Global Privacy & Data Stewardship Policy

1. Our Dual-Governance Architecture

Equedu operates under a unique “Siloed Governance” model. This architecture ensures that the data a university holds about you is never conflated with the data you choose to share with us for your career.

1.1 Our Roles Defined

• Admissions & Analytics Solutions (B2B): When universities use our analytics platforms, we act as a Data Processor. The educational institution is the Data Controller. We process data solely according to their instructions and our Data Processing Agreement (DPA). We prioritize “In-Situ” Processing, meaning we analyze data within the university’s own secure environment to ensure they retain absolute custody.
• Talent Network & Career Apps (B2C): When you create a profile directly with Equedu to find scholarships or jobs, we act as the Data Controller. In this capacity, we are directly accountable to you and determine how data is used to provide recruitment services.

1.2 Data Separation

We maintain strict technical and logical separation between B2B Analytics data and B2C Talent Network data. Information processed on behalf of universities is never used to build consumer profiles for the Talent Network without explicit legal permission from the University and, where required, your consent.

2. Information Stewardship: The “Why” Behind Collection

We adhere to Data Minimization — collecting only what is strictly necessary to achieve a specific outcome for you.

2.1 Academic Credentials

• Why We Collect It: To match you with institutions and employers where you are likely to thrive.
• Stewardship Note: This information is only shared with partners (universities or recruiters) that you explicitly authorize.

2.2 Sensitive Personal Information (SPI)

• Why We Collect It: To facilitate “Equity-First” recruitment and diversity-focused scholarships.
• Stewardship Note: Providing this data is entirely optional. You may “Limit Use” or request its deletion at any time without impacting your core services.

2.3 Digital Identifiers

• Why We Collect It: To secure your account, prevent fraud, and ensure our platform functions in your local language.
• Stewardship Note: We use these identifiers solely for platform functionality; we do not track your activity on non-Equedu websites.

3. The “In-Situ” Security Standard: Zero-Export Guarantee

For our University partners, we have pioneered the In-Situ Processing Model to mitigate risk.

• Data Residency: Sensitive student records (transcripts, financial aid, enrollment status) remain on University-controlled servers.
• Remote Insights: Our analytics dashboards act as a secure “lens,” allowing University leaders to see predictions generated inside their own environment without raw data ever being exported to Equedu.
• Audit Integrity: Every action we take is logged by the University’s own security systems, ensuring total oversight.

4. Algorithmic Accountability

We use proprietary matching engines to suggest opportunities, but we reject “Black-Box” automation.

• Augmentation, Not Replacement: Our AI identifies potential matches, but final decisions — like university admissions or job offers — are always made by human professionals.
• Bias Audits: We conduct regular “Red-Team” audits of our algorithms to ensure they do not create or reinforce unfair bias based on protected characteristics.
• Your Right to Review: If you believe an automated match has unfairly impacted your opportunities, you have the right to request a manual review by an Equedu specialist.

5. Data Lifecycles & Anonymization

• Retention: We maintain your Talent Network profile for five years after your last login — the typical duration of a student’s transition from high school to professional entry.
• De-identification: After five years of inactivity, data is either purged or de-identified using the k-anonymity (k > 5) standard. This ensures that information can contribute to educational research without being traceably linked to you. We contractually prohibit recipients of our research from attempting to re-identify individuals.

6. Global Data Mobility

• EU-U.S. Data Privacy Framework (DPF): Equedu complies with the DPF and its UK extension. We have certified our adherence to the U.S. Department of Commerce.
• Independent Recourse: Inquiries regarding DPF compliance should first contact contact@equedu.org. If unresolved, you may contact our U.S.-based third-party dispute resolution provider (JAMS or BBB National Programs).
• Standard Contractual Clauses (SCCs): We utilize the European Commission’s SCCs for all international transfers, backed by a Transfer Impact Assessment (TIA).

7. Children’s and Minors' Privacy

• Under 13: We do not knowingly collect personal information from children under 13 (COPPA).
• Minors (13–17): We implement enhanced protections:
  • Default Privacy: Profiles for minors default to “Private” settings.
  • Advertising: We disable cross-context behavioral advertising for accounts identified as minors.
  • No Sale/Sharing: We do not sell or share the personal information of users under 16 without affirmative authorization.

8. Your Rights and Autonomy

Regardless of where you live, Equedu provides a “Global Gold Standard” of user rights:

• Transparency & Access: Request a report of what data we hold and why.
• Control over Sale/Sharing: We honor Global Privacy Control (GPC) signals.
• Portability: Download your data in a machine-readable format.
• Sensitive Data Limitation: Restrict use of race or disability data to specific services (e.g., a specific scholarship application).

9. Contact the Office of Data Ethics

If you have questions regarding our “In-Situ” model or your data rights, please contact our Privacy Lead.

Email: contact@equedu.org
Registered Office: Equedu LLC, 1178 Broadway, 3rd Floor, New York, NY 10001, USA