Graham Strategies, Inc. DBA The Financial Aid Shop
Graham Strategies values privacy of our guests and members. To help maintain your privacy and the security of your personal information, we communicate this and all of our privacy policies to Graham Strategies employees and agents, and we internally enforce privacy safeguards.
Our Collection and Use of Information
Graham Strategies may collect information in a number of ways from users who access our Site or services. We collect personal and non-personal information in various ways. You may provide your information to us to receive a product, service, or communication from us; we may request your information to better serve you; or we may require your information in order to be able complete a transaction (e.g. a purchase) or provide access (e.g. to a paid service).
Collection of Personal Information
Personal information We Collect
Examples of some types of personal information Graham Strategies may collect in connection with the Site and how we may use it include the following:
- When you purchase, register, or login to use, products, or services, request support, register for an event or webinar, live workshop, or training, provide feedback on a course or program or product, or participate in a promotion, contest or online survey, or respond to an advertisement, we may collect a variety of information, including your first and last name, mailing address, phone number, email address, company or organization.
- Graham Strategies does not directly collect credit card numbers in connection with The Financial Aid Shop or on the website provided in connection therewith. Payments for The Financial Aid Shop products/services are made through other means or third-party servicer (STRIPE) and thus we do not collect or store credit card numbers in connection with any of those products/services that this Policy applies to.
How we use your personal information
Optional Communications: The personal information we collect allows us to provide you with The Financial Aid Shop’s latest product announcements, helpful tips and information, special offers, and upcoming events. If you don’t want to receive these communications, or do not wish to be on our mailing list, you can opt out of receiving them. Each communication will provide opt-out directions, and you can also generally opt-out via your account profile if you are a registered customer. The information in connection with these optional communications and your responses help us to improve our products, services, content, and advertising.
We also use personal information to help us develop, deliver, improve, and customize our products, services, content, and advertising and to provide a better user experience for every user of our products, and services.
- We may also use personal information for internal purposes such as auditing, data analysis, and research to improve The Financial Aid Shops products, services, communications, support and/or help functions, and user interfaces.
- If you enter into a promotion such as a contest, a giveaway, a one-time or special offer, or similar promotion, we may use the information you provide to administer those programs.
- If we become involved in a legal process as a result of your actions on the Site, or in connection with any products, or services offered via the Site, we may be required to disclose your PII to a government authority, or a third party who e.g., issues a subpoena that require us to provide it. Our response(s) to any such legal process will be handled on a case-by-case basis following the advice of our attorneys.
Collection of Non-Personal Information
How we collect and use your non-personal information
We may collect, use, transfer, and disclose non-personal information for any purpose. The following are some examples of non-personal information that we collect and how we may use it:
- We may collect non-personal information (e.g. demographic information) regarding our customers collectively including information such as gender, preferred language, zip code, area code, geographic location, or the time zone from which customers access the Site, products, or services. Such non-personal information is used so that we can better understand who our customers are, and their behavior generally with regards the Site, and to improve our products, services, communications, support, help, user experiences, and advertising for our customers.
- We also may collect non-personal information regarding customer activities on the Site or use of Graham Strategies, products, and services. This information is aggregated and used to help us provide more useful information to our customers and to understand which parts of the Site, or products, and services are of most interest or which can be improved. Non-personal support or help request data may be used to improve our Site, communications, and user interfaces, or to allow us to provide additional product or service offerings to our present or future customers.
- We may collect non-personal information regarding the digital footprints of our customers with respect to accessing the Site, products, or services including mobile and non-mobile access, This information may be used to improve the Site, products, or services including but not limited to their performance, functionality, design, or responsiveness.
A. Cookies and Other Technologies
Graham Strategies also uses specific technologies in connection with certain communications such as emails that may be used to track actions by recipients. For example, these communications may include one or more clickable text or graphics that include URLs that link to content on the Site. However, these URLs, may pass through a web server that tracks the click before arriving at the linked content on the Site. The tracked data can help Graham Strategies determine the effectiveness of our communications to users and customers, or to gage interest in specific topics. If you prefer not to have your responses to such communications tracked in this manner, do not click links in the email messages. Such communications may also include pixel tags that can tell us whether e.g. an email has been opened. We may use this information to throttle the number of messages sent to users or customers, or to remove people who do not read or interact with our communications from one or more lists.
B. Log Files
As part of standard protocols, The Financial Aid Shop automatically gathers certain information and stores it in log files. This information may include date/time stamp of access, log-in details referring page, exit page, and other data.
C. Social Media
Graham Strategies may collect certain information from you if you interact with us via social media such as Facebook, Twitter, LinkedIn, Google+, Pinterest, Snapchat, Instagram, and other such services. For example, you may be given the option to register for webinars, take advantage of special offers, receive mailings, newsletters or the like, via your social media account. The information we receive or collect from such social media, and our ability to collect it, may depend on the social media site, its policies, and its requirements or its technology. We may collect the information you provide from these social media interactions and may use it for various purposes to improve our services or your experience, or to contact you regarding the reason you connected with us or with additional offers in the future. Of course, you have the opportunity to opt-out at any time provided we do not require a means of contacting you to fulfill your request.
Protecting children's privacy is important to Graham Strategies. It is our policy to comply with the Children's Online Privacy Protection Act of 1998 and all other applicable laws. Therefore we restrict our website use to persons sixteen years or older. Therefore, we do not knowingly collect personal information from children under 16. If we learn that Graham Strategies has inadvertently collected or received the personal information of a child under 16 we will take steps to delete the information.
You must be 16 or older to use the Site, and to purchase products, or services offered via the Site without an adult (parent or guardian).
The Financial Aid Shop nonetheless encourages parents to go online with their kids. Here are a few tips to help make a child’s online experience safer:
- Teach kids never to give personal information, unless supervised by a parent or responsible adult. Includes name, address, phone, school, etc.
- Know the Site your kids are visiting, and which Site are appropriate.
- Look for Website privacy policies. Know how your child’s information is treated.
- Check out the FTC’s site for more tips on protecting children's privacy online
If we discover or form a reasonable belief that we have received any information from a child under 16 in violation of this policy, we will delete that information. If you believe Graham Strategies has any information from a child under age 16, please contact us at the following address:
Mail: Graham Strategies, Inc. 1732 Aviation Blvd. Suite 410, Redondo Beach, CA 90278
Disclosures to Third Parties
Graham Strategies may make personal information available to strategic partners that work with us to provide products and services, or that help us serve our customers. Personal information will only be shared by Graham Strategies to provide or improve the Site, products, services, and advertising.
A. Service Providers
To provide its various products or services, Graham Strategies works with third party providers, who may be located wherever Graham Strategies operates, or in any other location. Such companies provide services to Graham Strategies, Inc. Examples may include information processing, emailing services, server hosting, transaction processing and banking services, video hosting, product/service delivery, communications, managing and enhancing customer data, providing technical support and/or customer service, and conducting customer research or satisfaction surveys. At any given time, Graham Strategies may work with one or more such provider. We will only provide personal information to these companies where required for them to provide their services, or to improve our products or services for our customers. These companies are contractually obligated to protect your information.
Graham Strategies will not share PII with third parties for their marketing purposes. In some cases, Graham Strategies may be required by legal process to disclose your personal information. Such disclosure may be compelled by applicable law, regulation, judicial order, and/or lawful requests from local authorities. Graham Strategies may also disclose information about you if we determine, in our sole discretion, that disclosure is necessary or appropriate to ensure the safety of any individual(s), or for purposes of national security, law enforcement, or other issues of public importance.
If the Site and/or products, or services, or Graham Strategies, Inc. becomes the subject of a reorganization under the bankruptcy law, a merger, a sale, or other change in control, any and all personal information in Graham Strategies, Inc. control will be transferred to the trustee, debtor in possession, successor, acquirer, or such other third party as will control Graham Strategies, Inc., the Site, and/or products, or services thereafter.
We reserve the right to disclose personal information if we reasonably believe that disclosure is necessary to protect our users, customers, or the public, prevent fraud or financial wrongdoing, or in any action to enforce our Terms and Conditions, or other policies regarding Graham Strategies, Inc.
Personal Information Protection
Graham Strategies uses commercially reasonable security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data. We restrict access of personal information to our employees, contractors, and/or agents who need to know that information in order to process it on our behalf. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations. Graham Strategies and its third-party providers use Secure Sockets Layer (SSL) encryption on all web pages where personal information, including financial information is transmitted.
You are solely responsible for any personal information you choose to submit on a non-secure Site including but not limited any discussion forums or public comment threads on the Site, or any social media Site, groups, or threads related to the Site or related, products, or services.
Access to Your Personal Information
Graham Strategies customers should periodically log in to review your name, contact information and other readily available personal information, and to ensure they are accurate, complete, and up to date. You can make changes to your information. Changes to your personal details and particulars should be made through your membership, where applicable.
You can request access to any personal information we have for you. We will make a good faith effort to provide you with access to reasonably accessible information. You can request that we correct the data if it is inaccurate or delete your personal data. Graham Strategies will comply with such requests if they are reasonable and we will delete your data if Graham Strategies is not required to retain it by law, and does not require it for legitimate business purposes. We may reserve the right to refuse deletion requests that we believe require undue time, or technical effort, or where not provided by local law. We also reserve the right to deny or delay requests where the personal information is scheduled to be deleted as part of any upcoming purge of data that is not being retained.
Requests for access, correction, or deletion can be submitted to firstname.lastname@example.org
Links to Third-Party Site
Notice of Compliance to California Residents
Your California Privacy Rights Under The California Online Privacy Protection Act and the California Business and Professions Code
Graham Strategies does not maintain an online process for an individual consumer who uses or visits our commercial website or online service to review and request changes to any of his or her personally identifiable information that is collected through our website or online service.
For the purposes of this policy and California compliance the following definitions apply:
Depending on your activity on our website or online service, the following "personally identifiable information" may be collected, in addition to what is in prior sections of this document.
The term "personally identifiable information" means individually identifiable information about an individual consumer collected online via the Site from an individual and maintained by us in an accessible form and may include any of the following:
- A first and last name;
- A home or other physical address, including street name and name of a city or town;
- An e-mail address;
- A telephone number;
- Any other identifier that permits the physical or online contacting of a specific individual; and
Under California Law SB 27, California residents have the right to receive, once a year, information about third parties with whom we have shared information about you or your family for their marketing purposes during the previous calendar year, and a description of the categories of personal information shared. To make such a request, please send an email to email@example.com and please include the phrase "California Privacy Request" in the subject line, The Financial Aid Shop along with your name, address and e-mail address. We will respond to you within thirty (30) days of receiving such a request.
"Cookies" and How We Use Them
Some of our Web pages may contain electronic images known as Pixels, which are also called single-pixel gifs. These images allow us to count users who have visited those pages and to deliver co-branded services. Pixels are not used to access your personally identifiable information but they are a technique we use to compile aggregated statistics about our website usage. Pixels collect only a limited set of information including a cookie number, time and date of a page view, and a description of the page on which the Pixel resides. Some of our Web pages may contain pixels placed there to help us determine the effectiveness of our advertising campaigns.
Public Areas & Social Media
Any information you disclose in any public areas of our website or the Internet, including via social media becomes public information. You should exercise caution when deciding to disclose personal information in these public areas.
Discussions and Community Tools; Testimonials You agree that any information you submit to us through The Financial Aid Shop may be used for promotional purposes. Because of the public nature of some of our services, you should exercise caution when deciding to disclose any personal information. We may also use a limited amount of information, such as first name, last name and your town and state in marketing materials on the website. Your registration constitutes consent to this use.
International Users If you are visiting The Financial Aid Shop from a location outside of the United States, your connection will be through and to servers located in the United States, and all information you provide will be processed and securely maintained by our third party servers and internal systems located within the United States. By using The Financial Aid Shop website, courses or programs, you authorize and specifically consent to the transfer of your personal information to the USA and its storage and use as specified above when you provide such information to us.
Mail: Graham Strategies, Inc. 1732 Aviation Blvd. Suite 410, Redondo Beach, CA 90278
Last Updated: April 30, 2020