Last Updated: November 20, 2020
What type of information does Frank collect?
Over the past 12 months, we may have collected information from or about you including the following information:
- Contact information, such as name, alias, e-mail address, postal address, phone number and mobile number.
- Identifiers, such as your date of birth, phone number, mobile number, postal address, IP address or other unique online identifier, username, password, driver’s license number, state ID number, and Social Security Number.
- Financial Information, such as the information required by federal FAFSA® forms, which can include you or your parents’ income and total debts as well as bank account information and information contained on your federal tax returns. We do not collect any payment card information about you; we use third party service providers for that purpose.
- Commercial Information, such as a record of which of our Services you have purchased.
- Location Data, but not your precise geolocation. We collect location information provided by a mobile or other device interacting with the Site, or associated with your IP address or other online or device identifier.
- Professional or employment-related information, such as your past or present employment status.
- Sensitive Information related to your race, gender, marital status, or veteran/military status.
- User Profiles, we may aggregate the information that we collect about you or that your we collect from other sources in order to provide you with information on the Site, deliver Services, and secure our Site against fraud. We may share these profiles with certain third parties as described below.
Your Choice to Provide Information: You may choose not to provide personal information to Frank by refraining from, among other things, using the Site and our Services. You also may refrain from submitting information directly to us. However, if you do not provide personal information when requested, we may not be able to provide you with the full range of our Services, or with information about our Services, promotions, and other opportunities.
How does Frank use your personal information?
We may use the personal information we collect about you for a number of business purposes, including the following:
- Provide the information and Services requested.
- Determine your eligibility for our Services and process applications for products and Services.
- Send you communications in connection with the Services.
- Respond to customer service inquiries.
- Develop new Services.
- Operate, analyze, and maintain the Site.
- Manage our everyday business needs, such as administering and improving the Site and our Services.
- Prevent fraud, enforce our Terms of Service, comply with applicable laws and Frank’s reporting obligations, secure your account, and enforce our agreements.
- Market products and Services that may be of interest to you if further legal requirements for this are fulfilled.
With your consent, we may also use your personal information for additional purposes.
When and to whom Frank discloses your information
In the past 12 months, your information may have been disclosed or shared with the following categories of third parties for a variety of business purposes:
- With our service providers: We may share your information, including your financial information, with third-party service providers and vendors who perform services on our behalf but only if (a) the sharing of your personal information is necessary for them to carry out such support services and (b) those service providers are required to use any personal information they receive in accordance with our instructions and pursuant to a data processing agreement that complies with the requirements of applicable data privacy law.
- With our business partners and with your express consent: As part of our business operations, we may share your information with our business partners who may market or provide you with their products and services, but only when you provide your express consent for the disclosure to one or more particular business partners. For example, with your express consent, we may share your name, phone number, e-mail, zip code, school, degree preferences, and other information with our business partners for the purposes of marketing their educational products and services to you. If you would like to opt-out of this use of your personal information, you can do so by sending an email to firstname.lastname@example.org or by calling 347-690-7886.
- With third party technology providers: As described below in the Cookies and Automatic Data Collection part of this policy, we partner with certain third parties that provide cookies or similar tracking technologies used on our Site. These third parties may collect information about you, and we may share information about you with these third parties. You can disable cookies on your browser or mobile device at any time. However, if you do so, you may not be able to receive the full functionality of our Site or Services.
- In the event of corporate change: We may disclose personal information to a successor to all or part of our business or in connection with a corporate merger; consolidation or restructuring; sale of substantially all of our stock and/or assets; or other corporate change, including, without limitation, during the course of any due diligence process. If necessary and legally required, we will obtain your separate consent in this regard.
- To comply with legal requirements: We will disclose your information (i) if we are required to do so by law or legal process, (ii) in response to lawful law enforcement authority or other government official requests, (iii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, (iv) in connection with an investigation of suspected or actual illegal activity including any legal proceedings or prospective legal proceedings in order to establish, exercise, or defend our or a third party’s legal rights, or (v) as required for internal audits or to investigate a complaint or security threat.
The personal information that may have been shared in the past 12 months for these business purposes includes the categories of personal information listed in the What type of information does Frank collect section above.
How does Frank protect your personal information?
We have implemented security measures to protect against the loss, misuse, and alteration of the information under our control. Please be advised, however, that the security and confidentiality of any communication or information cannot be and is not guaranteed.
Cookies and Automatic Data Collection
We may use our own cookies to authenticate your access to our Site.
Additionally, our Site and Services may use third-party cookies of the following kinds to:
Assist in our marketing and targeted advertising to you. The information generated or collected by these cookies about your use of our Site (including your IP address) will be used for purposes that include collecting data based on user actions; engaging with a user that has previously visited our Site; targeting specific advertising offers in specific pages and retargeting in downstream tools such as Google Adwords; testing advertisement efficiency across websites; and delivering advertisement products. Some of these cookies may automatically expire after a period of time. Third party cookies used for this purpose may include cookies from, for example, Google (including Analytics, Tag Manager, and Ads), Microsoft Bing, Facebook, Snap, Taboola, Braze, Iterable, and OptinMonster.
Assist in our Site analytics, tracking, and optimization. The information generated by these cookies about your use of our Site (including your IP address) will be used for purposes that include analyzing Site traffic and seeing how users reached and used our Site; distinguishing unique users and calculating visitors; identifying users in subsequent visits to the same site; tracking and recording users’ actions on certain screens; integrating and collecting form information on financial aid applications that we facilitate; sending events that will trigger transactional and marketing emails; throttling request rates; optimizing performance based on anonymized user findings; and checking that the Site experience is consistent with functionality experiments. Some of these cookies may automatically expire after a period of time. Third party cookies used for this purpose may include, for example, cookies from Google (including Analytics, Tag Manager, and Ads), Microsoft Bing, Facebook, Snap, Taboola, Braze, Iterable, mParticle, Mixpanel, HotJar, VWO, Taboola, and Gravity Forms.
Assist in our user support. The information generated by these cookies about your use of our Site (including your IP address) will be used for purposes that include communicating with users via live chat; saving a chat ID to recognize devices between visits during a chat session; holding session information; and registering whether a self-service answer bot has been displayed to the user. Third party cookies used for this purpose may include, for example, cookies from Zendesk.
You can use the methods described below to manage cookies. You must take these steps on each browser or device that you use. If you replace, change, or upgrade your browser or device, or delete your cookies, you may need to use these opt-out tools again.
If the browser you use is not listed above, please refer to your browser’s help menu for information on how to manage cookies.
Third Party Websites
Accessing, Deleting, and Managing Your Data
Online users of the Site and Services can email email@example.com or call 347-690-7886 and:
- Correct or amend personal information in your profile.
- Delete your personal information, unless we are required to retain that information for legal purposes, to prevent fraud, or enforce our Terms of Service.
Upon your request to terminate your account, we will deactivate or delete your account. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Service, or comply with legal requirements.
How can I opt-out of receiving marketing?
Email: You can unsubscribe at any time by following the instructions included at the bottom of the communication you receive. In addition, you may communicate your choice to opt out via an email to firstname.lastname@example.org or by calling 347-690-7886.
Phone: Unless permitted by applicable law, Frank will not call or text your phone number without first providing notice or obtaining your consent as required by the laws applicable to your jurisdiction. If you previously chose to receive notifications on your mobile device or on your phone, but no longer wish to receive them, you can opt-out and manage your preferences either through your mobile device.
Notice to Residents of Nevada
Notice to Residents of California
California Civil Code Section 1798.83 permits California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing by sending an email to email@example.com or by calling 347-690-7886.
Personal Information of Minors
This Site is not intended for use by minors, and we do not knowingly solicit or collect personally identifiable information from individuals under the age of 13. We request that individuals under the age of 13 not provide personal information to us. If we obtain actual knowledge that we have collected information from someone under the age of 13, we will promptly delete that information.
Consent to Transfer and Processing of Data
Frank’s Services are intended for residents of the United States. However, if you are located outside of the United States, please be aware that information we collect through the Site and Services will be transferred to and processed in the United States. By using the Services, visiting our Site, or providing us with any information, you consent to the transfer, processing, and storage of your information in the United States.
Do Not Track
Some browsers have “do not track” features that allow you to tell a website not to track you. These features are not all uniform and we do not respond to those signals.
If you have any questions or privacy concerns, you can contact us at any time. Please email firstname.lastname@example.org or call 347-690-7886.