Privacy Policy

Last Updated: June 16, 2021

Welcome to Frank. This website is offered by TAPD, Inc., d/b/a Frank (“Frank,” “we,” our,” or “us”). This Privacy Policy addresses Frank’s practices regarding personal information that we collect from or about users (“you”) of our services (the “Services”) and from our website (the “Site”). This Privacy Policy, including the Terms of Service (withfrank.org/terms-of-service), govern your use of the Services. Please read this Privacy Policy from time to time. BY ACCESSING AND USING THE SITE OR SERVICES, YOU ACKNOWLEDGE AND AGREE TO THE TERMS OF THIS PRIVACY POLICY.

What type of information does Frank collect and how does Frank collect it?

We collect your personal information, for example, when you provide it to us to open an account, enroll in one or more of our Services, or contact us. In some instances, Frank automatically collects information about the devices you use to interact with the Site. The information we automatically collect may include your IP address, unique device identifier, type of operating system used, mobile device, mobile carrier, demographic information, and your browser location. We may also use cookies and other online tracking technologies, as described in the Cookies and Automatic Data Collection part of this policy described below. Frank may also collect information about you from third parties with whom you have interacted in the past.

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.
  • Internet or other electronic network activity information, including, but not limited to, browsing history, browser type and version, search history, and information regarding your interaction with our Site. We may collect this information through the use of cookies, web beacons, pixels, and other online tracking technologies as set forth in the Cookies and Automatic Data Collection part of this policy.
  • User Profiles, we may aggregate the information that we collect about you or that 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, maintain security of the Site and our Services, 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:

  • To provide Services: When you direct us to do so, we will share your information, including your financial information, with FAFSA.gov to enable you to submit your FAFSA®.
  • 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 personal information including contact information, demographic information, and academic preferences with our business partners for the purposes of marketing their 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 privacy@withfrank.org or by calling us toll-free at 888-914-9661 x451289.
  • 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.
  • To companies within our corporate family: We may disclose your personal information to our corporate affiliates for organizational purposes. To the extent that our corporate affiliates have access to your personal information, they will follow practices that are at least as restrictive as the practices described in this Privacy Policy, will use your information solely for the purpose for which it was provided, and will not further disclose your information.

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.

Data Retention

Unless provided otherwise in this Privacy Policy, we will retain your information for as long as your account is active or for as long as reasonably necessary for the relevant business purpose for which the information was provided. We may also retain and use your information for longer periods in case it is reasonably necessary to comply with our legal obligations, resolve disputes, and/or enforce our agreements.

Cookies and Automatic Data Collection

A cookie is a small text file that can be sent to your browser and placed on your device that allows us to recognize and remember you. When you visit a page from our Site, we or third parties with whom we have partnered may collect internet or networking information from you automatically through the use of cookies or other similar technology. This information may include your IP address, unique device identifier, type of operating system used, mobile carrier, and your browser location. You may adjust your internet browser to not accept or to delete our cookies at any time. However, if you set your browser to refuse cookies you may be unable to access certain parts of our Site. Unless you have adjusted your browser setting so that it will refuse cookies, our Site will issue cookies when you direct your browser to our Site.

We may use our own cookies to authenticate your access to our Site.

Additionally, our Site and Services may use third-party cookies, web beacons, and pixels 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, 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

Our Site may contain links to third party websites. If you access a third party website from a link on our Site, any information you disclose on that website is not subject to this Privacy Policy. It is possible that these links may be used by third parties or others to collect personal or other information about you. Frank is not responsible for the privacy practices of such websites, advertisers, or third parties or the content of such websites and it is your sole obligation to review and understand the privacy practices and policies of these other websites. Frank does not control these third parties’ use of cookies, collection of information, or how they manage such information. It is solely your obligation to review and understand the privacy practices and policies of these other websites, advertisers, and any third parties.

Accessing, Deleting, and Managing Your Data

Online users of the Site and Services can email privacy@withfrank.org or call us toll-free at 888-914-9661 x451289 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 privacy@withfrank.org or by calling us toll-free at 888-914-9661 x451289.

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 or by emailing privacy@withfrank.org.

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.

Changes to the Privacy Policy

Frank reserves the right at any time to modify, alter, or update this Privacy Policy. If we make material changes to the Privacy Policy that change how we use your personal information, we will use reasonable efforts to notify you of the change.

Contact Us

If you have any questions or privacy concerns, you can contact us at any time. Please email info@withfrank.org with general questions, email privacy@withfrank.org with privacy-related questions, or call us toll-free at 888-914-9661 x451289.

Notice to Residents of Nevada

If you are a resident of Nevada and would like to opt-out of the sharing of your information with third parties as described in this Privacy Policy, you can contact us at any time to limit our sharing. Please email privacy@withfrank.org or call us toll-free at 888-914-9661 x451289 with your request.

Notice to Residents of California

Our Privacy Policy provides you with an overview of what personal information Frank collects and shares with third parties, how Frank uses the information it collects, what third parties Frank shares personal information with, what rights individuals have with respect to their Personal Information collected by Frank, as well as information regarding Frank’s retention of your Personal Information.  This California Privacy Rights Notice describes the additional rights that California residents have with respect to their Personal Information.  This Notice supplements, but does not replace, Frank’s Privacy Policy.

Your Rights to Request to Know and to Access Personal Information

If you are a California resident, the California Consumer Privacy Act (CCPA) gives you the right to request more information about the Personal Information we have collected about you and how we have used, disclosed or sold it. If you want to know the Personal Information we have collected about you in the last 12 months, you may submit a verifiable consumer request to us and, once we have verified your request, we will provide you with the following information:

  • the categories of Personal Information we have collected about you;
  • the categories of sources from which the Personal Information is collected;
  • the business or commercial purpose for collecting, disclosing, or selling, if applicable, the Personal Information;
  • the categories of third parties with whom we have shared or sold, if applicable, your Personal Information; and
  • the specific pieces of Personal Information we have collected about you. 

In addition to these disclosures, you may submit a verifiable consumer request up to two (2) times in a twelve (12) month period for access to your Personal Information.  When you submit an access request, you can request that we deliver the information to you by mail or electronically.  If you elect to receive the information electronically, to the extent it is technically feasible for us to do so, we will provide the requested information in a portable and readily useable format.

To the extent that we collect the information in the first place, we will not disclose any of the following information in response to an access request: your social security number, driver’s license number or other government-issued identification number, financial account number, any health or medical identification number, an account password, or security questions or answers in response to a request to know.

In order to submit a verifiable consumer request, please see the “How You Can Submit A Verifiable Consumer Request” section below.   

Your Right to Request Deletion

If you want us to delete the Personal Information we have collected from you, you can send us a verifiable consumer request requesting that we delete some or all of the information we have collected from you, subject to certain exceptions.  Once we receive and confirm your request, we will delete your Personal Information in our active records, unless an exception applies.  We will also notify any service providers and third parties with whom we have shared your Personal Information of your request.  In the event that we deny your request to delete based on an exception under the CCPA, we will inform you, in writing, of the reason.    

How You Can Submit a Verifiable Consumer Request

In order for us to process a request made pursuant to the CCPA, it is necessary for us to verify your identity.  We cannot fulfill your request if we cannot verify your identity.   

We will acknowledge receipt of your request to know, access or delete within ten (10) business days of receipt.  However, it may take up to forty-five (45) calendar days to fulfill your request, or up to a total of ninety (90) calendar days if additional time is needed.  In the event that we cannot complete your request within the initial forty-five (45) calendar day period, we will notify you in writing within the initial forty-five (45) calendar day period. 

To request to exercise one or more of your CCPA rights, please submit a verifiable consumer request:

  • Click here to submit your request and all of the verification information described below; or
  • Call toll-free at 888-914-9661 x451289 and provide all of the verification information described below.

Only you or your authorized agent may submit a personal information request. You may also make a personal information request on behalf of your minor child. 

All verifiable consumer requests must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information, or an authorized agent. 
  • For a request from you, we will typically require: (1) your full name, (2) your email address, (3) your mailing address, (4) your telephone number, and (5) the username, if any, that is associated with your account.  If we require any additional information from you in order to verify your identity, we will contact you.  Any additional information you provide for verification purposes will be deleted within a reasonable period of time after responding to your consumer request.
  • For a representative request from an authorized agent, we require a signed authorization from you demonstrating the agent’s ability to act on your behalf, a valid power of attorney under California Probate Law or court appointment document, or, for agents that are business entities, a copy of the agent’s registration with the California Secretary of State.  We may contact you directly to confirm you have given your permission or to verify your identity.
  • For a request related to a household, all members of the household must submit the request, and each member must provide information sufficient for us to verify their identity.  Typically, that will include any email or physical address and phone number that may have been submitted to us and a valid phone number belonging to the individuals making the request.  We may deny a request from a household if we cannot verify that the individual(s) making the request are part of the same household.

Your Right to Opt-Out of the Sale of Personal Information

California residents may opt out of the “sale” of their personal information.  As the term is defined by the CCPA, Frank may have sold the following categories of personal information in the last 12 months for marketing purposes after obtaining your consent.  Specifically, with your consent, Frank may have shared your name, phone number, e-mail, zip code, and school and degree preferences with our partners, including educational institutions.  If you would like to opt-out of this use of your personal information, you can do so by calling us toll-free at 888-914-9661 x451289 or clicking here.

You may opt back in at any time by calling us toll-free at 888-914-9661 x451289 or sending an email with your request to privacy@withfrank.org.

Your Right to Non-Discrimination

The CCPA prohibits businesses from discriminating against California consumers for exercising any of their rights under the CCPA.  This means that if you exercise any of your rights under the CCPA, we will not deny you goods or services; charge you different prices or rates for goods or services; or provide different levels or quality of goods or services to you.

Notice to Residents of California last modified: June 15, 2021

We are not affiliated with the U.S. Department of Education. Federal Student Aid (FSA), an office of the U.S. Department of Education, makes the Free Application for Federal Student Aid (FAFSA®) form and assistance available to the public for free at fafsa.gov.

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