Graham Strategies, Inc. DBA The Financial Aid Shop

This Privacy Policy (“Privacy Policy) applies to the website related to The Financial Aid Shop provided by Graham Strategies, Inc. (“Graham Strategies”  or “We”), including but not limited to thefinancialaidshop.com, as well as to any services, and/or products offered on such website (hereafter the “Site”).

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.

 

This Privacy Policy has been developed to explain how we collect, use, disclose, transfer, and store information received from you in connection with the Site. Before disclosing information to us, please familiarize yourself with our privacy practices so you can understand how your information may be used by Graham Strategies.

 

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 (or “Personally Identifiable Information” or “PII”) is information and data that can be used to specifically identify or contact a single person. You may be asked to provide your personal information when you contact Graham Strategies for any reason. Graham Strategies may share your personal information internally. If we do, we will use it in accordance with this Privacy Policy. We may also combine personal information with other information to help us to develop or improve our products, services, content, communications, and/or advertising, or to provide improved user experiences.

 

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.

• Important Communications: We may use your personal information to send important communications, e.g., about your purchases of or access to software, products, or services, material changes to terms, conditions, and policies (including this Privacy Policy), critical updates to products, or services, or changes (including regulatory changes) that impact your use of Graham Strategies programs, products, or services. Because this information is vital to your interaction with Graham Strategies Inc., you may NOT opt out of receiving these communications if you wish to continue to use the Site, products, or services offered in connection with the Site.
• 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

Information of a type or in a form that does not permit direct identification of or association with any specific individual is ‘non-personal information.’ Combinations of personal and non-personal information are considered personal information if the combined information can be used to identify or contact any specific individual(s). Aggregated data is considered non-personal information for the purposes of this Privacy Policy as long as it cannot be used to identify or contact any specific individual. Internet Protocol (IP) addresses and certain other identifiers may be considered personal information under various local laws; we endeavor to comply with the laws and regulations that are applicable to us.

 

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

To help Graham Strategies serve you better, we use technological means to better understand and adapt to user behavior. To accomplish this, the Site, as well as our online software and services, email messages, and advertisements may use cookies or related technology such as pixel tags, clear gifs, and web beacons. These technologies help us to know which parts of the Site people have visited and provide data to aid us in understanding the effectiveness of the software services, our advertisements, and web searches. These data are used to improve our software, products, services, communications, and advertisements. We generally consider such information collected through the use of cookies and other technologies as non-personal information and treat it accordingly.

 

We also use cookies and other technologies to remember personal information when you use the Site, software, products, or services. These uses are intended to improve your personal experience. For example, we can provide better and more personal results if we ‘remember’ your preferred settings, your name, and such.

 

Graham Strategies may use cookies or other technologies in connection with certain advertising services to determine your experience with our content including whether an ad is likely to be of interest to you, whether or not you are served a particular ad, and the number of times you are served a particular ad. These technologies allow us to measure the effectiveness of our ad campaigns. You may have options for opting out of such targeted ads. You should contact your service provider or your mobile provider to inquire about how to do so.

 

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.

 

We also use cookies to track certain behaviors of unknown visitors on our site. For example, if you visit our site by following a link in an email from a third party or in an advertisement from such a party, we may track that behavior. In such cases, we may not have any personally identifying information about you at that time; however, if you later sign up for a product or service, or make a purchase, we may be able to associate your past behaviors on our Site with you thereafter.  Cookies and other technologies can generally be controlled on your devices. If you want to disable cookies and you should review your privacy or security settings. Please note that certain features of the Site or related software, products, or services may not be available if you have cookies disabled on your device.

 

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.

 

These log files are useful for a number of purposes including helping Graham Strategies to maintain security, measure relative usage, understand and analyze trends regarding users, server access, load, or server problems, more effectively and efficiently administer the Site, products, services, or communications, and gather non-personal demographic information about our users. Consistent with the provisions of this Privacy Policy, Graham Strategies may use the data in its Log Files in a variety way useful to its business or to provide better experiences for its users and customers.

 

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.

 

D. Children

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

Email: catherine@thefinancialaidshop.com

 

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.

 

B. Others

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 catherine@thefinancialaidshop.com

 

Links to Third-Party Site

The Site, products, services, and communications may contain links to third-party website, products, or services. Information collected by third parties is governed by their privacy practices, not this Privacy Policy. Please be aware when you leave the Site and understand that you are subject to a third party’s privacy policy except when you are on the Site, or using Graham Strategies Inc., products, or services.

  

Changes to this Privacy Policy and Privacy Questions

If you have any questions or concerns about this Privacy Policy please email us at catherine@thefinancialaidshop.com. This Privacy Policy is subject to change from time to time at Graham Strategies, Inc. sole discretion.

 

Please check this page periodically for changes. Any such changes to the Privacy Policy will be available on this page. If the policy has been changed in a material way, a notice will be posted on our website along with a link to the updated Privacy Policy. Your continued use of our site following the posting of changes to these terms will mean you accept the changes. Information collected prior to the time any change is posted will be used according to the rules and laws that applied at the time the information was collected.

 

Notice of Compliance to California Residents

Your California Privacy Rights Under The California Online Privacy Protection Act and the California Business and Professions Code

 

This privacy policy identifies the categories of personally identifiable information that our company collects through our website or online services about individual consumers who use or visit Graham Strategies’ commercial website or online services in connection with The Financial Aid Shop and thefinancialaidshop.com (collectively “the Site”) and the categories of third-party persons or entities with whom our company may share that personally identifiable information.

 

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.

 

See the section above titled "Changes To This Privacy Policy" for a description of the process by which our company notifies consumers who use or visit our commercial website or online service of material changes to our company's privacy policy for this website or online service.

 

The effective date of this Privacy Policy is listed at the end of this privacy policy under the heading, "Last Updated."

 

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:

1. A first and last name;
2. A home or other physical address, including street name and name of a city or town;
3. An e-mail address;
4. A telephone number;
5. Any other identifier that permits the physical or online contacting of a specific individual; and
6. Information concerning a user that the Site collect online, from the user, and which is maintained in personally identifiable form, in combination with an identifier described within this Privacy Policy.

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 catherine@thefinancialaidshop.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

A "cookie" is a small data file that can be placed on your hard drive when you visit certain website. The Site may use cookies to collect, store, and sometimes track information for purposes stated earlier as well as for statistical purposes to improve the products and services we provide and to manage our telecommunications networks. We may also use cookies for purposes of personalizing your experience on the Site, or for providing online behavioral advertising such a retargeting or remarketing. These uses provide you with additional opportunities to take advantage of our services or products  and provide us with additional opportunities to reach you with personalized offers more tailored to your interests. Advertisers and partners may also use their own cookies (e.g. on their own Site). Graham Strategies does not control any third party’s use of such cookies and we expressly disclaim responsibility for information collected by or through them.

 

Pixels

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.

This Privacy Policy does not create any contractual or other legal rights in or on behalf of Graham Strategies or any other party and is not intended to create any such rights.

 

Questions about this Privacy Policy may be directed to us in writing at:

 

Mail: Graham Strategies, Inc. 1732 Aviation Blvd. Suite 410, Redondo Beach, CA 90278

Email:catherine@thefinancialaidshop.com

 

Last Updated:  April 30, 2020