Please note that Common Application is a not-for-profit organization based in the USA. Any personal information you provide or we collect is transmitted to, and stored in, the USA, and will also be shared with our member Colleges and Universities, at your direction, including in countries where laws may be less protective of your personal information than in your home country.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact us directly.
Date of Last Update: October 1, 2020
This policy will let you know about:
- What personal information does Common Application collect from you?
- What are cookies and similar technologies and how are they used?
- How does Common Application use applicant information?
- How does Common Application use school official information?
- How does Common Application use member College and University administrator information?
- How does Common Application use parent/legal guardian information?
- With whom does Common Application share applicant information?
- What is Common Application’s policy when there has been an allegation of fraud, misrepresentation or other inappropriate act or criminal allegation involving an applicant?
- What are the applicant's choices regarding collection, use, and distribution of information?
- What is Common Application's policy on allowing you to access, update, correct, or delete your personal information?
- Participation in Partner Programs
- What kind of security precautions are in place to protect the loss, misuse, or alteration of your information, including your credit card information and how is your information stored, accessed and used by others?
- Your California Privacy Rights
- Your European Economic Area and Swiss Privacy Rights
- Posting of Testimonials
- Social Media Widgets and Integrated Services
- Additional information and how you can contact us regarding this Policy
- Emails that you send us
What personal information does Common Application collect from you?
Common Application collects various information from applicants, recommenders, educational institutions, and member Colleges or Universities. This information is collected when you register for Common Application; complete an online form, including any application forms; provide a recommendation; and interact with us for other purposes. Common Application also collects technical information about your visit when you access our Properties.
If you are a student applicant, certain personal information is collected from you when you complete your "profile" as part of the registration and application process, provide this information to us through the completion of an on-line User Registration form, and/or or voluntarily complete the Common Application, any application supplements, or other applicant forms. This information includes your name, home and mailing address, email address, telephone number, citizenship, date and place of birth, payment information, and Social Security number. Common Application also collects the username and password you create during registration.
If you are a student applicant we may collect personal information about you from recommenders and educational institutions you have attended, including information about your academic achievements and performance, impressions of you and any other information they choose to provide us to support your application(s).
If you are an administrator at one of our member Colleges or Universities who uses the Common Application to receive student 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 the Common Application. 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.
If you are a parent or legal guardian we may collect personal information about you from the applicant, including your name, relationship with the applicant, address, telephone numbers, and/or email address.
When you access our Properties, we may also gather information such as device operating system version, device type and system response times (mobile device), Internet Protocol (IP) addresses, browser type, Internet Service Provider (ISP), referring/exit pages, date/time stamp, and/or clickstream data. See the “What are tracking technologies and how are they used?” section for information we automatically gather when you access our Properties.
What are cookies and similar technologies and how are they used?
Information collected automatically may include Internet Protocol (IP) addresses, browser type, Internet Service Provider (ISP), referring/exit pages, device type and system response times, operating system, date/time stamp, and/or clickstream data. We link this automatically-collected data to other information we collect about you. We do this to:
* Ensure that our Properties work properly on your device so we can provide you with services you request.
* Promote our legitimate interests in safeguarding and ensuring the smooth operation of our IT systems, including our Properties, and to help safeguard your personal information.
We may work with third parties that collect data about your use of the Properties and other sites or apps over time for non-advertising purposes. Common Application uses Google Analytics and other third-party services to improve the performance of the Properties. For more information about how Google Analytics collects and uses data when you use our Properties, visit www.google.com/policies/privacy/partners/, and to opt out of Google Analytics, visit tools.google.com/dlpage/gaoptout/.
We also use mobile analytics software to allow us to better understand the functionality of our Mobile Software on your phone. This software may record information such as how often you use our App, the events that occur within the App, aggregated usage, performance data, and from where the App was downloaded.
How does Common Application use applicant information?
Common Application uses the information it collects about applicants for various purposes, including to process your application to member Colleges and Universities; to communicate with you; and for research and statistical uses.
We may use the information we collect from applicants for any lawful basis, including in the following ways: * To process your application(s) to our member Colleges and Universities which 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. This information is, therefore, necessary for the performance of our services to you.
* To allow us to communicate with you when necessary for the performance of our services to you. For example, to provide you with technical support, answer your questions about the Common Application, and provide you with updates on the progress of your application, including by reminding you of upcoming deadlines.
* To send you push notifications from time to time in order to update you about the admission application process as necessary for the performance of the Common App service. If you no longer wish to receive these communications, you may turn them off on your device.
* To allow you to pay fees required for your application to our member Colleges or Universities to be processed, by linking you to the Higher One web site which collects your payment-related information.
* To allow us to send you other informational materials linked to our services, where you have engaged with us and have not opted out from receiving such information or you have affirmatively consented to receive it, as required by law.
* To allow us to confirm or “validate” through a third-party verification service the accuracy of the mailing address that you provide to further our legitimate interest in preventing misuse of the Common Application and our Properties.
* To create anonymized, aggregate data that we and our partners can use solely for research and statistical use.
* To allow our members to meet their institutional reporting requirements regarding certain protected characteristics including gender, race, ethnicity, sexual orientation.
How does Common Application use school official information?
Common Application uses school official information for various purposes, including to communicate with you regarding applicants for which you provide information.
By activating your account registration with our Properties, your collected personal information may be shared and used by our member Colleges and/or Universities to contact you at any time and for any reason, including sending SMS messages to your mobile phone number(s), written communications to your mailing address, and/or emails to your email address in order to provide you with other information relevant to the applicant’s admission application process. This information that we collect and share with our members includes your name, your official title, your email address, your cell phone number, your zip code, school code information and date, as well as your mailing address.
We do the above:
* With your consent, to allow us and member Colleges and Universities to which the relevant applicant(s) is applying to contact you in connection with the application.
* With your consent, to assess your recommendation and the applicant’s suitability for admission, as is necessary for the performance of the Common Application service to applicants.
* To communicate with you as necessary for the performance of our services to associated applicants, e.g., to provide you with updates on the application process, answer technical queries and provide service-related reminders and general service support.
How does Common Application use member College and University administrator information?
Common Application uses member College and University administrator information for various purposes, including to process applications of those that apply to your school and to communicate with you.
We may use the information we collect about member College and University administrators for any lawful basis, including the following:
* To allow you to retrieve data of applicants who have applied to your College or University using the Common Application, as necessary for the performance of our services to you and applicants.
* To communicate with you as necessary for the performance of our services to your College or University and associated applicants, e.g., to provide you with updates on the application process, answer technical queries and provide service-related reminders and general service support.
* To communicate with you to further our legitimate interests in promoting our services.
* To share your information with our third party payment card processing vendor, to enable member administrators to gain access to a student applicant's payment status information, only as is necessary to fulfill that applicant’s application for admission.
How does Common Application use parent/legal guardian information?
If the applicant is under 16, to allow us to communicate with you so we and our member Colleges and Universities can get evidence of your permission for the relevant applicant to provide us with their personal information. Common Application may also communicate with you when providing services to the applicant and his or her family.
With whom does Common Application share applicant information?
Common Application shares information with certain third parties, including service providers used for web services and payment processing. Common Application also shares information with certain third parties for their direct marketing purposes.
Common Application shares your personal information with our service providers who then share this information with member Colleges and/or Universities to allow them to assess your suitability for admission, communicate with you, and meet institutional reporting requirements.
We also share your name, phone number, and home address with Experian QAS, one of our trustworthy independent web service partners, solely to confirm or “validate” the accuracy of the mailing address that you entered and to enhance the aggregate data that we and our partners are developing solely for research use. Experian QAS does not store this personal information. Your payment card information is shared with a payment card processor in order to make payment of admission application fees to the Colleges and/or Universities you have selected.
We may also share your personal information 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 only data for research purposes. Note that even if you never submit an application through the Common Application, the Colleges and/or Universities in which you have indicated interest will still have access to personal information downloaded as part of your pre-application data prior to your application being submitted. Such Colleges and/or Universities may use this information, for example, to contact you even prior to the time your application is submitted to provide information about their institutions and admission processes and deadlines. See "What are your choices regarding collection, use and distribution of my information, including your rights to ‘opt-in’ or ‘opt-out’," to find out more about how this works, and what information is shared and how you can limit it.
We may provide your personal information to Partner Programs (all located in the USA), but only when you request that we do so. Find out more about our Partner Programs in the Participation in Partner Programs section of this document.
If Common Application is involved in a merger, acquisition, or sale of all or substantially all of its assets or experiences a bankruptcy event, we will post a prominent notice on the Web Site informing you of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.
Common Application shares information with third parties for their direct marketing purposes. See the “Your California Privacy Rights” section for more information.
Common Application also shares information pursuant to a subpoena, court order, governmental inquiry, or other legal process or as otherwise required by law, or to protect our rights or the rights of third parties. We also share your personal information with your consent or as otherwise disclosed at the time of data collection or sharing.
What is Common Application’s policy when there has been an allegation of fraud, misrepresentation, or other inappropriate act?
In the event of an allegation of fraud, misrepresentation, or other inappropriate act involving an applicant, Common Application may disclose information, including where required by law or where necessary to protect our rights and the rights of our members.
Members, secondary schools, and applicants are advised that Common Application functions as a conduit of information between the student applicant, his/her secondary school, and the various member Colleges and Universities selected by the applicant. As such, it is Common Application’s policy not to judge, evaluate, conduct any verification of, or perform an investigation on any information provided on or about a student applicant regardless of the source of that information.
That said, where we have been informed of an act of fraud, misrepresentation, or other inappropriate act involving an applicant, in certain situations, Common Application may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
The Common Application reserves the right to disclose your personal information as required by law or in any instance or circumstance when we believe that disclosure is necessary to protect our rights, the rights of our members and/or to comply with a judicial proceeding, police investigation, court order, or legal process served on the Common Application. Subject to any rights afforded by law, Common Application also reserves the right upon notice to an applicant to disclose information collected from a registered user about which member Colleges and/or Universities a student applicant had applied to, including possibly suspending or closing an applicant’s on-line account upon notice to the student, when we have reason to believe that accessing and/or disclosing this information or taking such action is necessary to prevent, identify, contact or bring legal action against someone who may be violating any of our on-line user agreements or policies or who may be causing injury to or interference with (either intentionally or unintentionally) Common Application rights or property, other Common Application users, members or schools, or to help protect anyone else that could be harmed by such activities.
Common Application may also disclose or access registered user information when we believe in good faith that the law requires us to do so and for administrative, technical, and other related purposes that we deem necessary to maintain or improve our services. Subject to the terms and conditions of The Common Application, Inc. Membership Non-Compliance Procedures, Common Application also reserves the right in its sole discretion to remove any College or University as a member without any further or special notice.
What are the applicant's choices regarding collection, use, and distribution of information?
Common Application offers registrants a choice mechanism through which registrants can indicate whether they would like to receive communications from Common Application and member Colleges and Universities. Common Application also offers its App users the ability to provide choice regarding push notifications.
You have the right not to provide us with any personal information about you when you visit the Properties (if applicable) but you will not be able to utilize our services unless you complete an on-line User Registration form. When you first register with Common Application, you are given the option to choose to receive communications from member Colleges and Universities and have certain personal information released to our member Colleges and Universities on your "My Colleges List" prior to submission of your application to that selected member College or University.
You must affirmatively "opt in" according to your preference. Should you "opt in," you can later change your mind and "opt out" for any member College or University by using the "Unsubscribe" link located at the bottom of the email you receive from that member College or University. Alternatively, you may "opt out" for all member Colleges and Universities by appropriately changing the setting located on your "Account Maintenance" page. You can access the “Account Maintenance” page by clicking on the Settings icon in the upper right hand corner of your application after logging in.
Should you choose to "opt in," a limited amount of the personal information that you provided us will be released to your designated member Colleges and Universities prior to submission of your application to those selected members. The personal information shared will include your name, permanent home address, ethnicity, sex, citizenship, date of birth, phone number(s), email address, and Social Security number. In addition, your "opting-in" will allow member Colleges and Universities to use your information to contact you at any time and/or to text you at your cell phone number.
Should you choose to "opt out," a more limited amount of your personal information that you had provided us is released to your selected member Colleges and Universities to allow such Colleges and Universities to track the demographics of their prospective applicant pool as well as the ability to respond to inquiries from applicants who have indicated an interest in their institution. The personal information shared will include your name, city, state, zip code, country, sex, citizenship, and date of birth.
Once registered, while you are free not to provide any personal information requested on the Common Application form, any application supplement or other applicant form, to do so may cause the member College and/or University that you select not to accept the application, supplement or other applicant form as complete and consequently this may delay the application admission process or reject the submission as incomplete regardless of payment. Users/applicants can also decide not to provide information that is designated as "optional" on any application, supplement, or other form and still utilize the service that we provide. Users should communicate with their designated College and/or University directly if any admission application is delayed or rejected or otherwise results in an outcome that does not satisfy the applicant's expectations. The Common Application is not involved in and cannot be held responsible for any admission outcome of any specific applicant.
When you register with Common Application, you are also required to express your communications preferences to receive communications from Common Application. These communications may include emails, phone or text messages or physical mailings to your address. These communications may go beyond the technical support of application submission to include information on financial aid, tips, and broader topics that Common Application feels would benefit you. If you initially “opt in” to receiving communications from us and later decide that you would like to “opt out,” please contact the applicant Solutions Center with your request, using the “Instructions & Help” link from your applicant account, or by clicking on the gear icon from your applicant account and changing your communication preference. If you “opt out,” we may use your email address, your home address, and your cell phone number (if you opt in) to send or mail you 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. If you select the “opt-out” option, we will not communicate with you beyond what is in technical support of your admission application process.
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 ensure you receive proper notifications, we will need to collect certain information about your device such as operating system and user identification information.
For school officials, 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 their respective admissions process; however, we may use your email address (User Name), 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 provide on any paper forms, or using contact information provided by the applicant on his or her application.
What is Common Application's policy on allowing you to access, update, correct, or delete your personal information?
Common Application offers you the ability to access, update, correct, and delete the information Common Application holds about you.
The Common Application keeps your personal information for as long as it is necessary to provide you with the Common Application service or we have another legitimate reason to retain it, including longitudinal studies using aggregate data. When determining how long to retain your personal information, our considerations include our legal obligations 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 Common Application or App.
Upon request Common Application Inc. will provide you with information about whether we hold any of your personal information. You may access and edit your registration information by using your User Name (your email address) and password. If you have forgotten your password, please click the "Forgot Password?" link at apply.commonapp.org to have password reset instructions emailed to you. For all other problems signing in to the Properties, please click "Help Center" at www.commonapp.org. If you wish for us to delete or no longer use any of your personal information that you submitted to us, you may email us with such a request at email@example.com and, subject to our legal obligations and other mandatory record keeping requirements, your personal information will be deleted or no longer used within thirty (30) business days after receiving your request.
The Common Application allows you to make revisions to your personal information. For any information that was erroneously provided by the applicant but was already submitted and can no longer be changed or re-submitted, you must contact the College/University or payment card processor directly to alert them to the erroneous information.
You may also update your email address and cell phone number within your on-line account, though once your email address information has been submitted to a selected member College/University, you can only update your email address and cell phone number if you contact that member College/University directly.
Participation in Partner Programs
Common Application offers certain partner programs with which we may share your personal information.
As a student applicant user and registrant of the Common Application Properties, you will also be given the opportunity to choose whether you want us to share personal information for the purpose of participating in certain partner programs. The Common Application has relationships with the following partner programs:
- If an applicant is utilizing our service through any of our partners (Naviance, Maia Learning, etc.), any personal information that we received about you from these partners will be deleted upon the request of the applicant’s high school or school district to which the applicant is attending, provided the school or school district has control over that information.
What kind of security precautions are in place?
Common Application offers suggestions through which users of its Properties may secure their information.
Your User Registration information is password-protected. You may edit your User Registration information by using your User Name (your email address) and password. We recommend that you do not divulge your password to anyone. Also remember to sign out of your Common Application registration account and close your browser window when you have finished your work.
Also, to help ensure the security of your application, do not copy and paste links from within the online application into an email or share with others on a public forum.
The data transmission is encrypted when you make submissions of the Common Application, supplements or other applicant forms to designated member Colleges or Universities or when you access your user registered account information from our Properties, or when you give us your permission to share certain of your personal information with Strive for College or with the Michael & Susan Dell Foundation for the purpose of participating in either program.
Your California Privacy Rights
Common Application offers California residents the right to request certain information under California law about the sharing of their personal information with third parties.
California Civil Code section 1798.83 entitles residents of California to request information about the third parties with whom Common Application has shared personal information in the immediately preceding calendar year and if those third parties ever used such information for direct marketing purposes. California residents may submit one request per calendar year in the form of a report that details: (a) of the categories of information Common Application shared, and (b) the name and address of the third parties with whom Common Application shared such information.
California residents may submit their request by scrolling to the Section entitled "Additional information and how you can contact us regarding this Policy" and following directions for accessing the Help Center.
Your European Economic Area, United Kingdom, and Swiss Privacy Rights
Common Application offers users from a European Union country, Iceland, Liechtenstein, Norway, the United Kingdom, or Switzerland protections afforded to them under the General Data Protection Regulation
If you are a student applicant, school representative, recommender, or other individual based in a European Union country, Iceland, Liechtenstein, Norway, the United Kingdom, or Switzerland and you provide us with your personal information, you are afforded privacy rights under the General Data Protection Regulation (GDPR).
If you are based in a European Union country, Iceland, Liechtenstein, Norway, the United Kingdom, or Switzerland (collectively, the “EU”), you may have rights over your personal information we handle about you, including but not necessarily limited to:
* The right to access, receive, or correct your personal information at any time
* The right to have your personal information erased (where there is no longer legal or necessary grounds to process or store your personal information)
* The right to have your personal information transferred to another at any time
* The right to restrict, or otherwise object to, the processing of your personal information at any time where your personal information is not accurate, where the processing is unlawful, where your personal information is no longer needed or where there is no longer good legitimate grounds to process your personal information
* The right to object to your personal information being processed if the lawful basis for processing your personal information is either our or a third party’s legitimate interests or a reason of public interest, or we use your personal information for direct marketing
* The right to withdraw your consent to the collection, handling, storage, and/or processing of your personal information at any time
* The right to complain to us and/or the appropriate EU “supervisory authorities” if you believe any of your rights are being violated
* The right to know if you are being “profiled” or “monitored” or if certain decisions are being made automatically based on your personal information
The lawful collection and processing of your personal information is necessary for us to perform the service of providing you with use of the Common Application Properties and we always seek to provide you with affirmative options so that you may decide if you want us to process your data for a particular purpose. We strive to make certain that all of the data that we request is necessary in order to provide you with our service or to otherwise accomplish the stated purpose. When we share your data with a third party, we always inform you of the name of the recipient of such data. Further, all of the opt-in consents that are presented to you are intended to fully inform you whether you want us to process your data, the purpose behind processing your data and who, if anyone, we will be sharing your data with in order to accomplish that purpose.
Please note that if you are an individual who is based in the EU and between the ages of 13 to 16, we will not process any of the personal information that you may have submitted to us until we have promptly received the express consent from your parent or legal guardian. If this consent is not promptly provided to us, any data that you may have submitted during the account creation process will be purged from our system in order to make certain that we are not retaining any of your data.
Note also that we have put into place with our partners and members certain mechanisms of cooperation, communication, and agreements so that your EU privacy rights are also honored by our partners and members. Accordingly, should you decide to access, rectify, erase, object to, or otherwise transfer any of your data that you submitted to us or if you wish to withdraw any one or all of your consents, please send your instruction to firstname.lastname@example.org.
If you have any questions or concerns about your rights under the GDPR or the steps that we have taken to comply with the GDPR, please contact us at email@example.com.
Social Media Widgets and Integrated Services
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 Common Application.
Additional information and how you can contact us regarding this Policy
The Common Application, Inc.
3003 Washington Blvd., Ste. 1000
Arlington, VA 22201
Emails That You Send Us
Please note that any emails, text messages, or other communications that you send us or which we have been given legal access to may be copied, forwarded, or distributed to our members within our sole discretion.