Privacy Policy

Last updated on June 9, 2016

Interfolio complies with the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland. Interfolio has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view Interfolio’s certification, please visit http://www.export.gov/safeharbor/.

Interfolio’s Privacy Policy

Welcome to www.interfolio.com (the “Site”), a website owned and operated by Interfolio, Inc. (“Interfolio,” “us,” or “we”). We developed this privacy policy (“Privacy Policy”) to explain how we collect, protect, use, and disclose information from you, our user (“you” or“your”). Interfolio, Inc. offers services to both individuals and institutions. If you are using any of the Services through an educational or other institution that is a customer of Interfolio, this policy does not supersede the terms of any agreements between Interfolio and any other party, nor does it affect the terms of any agreement between any user of the Services, their educational institution or any third party. Please make sure that you read the terms of any privacy policies that you enter into with parties other than Interfolio, including your educational institution, as those policies may also explain how your personal information is used by them. Please review the following statement to understand how the information you provide to Interfolio through the services will be treated.

This Privacy Policy will apply to users of the Site regardless of the type of User you are. You may be any of the following types of Users:

  • “Visitor”, which means that you simply browse the Site;
  • “Applicant” or “Candidate” which means you have registered with us and established an Account. Applicants/Candidates may be students, employees or faculty members of a University or may join Interfolio without such affiliation;
  • “Recommender”, which means that you have been asked to submit a letter of recommendation for an Applicant;
  • “University User”, which means you are an employee, contractor or agent of a University operating in such capacity. A “University” is a college or university with whom Interfolio has a contractual relationship, generally with the career services department or a specific academic department, to provide services to students, employees and faculty members; and
  • “Recipient User”, which means an employee, contractor or agent of a college, university or other employer that uses the Service to locate potential employees and/or faculty members (“Recipient”).

So we are clear about the terminology we are using, when we use the phrase “Personal Information”, we mean contact information (i.e., your name, address, email address, and/or telephone number) and any other non-public information that is used or intended to be used to personally identify an individual, and information associated with the foregoing. When we use the phrase “Anonymous Information”, we mean information that is not associated with or linked to your Personal Information. Anonymous Information does not enable identification of or contact with, individual persons.

BY USING OUR SITE OR SERVICES OR SUBMITTING PERSONAL INFORMATION THROUGH OUR SITE OR SERVICES, YOU AGREE TO THE TERMS OF THIS PRIVACY POLICY AND YOU EXPRESSLY CONSENT TO THE PROCESSING OF YOUR PERSONAL INFORMATION ACCORDING TO THIS PRIVACY POLICY. YOUR PERSONAL INFORMATION MAY BE PROCESSED BY US IN THE COUNTRY WHERE IT WAS COLLECTED AS WELL AS OTHER COUNTRIES (INCLUDING THE UNITED STATES) WHERE LAWS REGARDING PROCESSING OF PERSONAL INFORMATION MAY BE LESS STRINGENT THAN THE LAWS IN YOUR COUNTRY.

HOW WE COLLECT INFORMATION

Personal Information

We receive and store information you voluntarily provide to us (either through the Site or in some other way) upon registration or your use of the Site and Services. When you register with us, regardless of the type of User you are, we require you to provide certain Personal Information, such as your name and email address. You may choose to provide additional Personal Information as part of certain Services. As a rule, Interfolio only collects information necessary to provide the Services you or your institution have requested.

Some of our Services are designed for job Applicants, in which case the following provisions apply. Please remember that you do not have to submit any of this additional information, but we may not be able to provide you certain Services without that information.

  • If there are fees associated with the Services you receive, we will collect certain Personal Information in order to process payment of such fees, including a credit card number and associated billing information, and charge and collect the fees. We refer to this information as “Billing Information”. Notwithstanding anything to the contrary in this Privacy Policy, we will only use this Billing Information to process and collect fees. We may store this Billing Information if you request us to do so. Some Universities cover the fees for their students to use certain of our Services.
  • If you are an Applicant creating a dossier on the Site for our document transmission services (a “Dossier”), we enable you to submit information relevant to your Dossier, including your contact information, information about your experience, education, and interests. We will also collect and manage documents associated with your Dossier, such as your writing samples, transcripts, letters of recommendation, and cover letters.
  • If you are an Applicant creating your portfolio on the Site to publish on our Site (“Portfolio”), in addition to the information we may collect for your Dossier, we may collect additional information about your work history, publications, experience and other information you voluntarily submit to us, whether through the Site or otherwise.

Disclosure—Information Collected from Third Parties.

Certain Personal Information may be provided about you by other Users. For example, if you are a University User, someone within your University will have registered you and granted you access to our Services. If you are a Recommender, an Applicant may provide us your name and email address. We will consider any Personal Information about you collected as part of the registration process to be your Personal Information.

Other Users may also submit confidential Personal Information about you, including as part of your Dossier. For example, a letter of recommendation, evaluation or committee packet for your Dossier may be provided to us by a Recommender or by your University. We will refer to this type of Personal Information as “Confidential Personal Information” in this Privacy Policy. If you are the User providing the Confidential Personal Information, you recognize that the User about whom such information pertains will be the party controlling that information, even though it may contain information about you and is designed to be confidential. For example, if you are a Recommender, you will no longer be able to control or edit a letter of recommendation after you submit it to the Services, except that you can request that it no longer be used on behalf of the Applicant. Rather, the Applicant will control the Recipients to whom the letter is disclosed, although it is associated with your name as Recommender, and it will not be considered your Personal Information. Notwithstanding the foregoing, an Applicant will not be able to see Confidential Personal Information about him or her but will be able to direct the disclosure to certain Recipients. The provider of Confidential Personal Information cannot see the manner in which it is disclosed.

Anonymous Information

As you use our Service, we may also collect certain information, including your Internet protocol address, browser type, and access times. We use Cookies and navigational data like Uniform Resource Locators (URLs) to gather information regarding the date and time of your use of the Service. An “Internet protocol address” or “IP address” is a number that is automatically assigned to your computer by your Internet access provider when you use the Internet. In some cases your IP address stays the same from browser session to browser session; but if you use a consumer internet access provider, your IP address probably varies from session to session. We track IP addresses solely in conjunction with session cookies to analyze our web page flow. “Cookies” are small pieces of information that a web site sends to your computer’s hard drive while you are viewing a web site. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them). Persistent Cookies can be removed by following Internet browser help file directions.

Disclosure—Usage of Third Party Cookies

We may use a third party tracking service (such as Google Analytics) to track and analyze Anonymous Information from Users of our Site. Such third parties may use Cookies to help track User behavior. We do not have access or control over these cookies. Our analytics service provider uses session IDs to help us uncover bugs, improve user pathways, and build better services.

HOW WE USE INFORMATION

Personal Information

As we mentioned above, we use Personal Information to: (a) assist you in managing the documents in your Dossier and Portfolio, (b) provide you an online location for your academic portfolio (if you so choose); (c) facilitate Applicants applying to Recipients; and (d) otherwise connect Applicants to Recipients. As a result, we use your Personal Information to:

  • Administer your Account;
  • Provide you with Services and customer support;
  • Tailor the features of the Site or Services to you;
  • Respond to your requests, resolve disputes and/or troubleshoot problems;
  • Verify your compliance with your obligations in our Terms of Use and/or other agreements you may have executed with us; and
  • Communicate with you about the Site and the Services.

Sensitive information such as social security numbers are also collected for identity verification, but may be disclosed in accordance with this Privacy Policy.

We may also use your Personal Information to create Anonymous Information records by excluding information that makes the information personally identifiable to you, any other individual and the applicable University or Recipient.

We may send you communications via email about the Site and Services. You can opt out of receiving certain communications from the Site by clicking the “Unsubscribe” link at the bottom of each email. Please note that even if you unsubscribe or opt-out, we may still send you Site and Service related communications (e.g., emails related to your account).

Anonymous Information

Generally, we use Anonymous Information in statistical analysis to help us analyze patterns in the use of our Services. We may, through our use of Cookies, keep you logged into the Site, personalize your use of the Site and customize your experience on the Site. We may also use your Anonymous Information to improve our internal operations, surveys and software, customize the content and layout of the Site and/or Service and notify you of updates to our Site and Services.

DISCLOSURE OF INFORMATION

If you are an Applicant, you are probably using our Services to help you either send components of your Dossier to Recipients or to manage your online Portfolio. Either way, our Services operate on the principle of a submission event. Our Services are designed to manage your distribution of certain Personal Information to selected Recipients (or, in some cases, on our Site). As an Applicant, we may (and you hereby authorize us to) disclose the Personal Information selected by you to Recipients designated by you. To be clear, if you tell us to send your Dossier to ABC University, we will consider it an authorization to disclose your Dossier to that university (and you agree that it will constitute an authorization). Additionally, if you maintain a Portfolio, you authorize us to disclose the Personal Information selected by you in the manner designated by you on our Site (whether publicly or privately).

We may disclose certain Personal Information:

  • To third party vendors who help us provide the Services or the Site, in which case we will require such vendors agree to process such information based on our instructions and in compliance with this Privacy Policy (including your Billing Information to our payment processor);
  • To third parties to whom you ask or authorize us to send Personal Information (including, if applicable, Recipients and/or your University);
  • To a parent company, any subsidiaries, joint ventures, or other companies under a common control (collectively, “Affiliates”), in the event we have such Affiliates in the future, in which case we will require our Affiliates to honor this Privacy Policy;
  • If we believe in good faith that such disclosure is necessary to (a) resolve disputes, investigate problems, or enforce our Terms of Use; (b) comply with relevant laws or to respond to requests from law enforcement or other government officials relating to investigations or alleged illegal activity, in which case we can (and you authorize us to) disclose Personal Information without subpoenas or warrants served on us; or (c) protect and defend our rights or property or the rights and property of you or third parties.

In the event of a change in ownership, or a merger with, acquisition by, or transfer (including by bankruptcy) or sale of assets to, another entity, we reserve the right to transfer all of your Personal Information to that entity. We will notify you (via a posting on a Site or email, in our discretion) of such a transfer. This means if you are concerned about your Personal Information being transferred to a new owner, you can deactivate your Account. We will require the acquiring entity to comply with this Privacy Policy.

In the event we offer public or private forums on the Site or Services, you are welcome to share as much Personal Information as you think is necessary and appropriate (or authorize us to share such information). But please be aware than any Personal Information will be made available to other Registered Users and/or generally on our Site and we do not control what third parties do with such information.

Disclosure to Universities or Recipients

Giving you tools to help you protect your Personal Information is a vital part of our mission. It is up to you to make sure you are comfortable with the information you provide. We do provide Personal Information to Recipients to whom you have authorized disclosure and, if applicable, your University. We do not control how Universities or Recipients (or their respective Users) use or disclose the information they obtain from us.

If you are affiliated with a University, you hereby authorize us, and we may disclose your Dossier, related Personal Information and your Dossier’s delivery history to your University and its University Users, unless you opt-out of such disclosure in your account settings. If you do not wish to share this information with your University, you can opt-out by logging into your account and changing your privacy settings.

IF YOU AUTHORIZE US TO SHARE PERSONAL INFORMATION WITH A RECIPIENT OR YOUR UNIVERSITY, WE DO NOT HAVE ANY CONTROL OVER HOW ANY SUCH RECIPIENT OR UNIVERSITY USES AND DISCLOSES YOUR PERSONAL INFORMATION, INCLUDING INFORMATION YOU PROVIDE DIRECTLY TO THAT RECIPIENT. YOU ACKNOWLEDGE AND AGREE THAT (1) INTERFOLIO DOES NOT EVALUATE ANY RECIPIENT’S OR UNIVERSITY’S PRIVACY PRACTICES, AND (2) INTERFOLIO WILL NOT HAVE ANY LIABILITY FOR ANY ACTIONS OF ANY RECIPIENT OR UNIVERSITY. YOU SHOULD KNOW THAT RECIPIENTS TO WHOM WE MAY DISCLOSE YOUR DISCLOSED PROFILE MAY SHARE YOUR DISCLOSED PROFILE WITH OTHERS.

ACCESSING AND CONTROLLING YOUR INFORMATION

To change information that you have previously provided Interfolio, you may log in to your account at http://www.interfolio.com and edit the information on your Settings page. You may also contact Interfolio’s Customer Support to change this information by emailing privacy@interfolio.com or by calling (877) 997-8807. If you change and/or request changes to your information, subsequent uses or disclosures of that information by us will reflect those changes, however, we do not have the ability to update any information previously disclosed to any third party, including your University. We will correct any inaccuracies in any Personal Information that we have in our possession once notified of the requested change. We endeavor to process these requested changes as soon as is possible, but it may take up to thirty (30) days to make requested changes.

You may not be able to access Confidential Personal Information submitted to the Services about you (e.g. a confidential letter of recommendation). Similarly, if you have provided us with Confidential Personal Information, you may not be able to control this information or to whom it is disclosed. However, you can request its deletion by emailing privacy@interfolio.com or by calling (877) 997-8807. Such a request will not affect any previously disclosed information.

Certain information is necessary in order for us to provide the Site or Services; therefore, if you delete such necessary information you will not be able to use the Site or Services. If you wish to have your Personal Information removed from our databases or to discontinue the Service you may contact us at privacy@interfolio.com. Within a reasonable time period after we receive your request—and it may take up to thirty (30) days to process the deletion—we will remove your Personal Information provided, however, that we may continue to maintain and use your Personal Information in a manner where the information is no longer personally identifiable.

Please note that even though you may request the deletion of your Personal Information by us, we may be required (by law or otherwise, such as to prevent fraud, resolve disputes, troubleshoot problems, or enforce our Services Agreement) to keep this information and not delete it (or to keep this information for a certain time) in which case we will comply with your deletion request only after we have fulfilled such requirements). When we delete Personal Information, it will be deleted from the active database, but may remain in our archives.

In compliance with the US-EU and US-Swiss Safe Harbor Principles, Interfolio commits to resolve complaints about your privacy and our collection or use of your personal information. European Union or Swiss citizens with inquiries or complaints regarding this privacy policy should first contact Interfolio at privacy@interfolio.com

Interfolio has further committed to refer unresolved privacy complaints under the US-EU and US-Swiss Safe Harbor Principles to an independent dispute resolution mechanism, the BBB EU SAFE HARBOR, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by Interfolio, please visit the BBB EU SAFE HARBOR web site at www.bbb.org/us/safe-harbor-complaints for more information and to file a complaint.

USER FEEDBACK

If you provide feedback to us, we may use and disclose such feedback in accordance with the terms in our Terms of Service, provided we do not associate such feedback with your Personal Information. We will collect any information contained in such feedback and will treat the Personal Information in it in accordance with this Privacy Policy.

THIRD PARTY SITES

The Site may contain links to other websites. Interfolio is not responsible for the privacy practices or the content of these other websites. This Privacy Policy applies solely to information collected by us through the Site or Services and does not apply to these third party websites. We encourage our Users to read the privacy policies of each and every website they visit. Users should always use caution and common sense when choosing to provide Personal Information on the Internet, particularly when it comes to information such as credit cards and other payment information. The ability to access information of third parties from the Site or Services is for your convenience and does not signify our endorsement of such third parties, their services, other websites, locations or their contents.

SECURITY

The security of your personal information is important to us. When you enter sensitive information (such as a credit card number) on our order forms, we encrypt the transmission of that information using secure socket layer technology (SSL).

We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security. If you have any questions about security on our Web site, you can send email us at help@interfolio.com. This site has security measures in place to protect the loss, misuse and alteration of the information under our control.

BLOG

Our Web site offers publicly accessible blogs or community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal information from our blog or community forum, contact us at help@interfolio.com. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and explain why.

TESTIMONIAL

We display personal testimonials of satisfied customers on our site in addition to other endorsements. With your consent we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us at help@interfolio.com.

SOCIAL MEDIA WIDGETS

Our Web site includes Social Media Features, such as the Facebook button [and Widgets, such as the Twitter button or interactive mini-programs that run on our site]. These Features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the Feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our Site. Your interactions with these Features are governed by the privacy policy of the company providing it.

REGARDING CHILDREN

The Site is not directed to children and children are not eligible to use our Services. Protecting the privacy of children is very important to us. We do not collect or maintain Personal Information from people we actually know are under 13 years old, and no part of the Site or Services is designed to attract people under 13 years old. If we later obtain actual knowledge that a User is under 13 years old, we will take steps to remove that User’s Personal Information from our records.

CHANGES

This Privacy Policy is a living document. We reserve the right to modify this Privacy Policy at any time. If we are going to use your Personal Information that we have previously collected in a manner different from that stated at the time of collection, and you have provided us with your current email address, we will use reasonable efforts to notify you at that email address of such change. In the event you have provided us with an invalid or incomplete email address, or we do not have your email address on file, a notice of any such changes will be posted to the applicable Site. You will have a choice as to whether or not we use your Personal Information in this different manner. Any such modifications become effective upon the earlier to occur of (i) your acknowledgement of such modifications; (ii) your continued access to and/or use of the Site or Services fifteen (15) days after we first provide you with email notification of such modifications; or (iii) if we have not provided you with an email notification of such modifications, your continued access to and/or use of the Site or Services thirty (30) days after we have first posted such notice to the applicable Site(s).

In addition, if we make any material changes to our Privacy Policy that do not affect User information already stored in our database, we will post a prominent notice on our Site notifying Users of the change, and, at our discretion, email Users who have opted to receive communications from us, notifying them of the changes in our privacy practices. It is your sole responsibility to check the Site from time to time to view any such changes to the terms of this Privacy Policy. If you do not agree to any changes, if and when such changes may be made to this Privacy Policy, you must cease access to the Site and use of the Services. You give us permission to email you for the purpose of notification as described in this Section. By using the Services, you signify your assent to the Interfolio Privacy Policy. If you do not agree to this policy, please do not use the Services. Your continued use of the Services following the posting of changes to these terms will mean you accept those changes. Notwithstanding the foregoing our data privacy practices are governed by our agreements with educational institutions and applicable law.

CONTACT US

If you have questions or concerns about our Privacy Policy, please contact us at: help@interfolio.com

Interfolio, Inc.

1025 Connecticut Avenue NW #1103

Washington, DC 20036