CommonTime Pathways Inc. Privacy Policy

Date of Last Update: January 2025

1. Notice

This Privacy Policy applies to properties owned and operated by CommonTime Pathways Inc (“CTPathways”, “We”, “Us”, “Our”), which include www.ctpathways.com, www.commontimepathways.com, (“Web Site”) and our mobile app (the “App”) (collectively, “Properties”). This Privacy Policy (“Policy”) describes how CTPathways collects and uses the personal information you provide through our Properties. It also describes the choices available to you regarding our use of personal information about you and how you can access and update this information.

Please read this Policy carefully before providing us with any information. When you visit or use our Properties, interact with customer service representatives, work with us, apply to work with us, or otherwise engage or interact with CTPathways or its employees, contractors, agents, or representatives, you understand that we will collect, use, and disclose your personal information as described in this Policy.

Please note that CTPathways is a corporation based in the U.S. Any personal information you provide or we collect is transmitted to, and stored in, the U.S., and will also be shared with our member Colleges and Universities, at your direction, including in countries where laws may be less protective of personal information about you than in your home country.

2. This policy will inform you about:

Changes to this Policy
Personal information CTPathways collects and how we use it
With whom CTPathways shares the information we collect about you
Your choices regarding communications from CTPathways and Member Colleges and Universities
CTPathways’s Data Retention Policy
CTPathways’s Data Security Policies and Practices
Children’s Privacy
How you can contact us regarding this policy

3. Changes to this Policy

Changes to this Policy will be posted on this page. We reserve the right to modify this Policy at any time, so please review it periodically to learn of updates. If you do not accept this Policy, please do not use our Properties.

4. Personal Information CTPathways Collects and How We Use It

A. Properties Visitors

Categories of personal information:

When you contact us through our contact form on our Properties or by email: we collect your name, email address and any other information that you decide to share with us.
With your permission where it is required by applicable laws, we and/or our partners may automatically log information about you, your browser, your computer or mobile device, and your activity on the Properties. The information that may be collected automatically includes your computer or mobile device operating system type and version number, manufacturer and model, device identifier (such as the Google Advertising ID or Apple ID for Advertising), browser type, screen resolution, IP address, the website you visited before browsing to our Properties, general location information such as city, state or geographic area; and information about your use of and actions on the Properties, such as pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and length of access. Our business partners may collect this type of information over time and across third-party websites and mobile applications. This information is collected using cookies, and similar tracking technologies. Please consult our Cookie Notice for more information.
The Properties include social media features, such as links to our Facebook, Twitter, LinkedIn, YouTube, Instagram pages. When you visit or interact with our pages on social media platforms you are agreeing to the platform provider’s privacy policy. This may include sharing with us your name, profile, photos, reactions and comments to our posts, etc. The platform provider’s privacy policy applies to your interactions and their collection, use and processing of your personal information. You or the platforms may provide us with information through the platform, and we will treat such information in accordance with this Privacy Policy.
The Google API Service is used to provide a student access to their Google Drive files, if they choose to use the integrated service. No data about the user’s Google account is stored or shared by the CTPathways.

Purposes for processing:
We use this information:

To provide, operate and improve our Properties
To respond to your requests, questions and feedback
To analyze and improve our Properties
To provide you with a personalized experience and advertisements
For compliance, fraud prevention, and safety.

B. Applicants

Categories of personal information:

When you create an account, we collect your name, email address, phone number, date of birth, and information regarding your plans to attend college. If you are a transfer student, we also collect information regarding your citizenship/nationality.
When you create a profile, we may collect your name, home and mailing addresses, home and telephone numbers, gender, legal sex, pronouns, military status, race, language proficiency, place of birth, duration of residency in the U.S./other country of residency, citizenship status, and financial status.
When completing an application(s), CTPathways collects detailed information regarding your education, testing, extracurricular and/or community involvement history, and college goals/plan. We also collect any and all information you voluntarily provide in your application(s), including writing samples and essays.
CTPathways may also collect personal information about you from recommenders and educational institutions you have attended, including information about your academic achievements and performance, recommendations and impressions of you, and any other information these parties choose to provide us in connection with your application(s).

Purposes for processing:
We use this information:

To process your application(s) to our member Colleges and Universities that require the information to assess your suitability for admission, communicate with you about your application, and meet institutional reporting requirements and obligations to safeguard students. If you do not provide the information our members require, we will be unable to process your application.
To allow you to pay fees required for your application to our member Colleges or Universities, by linking you to a PCI compliant credit card processor.
To validate the mailing address that you provide to further our legitimate interests in obtaining accurate information and preventing misuse of the CTPathways and our Properties.
To allow our members to meet their institutional reporting requirements regarding certain protected characteristics including gender, race, ethnicity, sexual orientation.
To generate aggregate data for research and product development purposes.
To allow you to participate in CTPathways Programs, such as direct admissions.
To allow you to participate in Partner Programs, with your consent, which requires sharing your information with those Partners. CTPathways will never share your data with Partners without your express consent.
To communicate with you. Applicants may opt-out of programs or request their data be deleted by submitting a request to CTPathways. To learn more, see the “What is CTPathways’s policy on retention and allowing you to access, update, correct, or delete your personal information?“ section of this Policy.

C. Parents/Guardians and Siblings of Applicants

Categories of personal information: If you are a parent or legal guardian of an applicant, we may collect personal information about you from the applicant: name, marital status, household member information, children, whether the parent is living or dead, occupation, and education level. CTPathways also collects the number of siblings an applicant has.
Purposes for processing: To allow us to communicate with parents or legal guardians of minors so we and our member Colleges and Universities can get evidence of parent or guardian permission to collect the minor applicant’s personal information.

D. College/University Administrators

Categories of personal information: If you are an administrator at one of our member Colleges or Universities who uses CTPathways to receive student recruitment or admission application data, we collect your name and email address to permit you to retrieve data of student applicants who have applied to your college or university using CTPathways. The personal information of the administrator is also shared with certain third-party vendors to enable member administrators to gain access to a student applicant’s payment status information.
Purposes for processing: we use this information to perform the contractual relationship that we have with the member Colleges or Universities you work for.

E. School Officials

Categories of personal information: If you are an official or employee at an educational institution, when you register for an account with our Properties, we collect information about you and your position at your school, including your name, your position and/or title, and your contact information, including email address, phone number(s), and mailing address(es) and zip code.
Purposes for processing: we use this information to perform the contractual relationship that we have with the educational institution your work for.

F. Recommenders

Categories of personal information: If you wish to submit recommendations for or on behalf of an applicant’s applications to one or more member Colleges or Universities, you must register an account with our Properties and provide information about yourself, including information about you and your relationship with the applicant, including your name, your position and/or title, any school code information, and your contact information including email address, phone numbers, and mailing address(es) and zip code.
Purposes for processing: To process applicant’s submissions(s) to our member Colleges and Universities

CTPathways also collects the above information when we believe that disclosure is necessary to protect our rights and the rights of our members and/or to comply with law or legal obligation (including to meet national security or law enforcement requirements).

5. With Whom CTPathways Shares the Information We Collect About You

CTPathways may disclose your personal information to third parties where it is necessary and for purposes described in this Privacy Statement or as notified at the time of collection, including:

Service Providers: CTPathways shares applicant names, phone numbers, and home addresses with service providers to confirm the accuracy of the mailing address that you enter. Applicant payment card information is shared with a payment card processor in order to make payment of admission application fees to the selected Colleges and/or Universities. We may also share personal information about you with other third party organizations allowing us and/or them to generate aggregate data which we and/or the third party may publish, combine, or enhance with other aggregate data obtained from other sources, and/or share or distribute the aggregate data. We also use services to provide and maintain our Properties.
Colleges and/or Universities: CTPathways shares personal information about applicants with member Colleges and/or Universities to allow them to assess applicants’ suitability for admission, communicate with applicants, and meet institutional reporting requirements. Note that even if an applicant never applies through the CTPathways, the Colleges and/or Universities in which the applicant has indicated interest will still have access to the applicant’s personal information as part of the applicant’s pre-application data prior to the application being submitted. Such Colleges and/or Universities may use this information, for example, to contact applicants even prior to the time an application is submitted to provide information about their institutions and admission processes and deadlines or track the demographics of their prospective applicant pool. CTPathways also shares information with Colleges and/or Universities for their own direct marketing purposes.
Business Partners: We may sometimes share your personal information with Business Partners or enable them to collect information directly via our Properties. Our Partners include, notably, Google, Facebook, Instagram, LinkedIn, Twitter, YouTube. Please read our Partners’ privacy policies to understand how they use your personal information.
Professional Advisors: We may disclose your Personal Data to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.
Authorities and others for compliance, fraud prevention and safety: We may share your Personal Data for the compliance, fraud prevention and safety purposes described above.
Business transferees: We may sell, transfer or otherwise share some or all of our business or assets, including your Personal Data, in connection with a business transaction (or potential business transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution.

6. Your Choices Regarding Communications from CTPathways and Member Colleges and Universities

Applicants. When you register with CTPathways, you are required to express your communications preferences to receive communications from CTPathways. These communications may include emails, phone or text messages or physical mailings to your address regarding financial aid, tips, and broader topics that CTPathways feels would benefit you. If you later decide that you would like to “opt out,” please edit your contact settings in your account. If you “opt out,” we may still contact you with messages regarding your account with us, including registration and submission confirmation texts, physical mail, and/or emails, to contact you to help answer a technical support question that you may have posed to us regarding your use of the Properties.

Through our App, we send you push notifications from time-to-time in order to update you about the admission application process. If you no longer wish to receive these types of communications, you may turn them off at the device level. To send these notifications, we collect certain information about your device such as operating system and user identification information.

School Officials and Recommenders. If you “opt out” of the online recommendation system via the email invitation initiated by the applicant, you will not receive any College/University specific information concerning the applicant’s admissions process; however, we may use your email address, cell phone number, and/or mailing address to send you registration and submission confirmation communications, text messages or emails, or we may need to contact the user/recommender to help answer a technical support question that you may have posed to us regarding your use of the Properties and to provide you with other information relevant to the student’s admission application process. Additionally, any member colleges may communicate with you regarding the applicant, using the information you or the applicant provide.

In addition, your mobile device settings may provide functionality to limit our, or our partners’, ability to engage in ad tracking or targeted advertising using the Google Advertising ID or Apple ID for Advertising associated with your mobile device.

If you choose to opt out of targeted advertisements, you will still see advertisements online, but they may not be relevant to you.

Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Choosing not to share your Personal Data. Please note that we may not be able to provide you with certain services if you choose not to share with us certain Personal Data.

7. CTPathways’s Retention Policy

CTPathways keeps personal information about you for as long as it is necessary to provide you with the CTPathways service or we have another legitimate reason to retain it, including for research purposes, longitudinal studies using aggregate data, or for our business purposes. When determining how long to retain your personal information, our considerations include our legal obligations under applicable law and other mandatory record keeping requirements and the likelihood of you needing access to the personal information we hold for purposes related to your previous use of the CTPathways or App.

8. CTPathways’s Data Security Policies and Practices

CTPathways follows industry-recognized security practices and standards to protect the personally identifiable information submitted to us, both during transmission and once it’s received. We employ physical, administrative, and technical safeguards designed to promote the security of our systems and protect the confidentiality, integrity, availability, and resilience of personal information. Those safeguards include: the pseudonymization and encryption of personal information where we deem appropriate; and periodic testing, assessment, and evaluation of the effectiveness of our safeguards.

When Properties are accessed using a supported web browser, Transport Layer Security (TLS) technology protects information using both server authentication and data encryption to help ensure that data are safe, secure, and available only to authorized users.

Your User Registration information is password-protected. We recommend that you do not divulge your password to anyone, that you sign out of your CTPathways registration account and close your browser window when you have finished your work, and that you do not copy and paste links from within the online application into an email or share with others on a public forum.

9. Children’s Privacy

CTPathways’s Properties are not intended for the use of children under the age of 13 or not old enough for us to process their Personal Information without parental or age-specific consent in the place where they live. If you believe we might have collected Personal Data from a child in one of these categories, please contact us at contact@ctpathways.com for us to investigate and delete as appropriate.

We do not process a child’s Personal Information, ages 13 to 15, without the explicit consent of the child’s parent or custodian. We collect this Personal Information to assist our users with the use of our application. Our legal basis for doing this is that it is necessary in order for children ages 13 to 15 to use our application.

10. Links to Other Websites

Our Properties may reference or contain links to other websites or services operated by other organizations that have their own privacy policies, such as Colleges and Universities. This Policy does not cover the privacy or information practices of those organizations that may be linked to or referenced by the Properties. Please make sure you read the terms and conditions and privacy policy carefully before providing any personal information on a website or service operated by another organization, as we do not accept any responsibility or liability for websites or services of other organizations.

11. How You Can Contact Us Regarding This Policy

If you have questions or concerns regarding this Policy, you should first contact the following CTPathways representative by email at the address below:

contact@ctpathways.com

U.S. Supplemental Statement

Certain U.S. states provide their residents with certain rights regarding their Personal Data that is collected by businesses. CTPathways has decided to allow all its customers and other persons in the U.S. to make the same requests, which we call Personal Data Requests (“PDRs”), regardless of whether their place of residence affords them the legal right to make such requests. CTPathways reserves the right to discontinue this policy at any time, and at its sole discretion, limit PDRs to only those residents of those jurisdictions where privacy laws afford the state residents privacy rights.

This section provides information about the types of Personal Data we collect and disclose to other companies. It also explains how you may make a PDR if you are a US resident.

Before processing your PDRs, we will confirm your identity by requiring you to provide certain information about you and/or your account with us and you will have to declare that you are who you claim to be.

You may exercise any privacy choice below by submitting a PDR via email to founder@ctpathways.com

Request to Know What Personal Data We Have Collected:
You may request that we disclose the following information to you:

The categories of Personal Data we have collected about you, directly or indirectly, including through or by a service provider or contractor;
The categories of sources from which the Personal Data was collected;
The business or commercial purpose for collecting or selling Personal Data;
The categories of third parties with which we share Personal Data;
The categories of Personal Data about you that we have sold or shared and the categories of third parties to which the Personal Data was sold or shared;
The categories of Personal Data about you that we disclosed for a business purpose and the categories of third parties to which the Personal Data was disclosed;
The specific pieces of Personal Data we have collected about you;

If you are an applicant, you may also save a copy of your application PDF to view the data CTPathways has collected about you.
Request Deletion of Personal Data: You may request that we delete any Personal Data about you, and that we notify any service provider, contractor, or third party to delete your Personal Data from its records. Your Personal Data may not be deleted under certain circumstances allowed by law, including, but not limited to, where maintenance of your Personal Data is necessary to: complete the transaction for which the Personal Data was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, to provide a good or service that you requested or that is reasonably anticipated within the context of their ongoing business relationship with us, or to otherwise perform a contract between us and you; to detect security incidents, protect against or prosecute fraudulent or illegal activity; to enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us; to comply with a legal obligation; or to otherwise use your Personal Data internally in a lawful manner that is compatible with the context in which you provided that specific data.
You may also delete your CTPathways account by sending us an email or through your account settings. For more information, please email founder@ctpathways.com
Request Correction of Personal Data: You may correct your Personal Data yourself through your CTPathways account before you submit your application. Once submitted, you will need to contact the Member institutions you have submitted your application to in order to correct your data.
Request Opt-Out from Sale or Sharing of Personal Data or Use of Personal Data for Targeted Advertising or Profiling:
You may direct us not to do the following:

Sell your Personal Data;
Share your Personal Data with third parties for cross-context behavioral advertising;
Use your Personal Data for targeted advertising;
Use your Personal Data for profiling that produces legal or similarly significant effects concerning you.

Request to Limit the Use and Disclosure of Sensitive Personal Data: You may request that we limit the use of your Sensitive Personal Data.
Appeal a Denial of a Personal Data Request: Should we deny your Personal Data request, you may appeal the denial within 60 days from receipt of our decision on your request. If your appeal is denied, we will provide you with an online mechanism, if available, or other method through which you may contact the Attorney General of your state to submit a complaint or express your concerns.

Authorized Agent: You may use an authorized agent to submit a PDR, including through the use of a technology including, but not limited to, an Internet link or a browser setting, browser extension or global device setting, indicating your intent to opt out of certain processing of Personal Data. To use an authorized agent, you must provide the agent with a signed authorization. We may require the agent to provide us with proof of the signed authorization. In addition, we may require you to verify your identity with us and directly confirm that you authorized the agent to submit the Personal Data request on your behalf. Such requirements, however, will not apply where you have provided the agent with power of attorney pursuant to applicable state law.

Authorized agents may submit Personal Data requests using the same process described above.

Non-discrimination: We will not discriminate against a person because the person exercised a PDR, including, but not limited to:

Denying goods or services to the person;
Charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
Providing a different level or quality of goods or services to the person;
Suggesting that the person will receive a different price or rate for goods or services or a different level or quality of goods or services;
Retaliating against an employee, applicant for employment, or independent contractor for exercising a PDR.

Personal and Sensitive Personal Data Collected, Shared, Sold, or Disclosed for a Business Purpose:

In the preceding 12 months, we may have collected the following categories of Personal Data from the following sources and for the following purposes. We may collect only certain pieces of Personal Data described in a given category and may not collect certain pieces of Personal Data described in each category. We retain this information as long as necessary for business purposes, which includes, but is not limited to, research and development, college application processing, and for compliance, fraud prevention, and safety.

Device operating system version, device type and system response times, Internet Protocol (IP) addresses, browser type, Internet Service Provider (ISP), referring/exit pages, date/time stamp, and/or clickstream data.

Category of Personal Data Collected

Name, email address, and any other information you decide to share with us. For more information, please review the “Properties Visitors” section of our Privacy Policy.

Category of Source of Collection

Web Site Visitors

Business or Commercial Purpose of Collection

To provide, operate and improve our Properties;
To respond to your requests, questions and feedback;
To analyze and improve our Properties;
To provide you with a personalized experience and advertisements;
For compliance, fraud prevention, and safety.

Category of Personal Data Collected

Name, home and mailing address, email address, home and cell phone number, date of birth, and information regarding your plans to attend college.

Your gender, legal sex, pronouns, military status, race, language proficiency, place of birth, duration of residency in the U.S./other country of residency, citizenship status, and financial status.

Your education, testing, extracurricular and/or community involvement history, and any information you voluntarily provide in your application, including writing samples and essays.

Information about you from recommenders and educational institutions you have attended.

For more information, please see the “Applicants” section of our Privacy Policy

Category of Source of Collection

Applicants

Business or Commercial Purpose of Collection

To process your application(s) to our member Colleges and Universities;
To allow you to pay fees required for your application to our member Colleges or Universities;
To validate the mailing address;
To allow our members to meet their institutional reporting requirements regarding certain protected characteristics, we may collect information about you, including your gender, race, ethnicity, sexual orientation.
To generate aggregate data for research and product development purposes.
To allow you to participate in CTPathways Programs, such as direct admissions.
To allow you to participate in Partner Programs, only with your express consent;
To communicate with you.

Category of Personal Data Collected

Name, marital status, household member information, children, whether the parent is living of dead, occupation, and education level, and number of siblings the Applicant has.

For more information, please see the “Parents/Guardians and Siblings of Applicants” section of our Privacy Policy.

Category of Source of Collection

Parents/Guardians and Siblings of Applicants

Business or Commercial Purpose of Collection

To communicate with parents or legal guardians for minors so we and our Member Colleges and Universities can get evidence of parent or guardian permission.

Category of Personal Data Collected

Name and email address

For more information, please see the “College/University Administrators” section of our Privacy Policy

Category of Source of Collection

College/University Administrators

Business or Commercial Purpose of Collection

To perform the contractual relationship that we have with the Member College or University you work for.

Category of Personal Data Collected

Name, email address, phone number(s), mailing address(es), zip code, the educational institution you work for, and your position and/or title.

For more information, please see the “School Officials” section of our Privacy Policy

Category of Source of Collection

School Officials

Business or Commercial Purpose of Collection

To perform the contractual relationship that we have with the Member College or University you work for.

Category of Personal Data Collected

Name, position and/or title, any school code information, email address, phone number(s), mailing address(es), zip code, and your relationship to the applicant.

For more information, please see the “Recommenders” section of our Privacy Policy

Category of Source of Collection

Recommenders

Business or Commercial Purpose of Collection

To process applicant submission(s) to our Member Colleges and Universities.