Catholic Virtual™ and its affiliates (collectively, "CV"), respects your privacy and has established this privacy policy ("Privacy Policy") to let you know how we collect, use, manage, share, and protect information that we may gather when you visit our website, the websites of our affiliated schools, or the websites for our student and education management systems (collectively, the "CV Sites"), or contact us by phone or other means. This Privacy Policy applies to the CV Sites where this Privacy Policy is posted and to information we gather from you over the phone, via conventional mail or in person. This Privacy Policy has also been compiled to better serve those who are concerned with how their "Personally Identifiable Information" ("PII") is being used online. PII, as described in US privacy law and information security, is information that can be used on its own or with other information to identify, contact, or locate a single person, or to identify an individual in context. Please read our privacy policy carefully to get a clear understanding of how we collect, use, protect or otherwise handle your Personally Identifiable Information in accordance with our Website.

CV reserves the right to change this Privacy Policy at any time. If we make any material changes to this Privacy Policy, we will post any revised Privacy Policy on the CV Sites. The most current version is always available by clicking on the "Privacy Policy" link located at the bottom of the CV Sites home page. Any changes to our Privacy Policy will become effective upon posting of the revised Privacy Policy. BY USING ANY OF THE CATHOLIC VIRTUAL SITES, YOU AGREE TO THE TERMS OF THE PRIVACY POLICY IN EFFECT AT THE TIME OF USE. IF YOU DO NOT AGREE TO THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY, PLEASE DO NOT USE ANY OF THE CATHOLIC VIRTUAL SITES.

The Family Educational Rights and Privacy Act is a U.S. Federal law that protects the privacy of student educational records. Briefly, FERPA guarantees that students have the right to inspect and review their records, the right to request amendments, through informal and formal hearings, to their record if they believe the information is incorrect, misleading or in violation of their privacy rights and the right to have some control over the release of PII from their educational records. Students also have the right to file complaints with the Family Educational Rights and Privacy Act Office concerning alleged failures by the institution to comply with the Act.

Student's education records will be protected by CV as required by FERPA and applicable state laws regarding the privacy of student records or PII. We will only disclose education records or provide access to them in compliance with FERPA and applicable state laws, and we will require third parties that contract with us and have access to education records to do the same. CV will not use PII to target a student for advertising, sell PII or use PII to create profiles about a student (other than for purposes of the student’s education in a CV course or program) when those activities are prohibited by law. CV will not use, or will seek permission to use, a student’s PII for purposes unrelated to providing or improving their education where required by law to do so. If any provision of this Privacy Policy conflicts with FERPA or other federal or state law, CV will comply with the more protective standard for the education records.

Under FERPA, schools may disclose directory information contained in an educational record that would not be considered harmful or an invasion of privacy if released. Directory information at CV includes, but is not limited to:

• Name
• Address (City and State of Residence Only)
• Courses and programs
• Dates of attendance

CV requires written permission from the eligible student, parent or legal guardian to release any other information from a student's education record, except under very limited conditions. FERPA allows CV to disclose those records, without consent, to the following parties or under the following conditions (34 CFR S 99.31):

• School officials with legitimate educational interest
• Other schools to which a student is transferring
• Specified officials for audit or evaluation purposes
• Accrediting organizations
• To comply with a judicial order or lawfully issued subpoena
• Appropriate officials in cases of health and safety emergencies

The following persons have access to student records: (i) CV’s CEO, administrative team, and professional staff; (ii) the appropriate administrative support staff members and other professionals who have a legitimate educational or legal interest in student records as designated by the CEO; (iii) educational institutions, organizations or home based education programs with access to the student’s educational records; or (iv) an agent representative of the student or family.

All CV students are provided a unique password to access online courses. It is the student’s responsibility to keep his/her password in confidence.

CV (or the educational institution, organization or homebased education program with access to the student’s educational records) provides an academic transcript upon the request of the student, parent or legal guardian.

Some schools assign a site facilitator to coordinate online programs, blended learning, or after school and/or supplemental programs, which may be provided to help students who use school labs to access CV courses. Facilitators will have access to students’ online work. Facilitators may have access to students’ demographics.

You can use portions of the CV Sites without divulging any PII. Our site does not collect personal information about students, parents or legal guardians except when such students, parents or legal guardians specifically provide such information on a voluntary basis (for example, when enrolling for a CV course or program; requesting additional information by contacting us; signing up for a CV in-person event; posting a message to a message board; requesting help; engaging in an online chat; or accessing, adding to, or changing the information on your account information page on the Student Information System ("SIS").

When a student is registered for a CV course or program, we are provided with information regarding the student, parent and/or legal guardian. This personal information may be collected on the CV Sites, or via telephone, facsimile or conventional mail. The types of information that you may be asked to provide include, but are not limited to first and last name; postal address; telephone number; the student’s names and age; student registration and enrollment information; and an e-mail address where we can contact the student, parent and/or legal guardian. If the student is enrolling in one of CV's courses or programs, we may also collect debit or credit card information.

Registration and enrollment information that is provided by the student, parent and/or legal guardian may be provided to third parties as required by state or federal law. To the extent that third party vendors assist CV in the provision of online products or services, those vendors are provided the minimum amount of data required to perform the tasks for which they have been engaged, consistent with legal requirements, such as FERPA. They have no independent rights to such data and have agreed to maintain the confidentiality of the data, to use it solely for the purpose of performing the school-based tasks for which they have been engaged and to safeguard the data as required by law and by contract.

Only if permitted by applicable state and federal law, CV may share PII your information with other companies in order to improve the academic performance of CV courses or programs or so that CV may offer products and services to you. You can request that your personal information not be shared with third parties by making a request in writing to CV Support.

CV may use the PII to provide educational services to the student enrolled in a course or program, and to otherwise support the student with regard to matters such as testing, academic progress, attendance, customer service, student affairs or for health or safety purposes. The PII is also used to deliver services to the student or to carry out activities that the student has requested. CV may also use PII to protect its own legal rights.

CV will use or share PII if required to do so by law, such as a court order, or permitted to do so for law enforcement, health or safety purposes or to protect CV’s legal rights. If permitted by applicable state and federal law, CV may aggregate PII to improve the educational experience for the student.,

We understand that children who are under age 13 need enhanced safeguards and privacy protection, as set forth in the Children’s Online Privacy Protection Act ("COPPA"). COPPA protects the information privacy of children under the age of 13 by requiring web site operators and online services to post privacy policies and obtain verifiable parental consent before collecting information from those children.

The CV Sites are not intended to solicit information of any kind from children under age 13, and we do not and will not knowingly contact or collect personally identifiable information from children under 13. The only personal information we receive about children under the age of 13 is information provided by the parent or legal guardian or information provided by the child as part of that child’s participation in a course as part of that child’s education program. By enrolling a child in such course, a parent or legal guardian consents to the collection of that Information.

It is possible that by fraud or deception by others we may receive information pertaining to children under age 13. If we are notified of the receipt of information under such circumstances, once verified, we will promptly obtain parental or legal guardian consent, and in the absence of such consent, will delete the information. If you want to notify us that we have inadvertently received information for a child under the age of 13, please do so by emailing us at CV Support.

To reduce the risk of unauthorized access, maintain data accuracy, and ensure the correct use of information, we have put in place commercially reasonable physical, electronic, and managerial procedures to safeguard and secure the information we collect. We also use Secure Sockets Layer ("SSL") protocol on the student account information and registration pages to protect sensitive personal information. As effective as our safeguards are, no security system for data is completely impenetrable. Therefore, CV cannot guarantee that the PII supplied by the student, parent or legal guardian will not be intercepted by others.

Student information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the information confidential. All transactions are processed through a gateway provider and are not stored or processed on our servers. Our website is scanned on a regular basis for security holes and known vulnerabilities in order to make your visit to our site as safe as possible.

The Fair Information Practices Principles form the backbone of privacy law in the United States and the concepts they include have played a significant role in the development of data protection laws around the globe. Understanding the Fair Information Practice Principles and how they should be implemented is critical to comply with the various privacy laws that protect personal information. In order to be in compliance with the Fair Information Practices, in the event of a data breach, we will notify the student, parent and/or legal guardian via email within seven business days.

The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations. We collect the student, parent and/or legal guardian’s email address in order to send information, respond to inquiries, and/or other requests or questions. In compliance with the CAN-SPAM Act, we will:

• Not use false or misleading subjects or email addresses.
• Identify the message as an advertisement in some reasonable way.
• Include the physical address of our business or site headquarters.
• Monitor third-party email marketing services for compliance, if one is used.
• Honor opt-out/unsubscribe requests quickly.
• Allow users to unsubscribe by using the link at the bottom of each email.

If at any time you would like to unsubscribe from receiving future emails from CV, please email us at CV Support and we will promptly remove the student, parent and/or legal guardian from future correspondence.