2. Overview of MPOWER Data Collection and Privacy Principles

To ensure compliance with all applicable laws and to inform you of all of your rights, this Site specific policy is long and detailed. We believe a short summary of our most important policies is helpful, while all of the detail is available below.

1. We do not collect, process, or share user data without your express consent, which is generally given through a check-box that clearly identifies the purpose of the data collection and directs you to this policy.
2. We do not knowingly collect any personal information from children under the age of thirteen.
3. We use cookies, but only in a limited way, and not in any manner that can personally identify the data subject.
4. We collect personal data when you want to: use one of our services or register on any of our Sites to search for or inquire to a college or university or to search for scholarships; sign up to receive a newsletter or other related offers from us; request services or offers through a Site; request a quote or purchase an insurance policy through us; or contact us through a form on one of our Sites. In each such instance, we ask for consent as part of the collection process. Each of these types of collection and processing of personal data is addressed in greater detail below.
5. Our collection and processing of personal data, such as your name, address, email address, or telephone number, shall comply with applicable law.
6. We comply (to the extent applicable) with all data subject rights provided under US law and the GDPR, including the rights of confirmation, access, rectification, erasure, restriction of processing, and data portability, as well as the right to object and right to withdraw consent.

3. Definitions

The privacy policy and data protection declaration contains terms and definitions used in connection with the adoption of the GDPR by the European Union. Our data protection declaration should be legible and understandable for the general public, as well as our customers and business partners. In furtherance of this goal, we would like to first explain the terminology used.

In this data protection declaration, we use the following terms:

1. Personal data
2. Personal data means any information relating to an identified or identifiable natural person (“data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
3. Data subject
4. Data subject is any identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing.
5. Processing
6. Processing is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
7. Restriction of processing
8. Restriction of processing is the marking of stored personal data with the aim of limiting their processing in the future.
9. Profiling
10. Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements.
11. Controller or controller responsible for the processing
12. Controller or controller responsible for the processing is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
13. Processor
14. Processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
15. Recipient
16. Recipient is a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with European Union (“EU”), EU Member State, U.S., or other applicable law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.
17. Third party
18. Third party is a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorized to process personal data.
19. Consent
20. Consent of the data subject is any freely given, specific, informed, and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her. Typically on the Sites, consent is given by checking a box that describes the proposed use of the data and directs the data subject to this policy.

4. Name and Address of the controller

Controller for the Sites is:

MPOWER Financing, PBC1101 Connecticut Avenue, Suite 900Washington, DC 20036 U.S. Phone: 202-417-3800Email: privacy@mpowerfinancing.comWebsite: www.mpowerfinancing.com

5. Cookies

We use cookies for all Sites. Cookies are text files that are stored in a computer system via an Internet browser.

We use cookies that contain a so-called cookie ID. A cookie ID is a unique identifier of the cookie. It consists of a character string through which Internet pages and servers can be assigned to the specific Internet browser in which the cookie was stored. This allows us to know when you visited our Sites and servers and identify and differentiate you from other visitors to our Sites.

Through the use of cookies, MPOWER can provide the users of its Sites with more user-friendly services that would not be possible without cookies. The information and offers on our Sites can be optimized for each user. Cookies allow us, as previously mentioned, to recognize users of our Sites. The purpose of this recognition is to make it easier for users to utilize our website. For example, by allowing cookies visitors do not have to enter access data each time a Site is accessed.

The data subject may, at any time, prevent the setting of cookies through our websites by means of a corresponding setting of the Internet browser used, and may thus permanently deny the setting of cookies. Furthermore, already set cookies may be deleted at any time via an Internet browser or other software programs. This is possible in all popular Internet browsers. If you decline or deactivate our placement of cookies on your Internet browser, you may eliminate or disable certain features or functions on our Sites.

6. Collection of insurance application and purchase information

Users can initiate a purchase of international travel and health insurance policies directly through the Sites. Users can also apply for international major medical policies through the Sites. MPOWER passes the data (that you provided and we collected) directly through to our insurance company partners in order for them to process your application. MPOWER retains Personal Information which includes name, address, email, phone number, date of birth, policy number, travel dates and destinations, home country and citizenship, that is necessary so that MPOWER can provide services to you. MPOWER’s insurance partners have each confirmed their compliance with HIPAA, GDPR, and any other applicable data privacy laws, and their privacy policies are all freely available from their websites. Here is the privacy policy of our primary insurance partner, International Student Insurance (ISI): https://www.internationalstudentinsurance.com/privacy-policy.

7. Collection of general data and information

The Sites collect data and information whenever you visit a Site. This data and information are stored in server log files. The data and information collected may include: (1) browser types and versions used, (2) the operating system used by the accessing system, (3) website(s) from which an accessing system reaches a Site (so-called referrers), (4) sub-websites, (5) the date and time of access to a Site, (6) an Internet protocol address (IP address), (7) the internet service provider of the accessing system, and (8) any other similar data and information that may be available.

MPOWER uses such data and information to: (1) deliver Site content correctly; (2) optimize Site content and advertising; (3) enable and maintain the stability, viability, and security of our information technology systems and website technology; and (4) provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack. MPOWER continuously monitors and analyzes that data and information for data protection and data security purposes.

8. Registration on our websites

The data subject has the possibility to register on MPOWER websites. When you register on a Site, the personal information you provide (including, but not limited to your name, address, email, home country, country of citizenship, highest education level achieved, degree sought, and area of study), as well as your IP address, and the date and time of your registration is collected and stored. We use this data to prevent the misuse of our services and Sites, and, where necessary, investigate and prosecute the criminal or improper use of a Site. This data is not passed on to third parties unless there is a statutory obligation to pass on the data, or if the transfer serves the aim of criminal prosecution.

Your registration on a Site, along with your voluntary submission of personal data, allows us to offer you Site specific content or services. You may edit or change your personal data at any time, or to have it deleted in accordance with applicable law.

In addition, we offer a “school search” through which users can search, sort, and select which colleges and universities they may be interested in. Upon your request, we will deliver your inquiry, including your personal data, to the selected college or university on your behalf. Personal data will never be shared or delivered to colleges, universities or other partners without your consent.

MPOWER shall, upon your request, tell you what personal data we have stored about you. Subject to applicable law, MPOWER shall, upon your written request, correct or erase your personal data from its records.. Please send any data requests to privacy@mpowerfinancing.com for prompt handling.

9. Subscription to our newsletters

On our Sites, users are given the opportunity to subscribe to various newsletters. Each Site and newsletter determines what personal data is collected and transmitted as part of the subscription process, however, at a minimum, all newsletter subscriptions require (1) a valid email address and (2) your registration and consent to newsletter delivery.The operating company of ShareThis is the Oracle Corporation

For all newsletter registrations, we also store your IP address, as well as the date and time of your registration.

All data and information collected when you register on a Site for any newsletter(s) will only be used to send you newsletters and other relevant email communications regarding our resources and offers. There is no other transfer of your personal data to any non-disclosed third party, except to the email service provider (ESP) we use to manage Site’s email list. Our current ESPs are Critical Impact and MailChimp. You may terminate your subscription to any of our newsletters at any time. For the purpose of unsubscribing to a newsletter, a corresponding link is found in each newsletter and other email. Once unsubscribed, MPOWER and its email service provider retains a record of your unsubscribe request.

10. Newsletter of general data and information

We process and store your personal data of the data subject only for the period necessary to achieve the purpose of storage, as far as authorized by US or other applicable law.

If the storage purpose is not applicable, or if a storage period prescribed by applicable law expires, the personal data are routinely blocked or erased in accordance with legal requirements.

11. Contact possibility via the website

All Sites contain electronic contact forms which generate an instant communication to us. As a result, If you contact us by either email or a contact form, your personal data is transmitted by the data subject and automatically stored. We do not transfer any of this personal data to any third parties.

12. Routine erasure and blocking of personal data

We process and store your personal data of the data subject only for the period necessary to achieve the purpose of storage, as far as authorized by US or other applicable law.

If the storage purpose is not applicable, or if a storage period prescribed by applicable law expires, the personal data are routinely blocked or erased in accordance with legal requirements.

13. Rights of the data subject

• Right of confirmation
• You have the right to obtain from us confirmation as to whether or not your personal data is being processed. If you wish to exercise this right, please send us an email request at privacy@mpowerfinancing.com.
• Right of access
• You have the right to know what personal data about you. We store this data and you have a right to receive a copy of this information. Furthermore, you have the right to know the following information:
• The purposes of the processing;
• The categories of personal data concerned;
• The recipients or categories of recipients to whom your personal data have been or will be disclosed, in particular recipients in third countries or international organizations (if any);
• Where possible, the period for which your personal data will be stored, or, if not possible, the criteria used to determine that period;
• The existence of your right to request us to rectify or erase your personal data, or restrict our processing of your personal data or to object to such processing;
• The existence of your right to lodge a complaint with a supervisory authority;
• When the personal data we collected did not come from you, any available information as to its source;
• The existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and consequences of such processing on you.
• You have a right to know if your personal data was transferred to a third country or to an international organization. If such applies to you, you shall have the right to be informed of the appropriate safeguards relating to the transfer. If you wish to avail yourself of this right of access, you may, at any time, send a request to privacy@mpowerfinancing.com.
• Right to rectification
• You have the right (without undue delay), to correct any inaccurate or incorrect personal data about you. Taking into account the purposes of the processing, you have the right to have your incomplete personal data completed, including by means of providing a supplementary statement. If you wish to exercise this right to rectification, you may, at any time, send a request to privacy@mpowerfinancing.com.
• Right to erasure (Right to be forgotten)
• You have the right request the erasure of your personal (without undue delay), and we have the obligation to erase your personal data where one of the following grounds applies, so long as no other legal obligations on us, exist:
• Your personal data is no longer necessary with respect to purposes for which your personal data was collected or otherwise processed.
• You withdraw your consent to our processing of your personal data in accordance with point (a) of Article 6(1) of the GDPR, or point (a) of Article 9(2) of the GDPR, and where there is no other legal ground for such processing.
• You object to our processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for such processing, or you object to our processing pursuant to Article 21(2) of the GDPR.
• Your personal data was unlawfully processed.
• Your personal data must be erased for compliance with a legal obligation of a law to which we are subject.
• If one of the aforementioned reasons applies, and you wish to request the erasure of your personal data stored by us, you may, at any time, send a request to privacy@mpowerfinancing.com.
• Where we have made your personal data public and are obliged pursuant to Article 17(1) to erase such personal data, we shall (taking account of available technology and the cost of implementation) take reasonable steps, including technical measures, to inform parties processing the personal data that you have requested erasure of any links to, or copy or replication of, your personal data processed by them, provided that such processing is not otherwise mandated or required. We will arrange the necessary measures in such individual cases.
• Right of restriction of processing
• You have the right to to restrict our processing of your personal data where one of the following applies:
• You contest the accuracy of your personal data, for a sufficient period to allow us to verify the accuracy of your personal data.
• Our processing is unlawful and you oppose the erasure of your personal data and request the restriction of your personal data instead.
• We no longer need your personal data for the purposes of our processing, but is required by you in connection with the establishment, exercise or defense of legal claims.
• You objected to processing pursuant to Article 21(1) of the GDPR pending the verification that we have legitimate grounds to override your objection.
• If one of the aforementioned conditions is met and you request that we restrict our processing of your personal data stored by MPOWER, you may at any time send a request to privacy@mpowerfinancing.com. MPOWER will arrange the restriction of the processing.
• Right to data portability
• You have the right to receive your personal data held by us in a structured, commonly used, and machine-readable format. You shall also have the right to transmit such data to another data controller without hindrance from us, subject to certain limitations set forth in Article 6(1) or Article 9(2) of the GDPR. Furthermore, in exercising your right to data portability, you have the right to have your personal data transmitted directly by us to another data controller, where technically feasible and when doing so does not adversely affect the rights and freedoms of others.
• In order to assert the right to data portability, You may at any time contact MPOWER by sending an email to privacy@mpowerfinancing.com.
• Right to object
• You have the right to object, on grounds relating to his or her particular situation, at any time, to our processing of your personal data, which is based on point (e) or (f) of Article 6(1) of the GDPR. This also applies to profiling based on these provisions.
• Following our receipt of your written objection, we shall no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing which either override your interests, rights, and freedoms, or for the establishment, exercise or defense of our legal claims.
• If we process your personal data for direct marketing purposes, you have the right to object at any time to our processing of your personal data for such marketing. This applies to profiling to the extent that it is related to such direct marketing. In addition, you have the right (on grounds relating to his or her particular situation) to object to our processing of your personal data for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
• In order to exercise the right to object, you may contact MPOWER by sending an email to privacy@mpowerfinancing.com.
• Automated individual decision-making, including profiling
• We do not use automatic decision-making or profiling. However, in offering insurance products that vary in their eligibility based on country of residence, travel destination and age, our insurance partners will make automated decisions as to your eligibility for their products. When they make an automated decision about you, you have the right to contest the decision, express your point of view, and to require a human review of the decision. Contact the appropriate insurance partner directly for additional information.
• Right to withdraw data protection consent
• You have the right to withdraw your consent to processing your personal data at any time. If you wish to exercise this right to withdraw the consent, you must contact MPOWER by sending an email to privacy@mpowerfinancing.com.

14. Legal basis

To the extent applicable to EU residents, Art. 6(1) lit. a GDPR serves as the legal basis for processing operations for which we obtain consent for a specific processing purpose. If the processing of your personal data is necessary for the performance of a contract, as is the case, for example, when processing operations are necessary to provide you with a service, the processing is based on Article 6(1) lit. b GDPR. The same applies to such processing operations which are necessary for carrying out pre-contractual measures, for example in the case of inquiries concerning our products or services. If we are subject to a legal obligation by which the processing of your personal data is required, such as for the fulfillment of tax obligations, the processing is based on Art. 6(1) lit. c GDPR. In rare cases, the processing of your personal data may be necessary to protect your interests or those of another person. This would be the case, for example, if a visitor were injured in our company and their name, age, health insurance data or other vital information would have to be passed on to a doctor, hospital or other third party. In these cases, the processing would be based on Art. 6(1) lit. d GDPR. Finally, processing operations could be based on Article 6(1) lit. f GDPR. This legal basis is used for processing operations which are not covered by any of the abovementioned legal grounds, if processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by your interests or fundamental rights and freedoms of yours which require protection of your personal data. We consider that a legitimate interest could be assumed if you are a client of ours (Recital 47 Sentence 2 GDPR).

15. The legitimate interests

Where the processing of personal data is based on Article 6(1) lit. f GDPR our legitimate interest is to carry out our business in favor of the well-being of all our employees and the shareholders.

16. Period for which the personal data will be stored

The criteria used to determine the period of storage of your personal data is the respective statutory retention period designated by applicable law. After expiration of that period, the corresponding data is routinely deleted, as long as it is no longer necessary for the fulfillment of the contract or the initiation of a contract.

17. Changes to this Policy

We may need to modify this privacy policy from time to time to reflect our current privacy practices, so please check back to view any changes. When you register or submit your email address on any of the Sites, you acknowledge receipt of this privacy policy and agree to receive future notices about it online. We make this policy continuously available online. We will inform you of material modifications to this policy in the future by posting changes on the Sites and/or sending you an email notification where appropriate.

18. Data Privacy and Protection Provisions From Web Service Companies Like Google and Facebook

At our discretion and election, we may use generally-available third party services on our Sites, like Google Analytics, AdSense, AdWords, and Google Remarketing. We may also include links or code that integrates with Facebook, Instagram, LinkedIn, and other social media platforms, as well as other web services companies like SalesForce, MailChimp, and others. Each of these third parties has its own data protection and privacy provisions, and detailed descriptions of each third-party, the service they provide, and links to their data privacy and protection provisions are available on this page.