California Privacy Statement

The California Consumer Privacy Act (“CCPA”) went into effect on January 1, 2020. CCPA concentrates on the protection of natural persons who are residents of California with regard to the processing of personal data and on the free movement of such data. CCPA sets new standards and compliance requirements for companies which have an annual gross revenue of 25 million; buy, receive, sell or share the personal information of 50,000 or more “residents”; or make at least half their annual revenue from the sales of personal information.

enrollmentFUEL, LLC is US based company, having its registered office at 136 E Rosemary St., Suite 100 | Chapel Hill, NC 27514, USA. enrollmentFUEL currently collects and shares the personal information of California residents and is subject to CCPA regulation. enrollmentFUEL is committed to protecting the data of our clients and their consumers. We set high standards for the handling of any and all information we collect, and manage data in accordance with legislation and regulation, including but not limited to CCPA. enrollmentFUEL verifies it will comply with all applicable CCPA regulations as a company which collects and stores, for a limited time period, potential college and university applicant data for the colleges and universities we partner with. We also strive to work in conjunction with our customers, the data controllers, to help them meet their CCPA obligations. Currently, the CCPA is interpreted to not include colleges and universities and other not for profit institutions. However, the CCPA does affect enrollmentFUEL and the data we collect.

Visitors to enrollmentFUEL’s website are not subject to personal information data collection. However, enrollementFUEL does receive the private information of California residents from our partners and clients. As part of our commitment to providing the best products and services to our clients, we do store personal information of California residents to help enrollment leaders at colleges and universities across the nation shape their classes and bring to life their campuses. Because of this we have updated our systems in order to comply with CCPA. We have created a policy which can be provided to any California resident and which includes the following information:

• Provides insight into what personal information is being collected about the California Resident;
• Gives the information on how to obtain access that information;
• Informs the resident that as part of our service their personal information may be disclosed to various colleges and universities;
• Informs the resident that while we do not sell their personal information that we do share that information. We also provide the resident with the opportunity to opt-out of our service;
• Informs the resident that they will receive equal service and price whether or not they exercise their privacy rights.

As part of our commitment to service we make it easy for California residents to contact us and submit a request to access their information and if desired to have such information erased from our systems.

In order to protect the data we collect we continue:

1. Building on and perfecting existing security and data management policies, processes and controls, to ensure compliance.
2. Analyzing privacy risks, and updating our systems to support CCPA compliance for enrollmentFUEL customers, and for the data we collect from their potential applicants. enrollmentFUEL is committed to protecting data from inappropriate access or use and stores only data needed to successfully fulfill the needs of our customers. enrollmentFUEL does not collect data outside of the interest of our organization or the interest of our customers’ organizations.
3. Working with our vendors who help us analyze the data we collect from authorized third-parties, our advertisements, and other marketing tools to ensure the vendor is compliant with CCPA regulations and understand privacy best practices.

It is important to stress that compliance is a shared responsibility and that enrollmentFUEL customers may also need to adapt their business processes, data management practices, and integrations. enrollmentFUEL attests that the customers of its marketing solutions remain the sole owner of the data, retaining the rights, title, and interest in the data stored from our student search campaigns and can take advantage of the features inherent in the service to meet their CCPA obligations related to deletion, rectification, transfer of, access to, and objection to processing of personal data.

As a data processor, enrollmentFUEL is undertaking assessments of the data we collect, revamping our security policies and procedures, and analyzing our contracts with data controllers and our sub-contractors. enrollmentFUEL is also reviewing our data erasure procedures and will adjust storage as necessary for each customer’s unique needs.

Finally enrollmentFUEL ensures that our staff are familiar with CCPA and their personal responsibilities and are adequately trained upon induction into the company and must complete an annual review of CCPA policies. Should there be a major legislation change, we will hold a companywide, mandatory training session to review the latest guidelines to continue to educate our employees on their responsibilities. The Privacy Policy and Terms of Service for enrollmentFUEL’s services are accurate, written in plain language and provide sufficient detail (1) the categories of information collected from customers of enrollmentFUEL services in the last twelve months and the sources of that information, we also include the  purpose for each category; (2) we inform them that the consumer may only make a personal information request twice in a twelve month period and that enrollmentFUEL will need to collect information from the requesting party so that we can verify their identity, and that enrollmentFUEL will respond within 45 days of receiving a personal information request; (3) we inform customers of what information is selected, how it is used and how long their information is being retained; (4) we inform them that third parties may have access to only necessary data in order to provide logistics reports and success rates; and (5) we provide easy to follow directions for erasure and requests for information including a direct link to our Data Processing Officer’s contact information.

enrollmentFUEL is committed to protecting our customer’s data and the data they share with us. enrollmentFUEL’s Associate VP of Business Intelligence & Analytics and our Data Processing Officer, Tyler Brenneman, may be reached at tyler.brenneman@enrollmentfuel.com or (617) 320-5710. You may also send inquiries to:

enrollmentFUEL, LLC
ATTN: Tyler Brenneman
PO Box 9792
Chapel Hill, NC 27515
United States of America

Additionally, customers have a right to a copy of the data being collected and may withdraw their consent at any time provided they alert the DPO. Altering data consent may result in altered availability of statistical data relevant to a customer’s advertising campaign. Such impacts will be addressed at the time consent is withdrawn.

{N0178221.DOCX; 1} Last Updated 3/31/2023