Pharos is committed to maintaining the privacy and security of personal information we collect or which is provided to us directly by our clients.

Changes in Privacy Policy

Pharos reserves the right to change this privacy policy from time to time, consistent with applicable privacy laws and principles.

Scope of this Privacy Policy

This Privacy Policy governs the information collected through pharosresources.com and all services we provide directly to you. It applies to personal information that can be associated with an identified or identifiable person. This Privacy Policy does not relate to anonymized, aggregated, or de-identified data. Whether you are accessing our public website, exploring employment opportunities through our third-party job portal, or using one of our products via a software application, this Privacy Policy governs our use of personal information for all our products and services that we provide directly to you. When we collect personal information directly from you in connection with our interactions with you, we are a data controller.

Scope of your Institution’s Privacy Policies

If you are an employee, student, prospective student, or other end user of our client, and we are collecting your personal information in connection with the products and services we provide to our clients, we are a data processor. In this case, our use of your personal information is governed by the privacy policy of the institution from which we have received, or on whose behalf we collected or use, your personal information (“your institution”). Our Privacy Policy does not supersede the terms of any agreements between us and your institution, nor does it affect the terms of any agreements between you and your institution, including any prior consent you have provided concerning the use and distribution of your personal information.

Information That We Collect

The type of personal information we collect about you depends upon your relationship with us.

Website Visitors

Pharos maintains a website that is generally accessible to the public. Our website provides information about our company and its products and services. Our website may also contain information concerning employment opportunities and provide the opportunity for individuals to submit applications for open roles. We may do this directly or through third-party vendors. You can generally visit our website without having to register or otherwise identify yourself.

We collect personal information in the following manner:

• Directly from you: To receive additional information about Pharos, you can fill out our Contact Us Form or Request a Demo Form by submitting PII, including your name and email address. This information is collected so that a Pharos representative can contact you. You also may provide personal information to us in connection with your request to attend sessions or events.
• Indirectly from you: We collect information about your online activities on websites and connected devices over time and across third-party websites, devices, apps, and other online features and services for analytics purposes (including the pages you visit and how you access and use our services using cookies and third-party analytics tools (e.g., log files, event data, GPS data, clear gifs, and scripts). This information includes information about the device(s) you use to access the service including unique device identifiers, IP address, operating system, browser, internet service provider, referring/exit pages, clickstream data, and cookies. Depending on your device settings, we may also collect information about your geographical location. We may use third-party analytics services, such as Google Analytics to collect this information. The information we obtain may be disclosed to or collected directly by these providers and other relevant third parties who use the information, for example, to evaluate the use of our service or help administer our services. To learn more about Google Analytics, please visit https://www.google.com/policies/privacy/partners/.
• Third-Party Integrations, Links, and Features: You may connect third-party integrations to your Pharos account(s) (e.g., Google SSO), which may ask for certain permissions to send information to Pharos. These third parties operate independently from us. The privacy practices of the relevant third parties, including details on the information they may collect about you, are subject to the privacy statements of these parties, which we suggest you review. To the extent any linked online service or third-party feature is not owned or controlled by Pharos, we are not responsible for these third parties’ information practices.

End User of an Institution That Uses Our Products
Your institution decides how your personal information is used. We provide our products and services to end users of an institution as a “data processor” on behalf of our clients (colleges and universities). This means that the main responsibility for data privacy compliance lies with your institution as a “data controller.” It also means that your institution’s privacy policy (rather than ours) governs the use of your personal information. Your institution determines what information we collect through our products and services and how it is used, and we process your information according to your institution’s explicit instructions.

The following section is primarily for informational purposes and describes how your information is generally collected when we provide products and services to you on behalf of a client. How your personal information is used depends on your institution, so you should read your institution’s privacy policy carefully.

We collect personal information in the following manner:

• Received directly from your institution: Depending on the products or services that Pharos provides to your institution, we may collect the following types of identifiable information: your name, email address, student ID, account credentials, course enrollment data, grades, enrollment and financial aid information, or other information directly from your institution or other third parties related to your enrollment or application status at your institution, or other institutions, or related to your success at your institution.
• Received directly from you: Depending on the Pharos products and services you use or your institution uses, we may collect the following types of identifiable information: your name, email address, and similar contact data when you provide or update this information in our products, your credentials for your institution’s systems account(s) to the extent our products integrate with such systems, content that you enter directly into our products, including results of surveys, notes, and summaries.
• Indirectly from you: We collect information on your use of our products and services. Depending on the products and services you access or use, we may collect the following data categories indirectly from you: We collect information about the pages you visit and how you access and use our products using cookies and third-party analytics tools. This information includes information about the device(s) you use to access the websites including unique device identifiers, IP address, operating system, browser, and cookies. Depending on your device settings, we may also collect information about your geographical location.

How We Use and Disclose the Information That We Collect

We may share the categories of personal information we obtain about you (as described above) with the categories of third parties listed in this section. Pharos collects, retains, processes, uses, and transfers your personal information for the following purposes and to the following third parties:

• To Provide our Services. We use personal information that we collect in order to provide our services, verify the identity of users; communicate with users of our services; provide information about, events, professional development sessions, and research collaboration opportunities; manage relationships with users of our services; provide support and troubleshooting services; and improve our services. We process personal information for these purposes because we have a legitimate business interest in doing so.
• Service Providers: We use service providers to help us provide our products and services to our clients and you or to perform work on our behalf. Where this requires access to personal information, we are responsible for the data privacy practices of the service providers. Our service providers are not allowed to use personal information they access or receive from us for any other purposes than as needed to carry out their work for us. Examples of our service providers include data storage providers, analytics platform providers, and survey providers.
• Analytics and Marketing: We use personal information that we collect in order to analyze the use of our services, enhance the services, develop new products or services, and perform market, trend, and statistical research and analysis. We analyze usage information for marketing purposes and for trends about our visitors’ demographics and use of our websites and services. This analysis is necessary to further our legitimate interest in understanding our users and how they interact with us and our website, improving our website, and communicating with you.
• Interest-Based or Targeted Advertising. We may obtain information about your online activities to provide you with advertising about products and services that may be tailored to your interests. This type of advertising is commonly referred to as interest-based advertising or targeted advertising. You may see our ads on other websites because we use third-party ad services. These services track your online activities over time and across third-party websites and apps by collecting information through automated means, including through the use of cookies, web server logs, web beacons, and other similar technologies. The ad services use this information to show you ads that may be tailored to your individual interests. The ad services may collect information including data about your visits to websites that serve Pharos advertisements, such as the pages or ads you view and the actions you take on the websites or apps. This information may be used for purposes of conversion tracking. This process also helps us track the effectiveness of our marketing efforts.
• Record Keeping. We use personal information that we collect for our internal record-keeping purposes, and for accounting, audit, and other internal functions.
• On behalf of your institution: For end users of institutions that use our products, we use your information on behalf of and under the instruction of your institution, which is the data controller. We share the information that we collect in accordance with our agreement with your institution. Your institution determines how your information is used.
• Product enhancements and research: To the extent permitted by applicable law or by our agreement with your institution, we may also use: Your personal information to evaluate and improve our products and services to develop new products and services; to tailor your experience on our websites; and/or de-identified information for research or business purposes like providing similarly-situated institutions a benchmarking data report on completion rates or class size.
• Client engagement and marketing: Pharos uses your information for client engagement and marketing purposes in limited circumstances, including managing the client relationship, invoicing, notification of product updates and maintenance, promoting Pharos products and services, and similar purposes.
• Other types of uses and legitimate business disclosures: We will also use and share your information to the extent required or appropriate in the following circumstances: to higher ed associations and other businesses with which Pharos co-hosts events if you chose to participate; to comply with legal or regulatory requirements and to respond to lawful requests, court orders, and legal processes; to protect and defend the rights, property, or safety of us, our clients, or third parties, including enforcing contracts or policies or in connection with investigating and preventing fraud; to process transactions when you use our services, we will share your payment and transaction data with third-party payment processors.

We do not disclose personal information about students that we collect through the provision of our educational products and services to third parties for behavioral targeting of advertisements to students.

Our marketing emails will include a link so that you can opt out of receiving marketing communications from us. You can do this by clicking on the “Unsubscribe” link in the email footer.

You can learn more about our use of cookies in our Cookie Notice.

Children’s Privacy

Pharos products and services are not intended for children under the age of 16, and we do not knowingly collect any information from children. If we learn that we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information upon request. Please contact us at privacy@pharosresources.com if you believe we have inadvertently collected personal information from a child under 16 without proper consent.

Your Rights and Choices

If you are a resident of certain states or countries, you may have one or more of the following rights.

• that we provide you with access to the personal information collected about you;
• that we provide a copy of your personal information to you in a portable format;
• that we correct or update your personal information that is inaccurate, incomplete, or outdated and that you are not otherwise able to update via your profile;
• that we delete your personal information;
• to opt out of the processing of your personal information for purposes of targeted advertising.

If you wish to exercise any of the rights described above in relation to your personal information or submit a request as an authorized agent on behalf of a consumer, please submit a request to Pharos at privacy@pharosresources.com. Prior to fulfilling your request, we will take reasonable steps to verify your identity.  To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.  If you choose to exercise any of these rights, you have the right to not receive discriminatory treatment from us.

Security

We employ a variety of physical, administrative, and technological safeguards designed to protect personal information against loss, misuse, and unauthorized access or disclosure.

Contact Us

If you have any questions or concerns about our Privacy Policy or data privacy practices, contact us at privacy@pharosresources.com or write to us at the following address.

Pharos Resources
Attn: Data Protection Officer
500 Chestnut St., Suite 700
Abilene, TX 79602