder via telephone at (800) 314-8972 or by e-mailing our webmaster at firstname.lastname@example.org.
Kuder complies with the U.S. – EU Safe Harbor Framework, as set forth by the U.S. Department of Commerce, regarding the collection, use and retention of personal information transferred to Kuder from European Union (“EU”) member countries. Kuder has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement with respect to such personal information. For purposes of this U.S. – EU Safe Harbor Privacy Statement, “personal information” means information that relates to and identifies or can be used to identify an individual and which is transferred from the EU to the United States, is recorded in any form, and is within the scope of the EU Directive on Data Protection to which the Safe Harbor Framework relates. To learn more about the Safe Harbor Framework and the Safe Harbor Privacy Principles, and to view our certification page for such program, please visit http://www.export.gov/safeharbor/.
Date last revised: February 23, 2011.