- OVERVIEW
Alliance for Choice in Education (d/b/a ACE Scholarships and referred to in this Privacy Policy as “ACE”) is a nonprofit organization that provides financial assistance to low-income students, administers education savings account (ESA) programs, and offers other educational products and services, including the ACE platform and our websites and applications (collectively, our “Services”).
To provide these Services, ACE may process certain “personal information” (i.e., information that is linked or reasonably linkable to an identified or identifiable individual), including from or about parents, guardians, students, educational institutions, government agencies, marketplace vendors, and service providers. ACE has therefore adopted this Privacy Policy (this “Policy”) to explain how we collect, store, use, disclose, and otherwise process personal information in connection with our Services.
Please note that ACE is not responsible for the collection and use of information by organizations or individuals unaffiliated with us, including marketplace vendors. As such, please review the privacy policy of such third parties to learn about how they process and use personal information.
Additional terms may apply to you based on the state you reside in or the Services that we provide to you. Please see Additional Information Regarding Other Laws and Individual Rights below to learn more about additional terms and rights that may apply to you.
- WHAT WE COLLECT
The personal information ACE collects or receives depends on the context of your interactions with us and our Services. For example, ACE may collect certain personal information in connection with processing scholarship applications, managing ESA programs, communicating with you, ensuring compliance with scholarship requirements and applicable laws, and otherwise in connection with providing our Services.
The types of personal information we may collect may include:
- Identification information, such as names, including of parents, guardians, and their student(s), email addresses, mailing addresses, phone numbers, dates of birth, and other information provided when applying for scholarships, making donations, communicating with us, or otherwise using our Services;
- Educational and other eligibility information, including information related to a student’s educational institution, grade level, academic performance, residency status, and eligibility for educational programs and scholarships;
- Financial information, such as income information, family financial status, scholarship or grant information, including any other financial support a parent, guardian, or student is receiving for educational purposes, information necessary to process payments, and other information required to determine eligibility for scholarships or educational programs;
- Payment information, such as credit card numbers, bank account details, billing information, payment history, including when processing donations, payments, scholarships, orders and other transactions, and purchase history, including information about vendors and related purchases;
- Account information, such as username, password, and access credentials for our Services;
- Usage data, including information related to the use of our Services, including IP address, browser type, pages visited, device information and identifiers, and time spent with our Services;
- Communication data, including any inquiries, assistance, or support requested from us, the contents of such communications, records of such correspondence, and any feedback or survey responses that may help us improve our Services;
- Volunteer or employment information, including resumes, references, work experience, educational history, and interview notes in connection with applications for a volunteer or employment position with ACE;
- Sensitive personal information, including data that may be considered sensitive under applicable privacy laws, including information related to disabilities or special education needs (if disclosed), social security numbers, driver’s license numbers, state identification numbers, passport numbers, financial account numbers and security or access codes, passwords, or credentials allowing access to an account, precise geolocation, health or medical information, racial or ethnic origin, citizenship or immigration status, and/or religious or philosophical beliefs; and/or
- Third-party information, including information ACE may receive from educational institutions that provide academic records or confirm enrollment and attendance, government programs, financial aid providers, or other scholarship organizations that share eligibility details, and from partners, affiliates, vendors, and service providers who assist or participate in the scholarship application process or in administering or providing products or services, including in connection with ESAs.
Our Services are not intended to be used by children. We do not verify the age of any of our visitors or users, and by using our Services, you represent that you are at least eighteen (18) years of age. If you believe that we may have received information directly from a child, please contact us.
- How and where we collect your personal information
ACE Scholarships collects personal information in several ways, both directly and indirectly, including through interactions with our Services, and from third parties.
- Direct interactions: We collect personal information when it is provided voluntarily to us, including in connection with:
- Applications: During the application process, we collect contact information, as well as certain educational information about students, and financial information to assess eligibility;
- Subscriptions to newsletters or communications: When you subscribe to receive updates about our Services, scholarships, events, programs, or ACE’s activities, we may collect your email address and other contact information;
- Forms and surveys: We collect personal information provided in surveys or through forms on our Services, including on our websites (e.g., for scholarship application updates, feedback, or interest in new programs);
- Webinars, events, and conferences: We collect registration and attendance information, including any provided feedback or materials, from participants and registrants of our events (e.g., informational webinars, conferences, or workshops);
- Donations: We collect payment information, including credit card details or bank account information, and contact details for receipts and acknowledgments, in connection with receiving and administering contributions and donations;
- Communications: We collect information provided in communications to us, including via email, phone, or through website forms, such as inquiries for information or support related to scholarships, ESAs, other educational resources, or other aspects of our Services, as well as in connection with appeals made in connection with our Services; and/or
- Applications for jobs or volunteer positions: We collect personal and professional details from applicants for jobs or volunteer opportunities, such as resumes and references.
- Automatically through our Services: We may collect information automatically through interactions with our Services, including our websites. This may include:
- Cookies and tracking technologies: We use cookies, web beacons, and similar technologies (collectively, “cookies”) to collect data about how users navigate our Services, their preferences, and their interactions with our content. Cookies help us personalize user experience, remember preferences, and provide functionality such as session management and website analytics. For more details on how we use cookies and how to manage cookie preferences, please see the section on COOKIES below; and/or
- Usage data: We may automatically collect certain information when users access our Services, including IP addresses, browser types, device information, and pages viewed. This data helps us analyze website traffic, identify trends, and troubleshoot issues to improve user experience.
- Third-party sources: ACE may obtain personal information from third parties who support us and otherwise in connection with our provision of Services. These may include:
- Educational institutions or databases: Schools may provide us with information about students, including academic status and school attendance. This helps us verify eligibility for scholarships and educational assistance. We may also collect information from public school databases to prevent dual enrollment for ESA programs;
- Government agencies and financial aid programs: We may receive data from state or federal government agencies in order to provide our Services, including information related to financial status, tax filings, and eligibility for education-related financial aid or programs;
- Service providers: We may collect information from third-party organizations that assist with providing our Services, including to facilitate the proper administration of our programs and to ensure compliance;
- Vendors: ACE may collect certain types of information from vendors to facilitate the proper administration of ESA programs, ensure compliance, and provide necessary Services. The information shared depends on the vendor’s role and the nature of their offerings, but may include contact information, details of specific purchases, and other transaction data, which vendors may share with ACE in connection with the Services;
- Partner organizations: We may collaborate with other organizations or foundations that provide scholarship funding or educational support. These partners may share information with us about their applicants, financial need assessments, or academic records to ensure applicants meet the necessary criteria;
- Social media and public platforms: If users choose to connect with ACE through social media platforms or other public forums, we may collect information such as social media handles, profile details, or any public posts made in connection with ACE;
- Background check services: We may collect background check information from third-party providers as necessary for employment or volunteer verification purposes;
- Public records: ACE may access and collect personal information that is publicly available from public records or government databases, particularly in connection with applications for financial assistance that are linked to publicly available records (e.g., tax filings or government benefits); and/or
- Referral programs: If you are referred to ACE by a friend, family member, or another individual, we may collect basic contact information from the person referring you in order to manage the referral process and track the success of our programs.
- How We Use Your Information
ACE uses the personal information we collect for a variety of purposes in order to manage our programs, improve user experience, and otherwise to provide our Services. We do not sell personal information and we do not process personal information for targeting advertising purposes.
The following outlines the primary ways in which we may use personal information:
- Scholarship application processing: One of the most common reasons we use personal information is to process scholarship applications. We use personal information provided to us to review financial needs, academic performance, residency, and other factors to determine eligibility for scholarships. We also use it to allocate scholarship funds based on eligibility criteria and other relevant factors, such as the availability of funds, and we use it to communicate the outcome of scholarship applications and to provide instructions on next steps (e.g., accepting the award, providing additional documents, etc.);
- Program management: We may also use personal information to manage our educational support programs. For example, we may use contact details, financial information, purchase and payment information, and educational information to administer and manage ESAs, if applicable, including to process contributions and transactions, manage account balances, send updates, and communicate with you;
- Communication and support: We use contact details for communication purposes, including as applicable, to provide updates on the status of applications, changes to our Services and other relevant news or deadlines, to respond to inquiries or concerns regarding our Services, to send newsletters, promotional materials, or other communications related to our programs, including new scholarship opportunities, events, or collaborations (which you can opt-out of at any time by following the instructions in our emails or by contacting us directly), and to invite individuals to participate in ACE-hosted events, informational webinars, or community outreach activities;
- Financial assistance management: In addition to providing scholarships, we may use personal information to process and manage payments related to scholarship disbursements or any other financial assistance, including monitoring how scholarship funds are utilized. We may also use personal information to assess financial need and eligibility for other assistance programs, including government-funded scholarships or state-level educational support. We may also use it for purposes of handling donations, grants, scholarship funds, and other transactions;
- Services improvement: We may use personal information to improve our Services. For example, we may analyze usage data, such as duration of use of our Services and pages visited. This helps us understand which areas of our Services need improvement or additional resources, and allows us to enhance the user experience. We may customize users’ experiences based on interactions with our Services, including offering relevant opportunities or resources based on specific needs or interests. Finally, we may use technical information (e.g., IP addresses or device information) to ensure that our Services function properly and troubleshoot any issues that may arise, improving overall performance;
- Appeals: We may use personal information to process appeals in connection with decisions ACE makes with respect to eligibility, preference categories, suspensions, and/or denials in connection with our Services;
- Volunteer and employment purposes: If you apply for a job or volunteer position with ACE, we may use your information to evaluate your qualifications and experience, make hiring decisions, conduct interviews, and evaluate suitability for the role, and, if hired, we will use your personal information to maintain employment records, manage payroll, and comply with employment-related laws and regulations;
- Internal research and development: ACE may use anonymized or aggregated data to analyze trends and patterns with respect to the Services, scholarship applications, educational needs, and the effectiveness of our programs, and to evaluate and improve our offerings and educational support programs;
- Legal and compliance obligations: ACE is required to comply with various legal and regulatory obligations. As such, we may use personal information to adhere to applicable federal, state, and local laws and regulations, to provide reports to government agencies or regulatory bodies, including those that oversee scholarship disbursements, ESAs, and tax compliance, and to maintain records, including related to scholarship disbursements, applications, ESA-related transactions, and financial assistance, as required for legal or compliance purposes; and/or
- Protection and enforcement of legal rights: We may use personal information to protect our rights, property, or safety, and the rights, property, or safety of others. This may include detecting and preventing fraudulent activity, including fraudulent scholarship applications or financial transactions, ensuring compliance with our terms of use, policies, and other agreements, and/or defending ACE in legal proceedings, including responding to lawsuits or government inquiries.
- HOW WE SHARE YOUR INFORMATION
ACE does not sell, rent, or trade personal information to third parties. However, we may share personal information in certain situations, where necessary, to provide our Services effectively, comply with legal obligations, or with trusted partners, vendors, and service providers who participate in or help manage our programs and Services. Below are the ways we may share personal information:
- Third-party service providers: We work with trusted service providers to help operate our programs and deliver our Services. We may provide payment information to third-party service providers to handle transactions and process payments, and we may use third-party services to help verify eligibility for scholarships or educational assistance. We may also share information with web hosting providers, cloud service providers, and website developers to ensure the security, functionality, and ongoing maintenance of our Services. Third-party analytics providers may also process information about interactions with our Services to help us improve user experience, marketing strategies, and other operational aspects of our Services. We may use email marketing services, survey tools, and communication platforms to send you newsletters, notifications, and updates. These providers may have access to contact information for the purpose of sending communications on our behalf. We may also engage IT service providers for system maintenance, cybersecurity, and fraud detection to protect the security and integrity of personal information;
- Educational institutions: We may share necessary information with educational institutions or school administrators, including to confirm eligibility and participation in educational programs, to ensure that scholarship funds are being used for their intended purposes, and/or, if disclosed, we may share information related to special educational accommodations to ensure the provision of appropriate support;
- Government agencies: In some cases, we may share personal information with government entities or regulatory bodies, including to comply with tax reporting requirements and verify donations for tax-exempt purposes. We may need to share personal information of participants in government programs like ESAs with relevant government agencies to ensure compliance with program requirements and regulations. We may also disclose personal information to comply with a subpoena, legal process, or other lawful request by government authorities. This includes responding to court orders or requests for information in connection with legal proceedings;
- Vendors: ACE may share certain types of information with marketplace vendors to facilitate the proper administration of ESA programs, ensure compliance, and provide necessary Services. The information shared depends on the vendor’s role and the nature of their offerings, but may include contact information, details of specific purchases made through the ESA, including products purchased, purchase amount, and date of the transaction, balances, and transaction data, which ACE may share to allow vendors to process transactions, provide educational services, and/or fulfill requests;
- Partner organizations: We may collaborate with other organizations or foundations that provide scholarship funding or educational support, including information about applicants, financial need assessments, or academic records;
- Legal or corporate transfers: In the event of a merger, acquisition, or sale of all or part of ACE assets, your personal information may be transferred to the acquiring entity;
- Affiliates and fundraising partners: If you are involved in ACE’s fundraising efforts, we may share information with trusted partners or affiliates who help us with fundraising and campaigns and to track and process donations and contributions;
- With your consent: In certain cases, we may share personal information with third parties when you have given us explicit consent to do so, including for example, if you agree to participate in a program or research study that involves sharing your data with another organization or entity, in connection with marketplace transactions with vendors, or if you consent to public recognition; and/or
- To prevent fraud and protect rights: We may share personal information with law enforcement agencies or legal professionals if we believe it is necessary to investigate, detect and prevent fraudulent scholarship applications or donations and/or to protect the rights, property, and safety of ACE, our employees, participants, or others, including during legal proceedings or disputes.
- COOKIES
As mentioned, we use cookies to collect data about how users navigate our Services, including preferences and interactions with our content. We may use cookies to provide Services and related features available through our websites, to authenticate users and prevent fraudulent use of user accounts, to identify whether users have accepted the use of cookies on a website, to compile data about website traffic and how users use the website to offer a better website experience, and to understand visitor preferences for future visits, such as remembering login details or language preference, to provide a more personal experience, and to avoid users having to re-enter preferences every time they visit the website.
You may delete cookies from your web browser at any time or block cookies on your equipment, but this may affect the functioning of our Services. You can prevent saving of cookies (disable and delete them) by changing your browser settings accordingly at any time. It is possible that some functions of the Services will not be available when you deactivate cookies.
- HOW WE PROTECT YOUR INFORMATION
We follow industry-standard practices to secure personal information we collect and maintain to prevent any unauthorized access, use, or disclosure.
We use physical, technical, and organizational safeguards designed to protect personal information. For example, we use industry-standard encryption (SSL/TLS) to protect information during transmission and while stored. We also limit access to personal information based on employee roles and we enforce secure authentication methods. Personal information is also stored in secure servers with physical access controls, and regular backups to ensure data recovery in case of failure. We also use firewalls and intrusion detection systems (IDS) to protect against unauthorized access, and we conduct regular audits to identify and address vulnerabilities.
Our staff also undergoes regular training on data privacy and security to handle personal information responsibly and securely. We also require that any third-party service providers we work with adhere to strict security standards and we use secure methods when sharing personal information, such as encrypted communication channels.
Although we take the responsibility of safeguarding personal information seriously, no security measures are completely effective and we cannot guarantee that these practices will prevent every unauthorized attempt to access, use, or disclose your information.
- RETENTION
We keep personal information for different lengths of time depending on the type of information and our internal and legal requirements. In deciding how long to retain personal information, we consider many criteria, including the purposes for which the personal information was collected, relevant federal, state, and local recordkeeping laws, applicable statutes of limitations for claims to which the information may be relevant, and legal preservation of evidence obligations. Some information is deleted automatically after a set period of time, often set by law, unless we are legally required to hold it longer, such as for pending litigation.
- YOUR PRIVACY RIGHTS
You may have rights under certain privacy laws regarding the collection, use, and sharing of your personal information.
As described in more detail in Additional Information Regarding Individual Rights, depending on where you live and the types of information we collect about you, and subject to legal and contractual retention requirements, you may have the right to request:
- Access to the personal information we have collected from you;
- Correction of any inaccuracies in the personal information we have about you;
- Opt out from our marketing communications, which you can do by following the instructions in our email or contacting us directly. This opt-out may not apply to information provided to ACE as a result of purchases, registrations, or other transactions; and/or
- Deletion of your personal information.
As explained above, we may also use cookies and similar tracking technologies in our Services to provide personalized experiences, which you can control by changing your browser settings. For more information, see the COOKIES section above.
We will make all required updates and changes within the time specified and as required by applicable law. Requests may be submitted in writing to the contact information provided in the CONTACT US section below.
To help protect the privacy and the security of your information, we may request additional information to verify your identity and/or ownership rights prior to us exercising your privacy rights. If we are unable to verify your identity or ownership rights to the information, we may not be able to provide you with such rights until you are able to provide us with proper documentation.
Please note that there may be information we will not return or provide access to in response to an access request, such as information that would affect the privacy of others or interfere with legal requirements. Similarly, there may be reasons why we cannot comply with your deletion request, such as the need to keep your personal information to provide you the Services or to fulfill a legal obligation. In certain circumstances, we may not collect sufficient identifiers to match information in our records with your request.
Some web browsers incorporate a Do Not Track (“DNT”) or other similar feature that signals to websites that a visitor does not want to have his or her online activity and behavior tracked. Not all browsers offer a DNT option, and there is currently no industry consensus for how to recognize or respond to a DNT signal. For these reasons, ACE does not currently respond to DNT signals.
- Additional Information Regarding Other Laws and Individual Rights
Additional terms may apply to you based on the state you reside in or the Services that we provide to you. Please see below to learn more about additional terms and rights that may apply to you.
Additional Information regarding Colorado Residents’ Privacy Rights
Colorado law provides Colorado residents with rights to access, delete, and correct certain “Personal Data” collected about them, as well as to restrict the use of that Personal Data for “targeted advertising,” restrict the “sale” of that Personal Data, and control the use of Personal Data considered sensitive. If you are a Colorado resident, you may also have a right not to receive discriminatory treatment for the exercise of your privacy rights. While Colorado residents have the right to opt out of automated profiling that would produce legal or other similarly significant effects, we do not use Personal Data to make automated decisions in any situation where you would have a legal right to opt out.
The Colorado Privacy Act defines “Personal Data” to mean “any information that is linked or reasonably linkable to an identified or identifiable individual.” When we use the term “personal information” in our Privacy Policy, it includes Personal Data covered by this definition.
You or your authorized agent may submit a request to exercise these rights, as applicable, by contacting us using the information provided in the CONTACT US section below. For your security and to ensure unauthorized third parties do not access your personal information, we may require that you verify your identity before we can act on your request. If you are asking for access on behalf of someone else, we may require verification of your identity, as well as proof of authorization by the individual whose personal information you wish to access. If we deny your request, you have the right to appeal our decision. You can request further review by emailing us at the same email address.
Additional Information regarding Texas Residents’ Privacy Rights
Texas law provides Texas residents with rights to access, delete, and correct certain “Personal Data” collected about them, as well as to restrict the use of that Personal Data for targeted advertising, restrict the “sale” of that Personal Data, and control the use of Personal Data considered sensitive. If you are a Texas resident, you may also have a right not to receive discriminatory treatment for the exercise of your privacy rights. While Texas residents have the right to opt out of automated profiling that would produce legal or other similarly significant effects, we do not use Personal Data to make automated decisions in any situation where you would have a legal right to opt out.
The Texas Data Privacy and Security Act defines “Personal Data” to mean “any information, including sensitive data, that is linked or reasonably linkable to an identified or identifiable individual.” When we use the term “personal information” in our Privacy Policy, it includes Personal Data covered by this definition.
You or your authorized agent may submit a request to exercise these rights, as applicable, by contacting us using the information provided in the CONTACT US section below. For your security and to ensure unauthorized third parties do not access your personal information, we may require that you verify your identity before we can act on your request. If you are asking for access on behalf of someone else, we may require verification of your identity, as well as proof of authorization by the individual whose personal information you wish to access. If we deny your request, you have the right to appeal our decision. You can request further review by emailing us at the same email address.
Additional Information regarding Montana Residents’ Privacy Rights
Montana law provides Montana residents with rights to access, delete, and correct certain “Personal Data” collected about them, as well as to restrict the use of that Personal Data for targeted advertising, restrict the “sale” of that Personal Data, and control the use of Personal Data considered sensitive. If you are a Montana resident, you may also have a right not to receive discriminatory treatment for the exercise of your privacy rights. While Montana residents have the right to opt out of automated profiling that would produce legal or other similarly significant effects, we do not use Personal Data to make automated decisions in any situation where you would have a legal right to opt out.
The Montana Consumer Data Privacy Act defines “Personal Data” to mean “any information that is linked or reasonably linkable to an identified or identifiable individual.” When we use the term “personal information” in our Privacy Policy, it includes Personal Data covered by this definition.
You or your authorized agent may submit a request to exercise these rights, as applicable, by contacting us using the information provided in the CONTACT US section below. For your security and to ensure unauthorized third parties do not access your personal information, we may require that you verify your identity before we can act on your request. If you are asking for access on behalf of someone else, we may require verification of your identity, as well as proof of authorization by the individual whose personal information you wish to access. If we deny your request, you have the right to appeal our decision. You can request further review by emailing us at the same email address.
Additional Information regarding Utah Residents’ Privacy Rights
Utah law provides Utah residents with rights to access and delete certain “Personal Data” collected about them, as well as to restrict the use of that Personal Data for targeted advertising, restrict the “sale” of that Personal Data, and control the use of Personal Data considered sensitive. If you are a Utah resident, you may also have a right not to receive discriminatory treatment for the exercise of your privacy rights.
The Utah Consumer Data Privacy Act defines “Personal Data” to mean “information that is linked or reasonably linkable to an identified individual or an identifiable individual.” When we use the term “personal information” in our Privacy Policy, it includes Personal Data covered by this definition.
You or your authorized agent may submit a request to exercise these rights, as applicable, by contacting us using the information provided in the CONTACT US section below. For your security and to ensure unauthorized third parties do not access your personal information, we may require that you verify your identity before we can act on your request. If you are asking for access on behalf of someone else, we may require verification of your identity, as well as proof of authorization by the individual whose personal information you wish to access. If we deny your request, you have the right to appeal our decision. You can request further review by emailing us at the same email address.
Additional Information regarding Delaware Residents’ Privacy Rights
Delaware law provides Delaware residents with rights to access and delete certain “Personal Data” collected about them, as well as to restrict the use of that Personal Data for targeted advertising, restrict the “sale” of that Personal Data, and control the use of Personal Data considered sensitive. If you are a Delaware resident, you may also have a right not to receive discriminatory treatment for the exercise of your privacy rights.
The Delaware Personal Data Privacy Act defines “Personal Data” to mean “any information that is linked or reasonably linkable to an identified or identifiable individual.” When we use the term “personal information” in our Privacy Policy, it includes Personal Data covered by this definition.
You or your authorized agent may submit a request to exercise these rights, as applicable, by contacting us using the information provided in the CONTACT US section below. For your security and to ensure unauthorized third parties do not access your personal information, we may require that you verify your identity before we can act on your request. If you are asking for access on behalf of someone else, we may require verification of your identity, as well as proof of authorization by the individual whose personal information you wish to access. If we deny your request, you have the right to appeal our decision. You can request further review by emailing us at the same email address.
- CHANGES TO THIS PRIVACY POLICY
From time to time, we may change or update our Privacy Policy. We reserve the right to make changes or updates at any time and in our sole discretion. In the event that we make material changes to the way we process your personal information, we will notify you through our Services, by posting a notice on our website, by sending you a notification, or by other means consistent with applicable law.
You can see when this Privacy Policy was last updated by checking the “last updated” date displayed at the top of this Privacy Policy. If we amend our Privacy Policy, the amended Privacy Policy will take effect immediately for all users of our Services, and your continued use of the Services following an amendment will constitute your acceptance of the amended Privacy Policy. Please review this Privacy Policy periodically to stay informed about how ACE uses personal information and protects your privacy.
- CONTACT US
If you have any questions about this Privacy Policy, please contact us here or 303.573.1603