Last Modified: June 1, 2021

GUIDE TO CONTENTS

INTRODUCTION

Welcome to Creative Communication Associates (“CCA” or “we” or “us”). CCA is a full-service, full-funnel higher education marketing agency, we help colleges and universities uncover their differentiators and tell their stories in a variety of ways (the “Services”). CCA is owned and operated by Noodle Partners, Inc.

This privacy Policy applies to the https://www.ccanewyork.com/ website and any associated landing pages.

Because CCA values your privacy, we have created this Privacy Policy to explain how we collect information from and about you (“Personal Information”) when you visit our website and landing pages and how we may disclose and use that information.

This Privacy Policy applies to CCA’s collection and use of Personal Information, which is information that can be used to identify or contact a specific person, such as a full name or email address, as well as our practices for handling non-personally identifiable information, such as user preferences and services usage information.

By visiting CCA’s website, https://www.ccanewyork.com/, and any or our related landing pages, you agree to the terms and conditions of this Privacy Policy. If you do not agree with the terms of this Privacy Policy, please leave this page immediately and do not use any of our services or share any Personal Information with us.

COLLECTION OF INFORMATION

We collect information to provide Services to all of our users and to improve our Services. We limit the collection of information to only that which is absolutely necessary to carry out our legal or business obligations. We store the information we collect with unique identifiers tied to the browser, application, or device you’re using.

CCA and our service providers may collect the following information from and about you:

  • First Name and Last Name
  • Email Address
  • Phone Number
  • Zip Code
  • Program of Interest
  • Level of Education Attained
  • Whether or not you’ve taken an Admissions Exam
  • Years of work experience
  • Gender
  • Picture
  • Education history
  • Areas of interest which you have explicitly declared, as well as what we can infer from your engagement with our products and services

Information from Social Media and Other Sites

You may have the option to sign up for CCA Services through a social media service (e.g., Facebook or another third-party site. If you sign up for a CCA account in this way, we may collect information about you from that service or site, which may include the username associated with that service or site, your name, profile picture, email address, gender, birthday or friends lists, your likes, preferences, searches, comments and posts, and any other information or content of yours collected by that service or site. All information from and about you that is collected from social media services and third-party sites in this manner may be used and disclosed by CCA in accordance with this Privacy Policy.

Activity Information

When you access and interact with the CCA Services, we may collect certain information about those visits, such as your searches and preferences as well as technical information about your computer and its operating system, your internet browser, your internet protocol address, your navigation path (including your navigation on the CCA Services and the domain names of the sites from and to which you link), and other information about your software and hardware. If you access the CCA Services from a mobile or other device, we may collect certain information including the unique device identifier assigned to that device, geolocation data, your wireless service provider, operating system, browser type and other transactional information for that device.

Use of Web Beacons

Some of our web pages may contain electronic images known as Web beacons (sometimes known as clear gifs) that allow us to count users who have visited these pages. Web beacons collect only limited information including a cookie number, time and date of a page view, and a description of the page on which the web beacon resides. We may also carry web beacons placed by third party advertisers. These beacons do not carry any Personal Information and are only used to track the effectiveness of a particular campaign.

We may also use web beacons or similar technology to learn whether or not emails sent to you have been opened.

Cookies and California Do Not Track Disclosures

Cookies are small bits of data that a site or its service provider transfers to your computer through your browser that enables the site or service provider to recognize your browser and remember certain information about you. We may use cookies and other tracking technologies (such as pixel tags, ad tags and web beacons) to collect information to help us understand your interactions with the CCA Services, such as pages you have visited, content you have viewed, search queries you have run and advertisements you have seen. Third parties that support the CCA Services by serving advertisements or providing services, such as allowing you to share content or tracking aggregate usage statistics, (e.g., Google Analytics tracking and Google AdWords) may also use these technologies to collect similar information. CCA does not control these third-party technologies and their use is governed by the privacy policies of the third parties using such technologies. Your browser may permit you to disable these technologies. However, doing so may prevent you from using certain parts of the CCA Services. See the cookies policy for more information.

If you would like to delete cookies or instruct your web browser to disable tracking please visit the help pages on your web browser. However, doing so may prevent you from using certain CCA Services. Please note that CCA does not respond to “Do Not Track” settings configured in your web browser.

Information from Other Sources

We may supplement the information we collect through the CCA Services with information from other sources, such as information that you submit to CCA directly by email, telephone or other means (e.g., information you provide to CCA’s customer service team) and publicly available information from social media services, commercially available sources and information from our affiliates or business partners.

Legal Basis For Processing Your Personal Information

We collect and process information about you only where we have a legal basis for doing so under applicable law. The following are the legal bases for collecting and processing your Personal Information:

When you give us your consent to do so, this includes:

  • Where consent is required by law, and where we ask for your consent to process your Personal Information for a stated purpose.
  • Where we rely on your consent to process your Personal Information, you may withdraw your consent at any time. You will not suffer any detriment for withdrawing your consent. If you withdraw your consent, this will not make the processing which we undertook before you withdrew your consent unlawful.

To meet contractual obligations or obligations related to a contract, this includes:

  • Providing our services and their features to you.
  • Providing you with customer support.
  • Responding to your communications and requests.
  • Communicating with you.
  • Creating an account and profile for you.

For CCA’s legitimate interests, this includes:

  • Developing and operating our business.
  • Maintaining and improving our products and services.
  • Operating our site and providing our services.
  • Conducting market research, audits, and other business operations.

For purposes which are required by law, this includes:

  • Complying with any regulations, procedures, and laws which apply to us.
  • Investigating misuse of your account.

USE AND DISCLOSURE

When information collected from or about you does not identify you as a specific person, CCA may use that information for any purpose or share it with third parties who may use it for any purpose. When information collected from or about you is personally identifiable, CCA and our service providers may use and disclose that information in the following ways:

To provide and personalize the CCA Services

We use your Personal Information to provide the requested CCA Services and its features to you, including: to improve the CCA Services and its features, to personalize the CCA Services, and to improve your experience with the CCA Services by delivering content and advertising you will find relevant and interesting, by customizing search results generated by your queries, and by making recommendations based on your preferences; and to provide you with customer support and to respond to inquiries.

To allow service providers to assist us in providing and managing the CCA Services

CCA may make your Personal Information available to certain third party service providers solely for the purpose of helping us with our business operations, such as data processing, marketing, and technology services.

To allow social sharing functionality

By accessing the CCA Services from a social media service or third-party site, you are authorizing us to share your Personal Information with the social media service or third-party site provider and other users and your friends on that service or site and you understand that use of such shared information by the social media service or third-party site provider will be governed by its privacy policy. If you do not want your Personal Information shared in this way, please do not connect your social media service or other third-party account with your CCA Services account and do not participate in social sharing on the CCA Services.

To deliver relevant advertisements

CCA and our service providers may use your Personal Information to deliver relevant ads to you when you use the CCA Services or another service. As noted above, third-party advertising networks and advertisers may use cookies and similar technologies to collect and track information such as demographic information, inferred interests, aggregated information, and activity, including but not limited to information about your visits to websites to display advertisements more tailored to your interests and to provide you the most relevant advertising. If you wish to know more about this practice or would like to know more about your options, you can visit the Network Advertising Initiative (“NAI”) web-site. The NAI is a cooperative of online advertising companies who are committed to responsible practices and consumer protection.

To contact you

CCA may periodically send you promotional materials, newsletters, or notifications related to CCA and the CCA Services and related products or services. These emails are meant to be useful to you while helping us improve our user experience. However, if you want to stop receiving promotional materials, you can follow the unsubscribe instructions at the bottom of each email. There are certain service notification emails that you may not opt-out of, such as notifications of changes to the CCA Services or policies.

To share with our CCA Affiliates

CCA may share your Personal Information with our affiliates for the purposes described in this Privacy Policy.

To protect the rights of CCA and others

There may be instances when CCA may disclose your information, including situations where CCA has a good faith belief that such disclosure is necessary in order to: (i) protect, enforce, or defend the legal rights, privacy, safety, or property of CCA; (ii) protect the safety, privacy, and security of users of the CCA Services or members of the public; (iii) protect against fraud or for risk management purposes; (iv) comply with the law or legal process; or (v) respond to requests from public and government authorities.

To complete a merger or sale of assets

If CCA sells all or part of its business or makes a sale or transfer of its assets or is otherwise involved in a merger or transfer of all or a material part of its business, CCA may transfer your Personal Information to the party or parties involved in the transaction as part of that transaction.

USER CONTROL OF PERSONAL INFORMATION

Personally identifiable Information

Please do not submit to us or post on the CCA Services any Personal Information that you do not want us to collect. In particular, we ask that you not send us, and you not share, any sensitive information, such as social security numbers, on or through the CCA Services. Please keep in mind that, although you are not required to provide any Personal Information that we request, in many cases, if you do not provide us with the requested information, we may not be able to provide you with certain services or respond to any questions you may have.

Receiving electronic communications from us

If you no longer want to receive emails from us on a going-forward basis, you may opt-out of receiving these emails by following the unsubscribe instructions in the email footer. We will process your request within a reasonable time after receipt. However, we are not responsible for removing your Personal Information from the lists of any third party who has previously been provided your information in accordance with this Privacy Policy or your consent.

Canceling your account

While your account is active, we retain your Personal Information. If you cancel your account or if we terminate your account for any other reason, we may continue to retain your Personal Information for reasons including, but not limited to, complying with our legal obligations or our internal security policies, meeting regulatory requirements, for fraud detection, improving our site and services, or enforcing this Privacy Policy. Remember that even after your account is cancelled, copies of some information from your account may remain viewable in some circumstances, for example, where you have shared information with a third-party application or web site or where you have posted your Personal Information publicly on the CCA Services. In addition, because of the nature of caching technology, your account may not be instantly inaccessible to others, and there may be a delay in the removal of the content from elsewhere on the Internet and from search engines.

SECURITY

The security of your information is very important to us. To safeguard Personal Information of the users of the CCA Services, CCA has chosen to use a proven method of securing its data and business supporting technologies. By employing the International Standards Organization’s (“ISO”) 27001 standard, which formally specifies an Information Security Management System, CCA follows a mature program for the assurance of information security. However, due to the inherent open nature of the Internet, no data transmission over the Internet or any wireless network can be guaranteed to be secure. As a result, while we take measures to protect your Personal Information, we cannot ensure or guarantee the security of any information you send to us or that we store on our servers. Your use of the CCA Services demonstrates your assumption of this risk.

DATA TRANSFERS

Personal Information collected by CCA may be transferred to, stored, and processed, in your country and in the United States, or any other country where our service providers process information. Our service providers are required by contract to safeguard this Personal Information and are prohibited from using it for any purpose other than to perform the services instructed by CCA. Data protection laws vary among countries, with some providing more protection than others. Regardless of where your information is processed, we apply the same protections described in our Privacy Policy. We also take steps to provide adequate protection for any transfer of your Personal Information in accordance with applicable law.

LINKED SERVICES

The CCA Services may contain links to third-party services and sites, and may carry advertisements or offer content, functionality, games, newsletters, contests or sweepstakes, or applications developed and maintained by unaffiliated companies. CCA is not responsible for the privacy practices or content of such third-party services and sites and unaffiliated companies. Once you leave the CCA Services or click an advertisement you will be bound by, and should review the applicable privacy policy of, the other site or service.

SOCIAL MEDIA

The CCA Services may contain links to our presence on various social media platforms. We do not operate or control these platforms. You should be aware that Personal Information which you voluntarily include and transmit online in a publicly accessible blog, social network or otherwise online may be viewed and used by others. We are unable to control these uses of your personally identifiable information, and by using such services you assume the risk that the Personal Information provided by you may be viewed and used by third parties

OTHER IMPORTANT INFORMATION

PROTECTION OF CHILDREN

The CCA Services are not targeted to children, and we do not knowingly collect Personal Information identifiable information from children younger than 16 years of age. If we become aware that Personal Information from a child younger than 16 years of age has been collected without the consent of such child’s parent or guardian, we will delete such information from our database without requesting permission to do so.

YOUR CALIFORNIA PRIVACY RIGHTS (FOR CALIFORNIA RESIDENTS ONLY):

Under the California Consumer Privacy Act (CCPA), California consumers are entitled to disclosures regarding the collection and use of their Personal Information. This section describes your CCPA rights and how to exercise those rights.

Collection and Disclosure of Personal Information

In the past 12 months, we may have collected, and may have disclosed for our business purposes, the following categories of Personal Information relating to California residents:

  • First Name and Last Name
  • Email Address
  • Phone Number
  • Location
  • Education History
  • Gender
  • Information from social media and other sites
  • Usage Data

Other Personal Information described in the section above titled “Collection of Information” may have been collected.

The categories of sources from whom we collected this Personal Information

Categories of sources from whom we collect Personal Information are described above under the section titled “Collection of Information.”

Purposes of collecting Personal Information

We collect the Personal Information described above to provide services to all of our users, to improve our services, and for our business purposes. We limit the collection of information to only that which is absolutely necessary to carry out our legal or business obligations, and for the purposes described under the section titled “Use and Disclosure.”

The categories of third parties to whom we may disclose Personal Information for our business purposes are:

  • Affiliates of CCA for the purposes described in this policy.
  • Providers of the CCA Services that you are interested in
  • Third party service providers solely to assist us in providing and managing our services, such as data processing, marketing, and technology.
  • To third parties to protect the rights of CCA and others.

Rights of California Consumers under the CCPA

If you are a California resident you have a right to request that we provide you with the following information from 12 months prior to your request:

  • The categories of Personal Information that we have collected about you.
  • The categories of sources from which the Personal Information was collected.
  • The business or commercial purpose for collecting Personal Information about you.
  • The categories of third parties with whom we shared or sold your Personal Information.
  • The specific pieces of Personal Information we have collected about you and may have shared or sold.

You have the right to request that we delete any Personal Information we may have collected about you, unless the CCPA recognizes an exception. You also have the right to request to know what information we have about you. If you would like to exercise your right to request to delete your information or know about your information you may do so by sending an email to privacy@ccanewyork.com. Please provide your first name, last name, and email used to provide us your personal information. Please also indicate whether you wish for us to delete your information from our database, or if you would like to know what information we have about you.

The CCPA prohibits discrimination against any consumer for exercising any of the rights described above. You have the right for us to process your request free of charge within 45 days of us receiving a verifiable consumer request.

Sale of Personal Information

**CCA educator does not sell your Personal Information**

Identity Verification Process

Verification Process: Once we receive a request to know or to delete your information, we must verify your identity before we can process your request. We will verify your identity by sending you an Identity Declaration document (“Declaration”) to sign. Your identity will be verified with the information you provided to us in your email request and by you signing the Declaration.

Authorized Agent

A California resident may use an authorized agent to submit requests to opt-out of the sale of their Personal Information, delete their Personal Information, and know about their Personal Information collected. To use an authorized agent the California resident must provide the agent with written authorization and the California resident may be required to verify their identity with CCA. We may reject the request of an authorized agent that does not provide proof of authorization. Please submit a detailed request and proof of authorization to privacy@ccanewyork.com.

RESIDENTS OF THE EUROPEAN ECONOMIC AREA

GDPR PRINCIPLES

CCA complies with the principles of the GDPR and adheres to that Personal Information shall be:

  • Processed lawfully, fairly and in a transparent manner in relation to the person.
  • Collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes.
  • Adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed.
  • Accurate and, where necessary, kept up to date.
  • Kept in a form which permits identification of persons for no longer than is necessary for the purposes for which the Personal Information is processed.
  • Processed in a manner that ensures appropriate security of the Personal Information.

If you reside or are located in the EEA you have the right, under certain circumstances, to request that we:

  • Erase your Personal Information without undue delay.
  • Provide you with your Personal Information in a structured, commonly used and machine-readable format.
  • Rectify any inaccurate Personal Information concerning you.
  • Restrict the way we process your Personal Information.
  • Inform you about what Personal Information we collect about you.
  • Don’t subject you to a decision based solely on automated processing.
  • Do not process your Personal Information and that we do not provide your Personal Information to third parties.

Noodle Partners, Inc. is the data controller, which means that we are responsible for responding to your requests in relation to how your Personal Information is used. If you have any privacy concerns or if you would like to exercise any of your statutory rights described above please let us know by contacting us at this email address privacy@ccanewyork.com. Please provide your full name, contact information, and a detailed description of your request. You may use this same email address to contact CCA’s Data Protection Officer. We will address your request or inquiry without undue delay.

UPDATING YOUR PERSONAL INFORMATION

You may review, correct, update or change your Personal Information at any time by contacting us at privacy@ccanewyork.com.

RETENTION

We will retain your personal data for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law. This retention period may be extended if any applicable statutory or regulatory obligation requires us to hold information for a longer period.

UPDATES THIS PRIVACY POLICY

We may modify this Privacy Policy. Please look at the date above to see when this Privacy Policy was last revised. Any changes to this Privacy Policy will become effective when we post the revised Privacy Policy on the CCA web pages and landing pages. Policy changes will apply only to information collected on and after the date of the change.

HOW TO CONTACT US

As a reminder, if you have any questions about this statement or your personal information, please contact us at privacy@ccanewyork.com.

We’re Listening. Let’s Talk.