Privacy Policy

1.Who we are and what this policy covers

This Privacy Policy explains how Capstelo, a brand of The Nelson M Group LLC ("Capstelo," "we," "us," or "our") collects, uses, shares, and protects personal data when you visit capstelo.com (the "Site"), fill out a form, sign up for email or text-message updates, or contact us (together, the "Services"). The Nelson M Group LLC is the business responsible for your personal information.

Capstelo is an information service that publishes plain-language educational content about how education grants and student financial aid generally work, how the main forms and deadlines fit together, and which inquiries to ask a financial aid office, and lets visitors opt in to related updates by email or text. Capstelo does not award, administer, or decide grants, take applications, offer or arrange loans, or match or refer people to schools or programs. Capstelo is not a school, college, lender, scholarship service, or government agency and does not provide financial, legal, or tax advice. Choosing a school and how to pay for it is always your own decision.

By using the Services, you acknowledge this Policy. If it does not suit you, please do not use the Services.

2.Information we collect

Topic information. The topic you select (for instance, "FAFSA basics" or "state grant deadlines") may suggest an interest in a financial area. We treat this as confidential and never share it. Please do not send us Social Security numbers, FSA ID passwords, tax returns, bank details, student ID numbers, or other detailed personal or financial details through our forms or by text. We do not need it.

We do not knowingly collect Social Security numbers, financial account numbers, or government ID numbers.

3.How we use your information

• To provide the Services you request, such as sending you education grant information on the topics you choose.
• To deliver the email and text messages you opted in to, among them confirmations, reminders, and notices about new educational guides.
• To honor your preferences, including opt-outs, unsubscribes, and privacy requests.
• To hold records of your consent, as required or recommended under laws and carrier rules for text messaging.
• To answer your questions and give support.
• To operate, secure, and enhance the Site, and to prevent fraud, spam, and abuse.
• To follow legal duties and enforce our Terms & Conditions.

We never use your details to make decisions that produce legal or similarly significant effects about you, and we do not make eligibility, aid, or admissions determinations about you.

4.How we share information

Your personal details is never sold. We will not "share" it for cross-context behavioral advertising.

No sharing of mobile information for marketing. We do not share your mobile phone number, text-message opt-in data, or consent records with third parties or affiliates for their marketing or promotional purposes. No mobile information will be shared with third parties or affiliates for marketing or promotional purposes. Text-messaging originator opt-in data and consent are not shared with any third parties except as described in this section.

No partner sharing. We do not sell, rent, or share your personal data, for example your name, contact details, ZIP code, or interests, with schools, lenders, scholarship or matching services, recruiters, lead-generation companies, or any other partners, and we are not paid by anyone for your information. We share information only in these limited situations:

• Service providers. Vendors that act on our behalf and under contract, for example website hosting, email delivery, customer-relationship software, form processing, and SMS platforms and the carriers or aggregators that deliver text messages. They may use your information only to offer services to us, and not for their own marketing.
• Legal and safety. When needed by law, subpoena, or legal process, or to protect the rights, safety, and property of you, us, or others.
• Business transfers. If The Nelson M Group LLC is involved in a merger, acquisition, financing, or sale of assets, information may be transferred as part of that transaction, subject to this Policy. Mobile opt-in data will not be transferred to a buyer for its own marketing without your consent.
• De-identified or aggregate data. We may use information that cannot reasonably identify you for analysis and reporting.

5.Text messaging (SMS)

If you opt in, we deliver text messages for the program Capstelo Capstone Notes. We use your mobile number only to deliver those messages and to administer the program. See our SMS Terms for message types, frequency, costs, and how to opt out.

• Text consent is optional and is not a condition of purchase or of using the Services.
• Educational text consent is collected through a separate, unchecked box.
• Reply STOP at any time to opt out. Reply HELP for help.
• Message frequency varies. Message and data rates may apply.

6.Text messages: rates, frequency, STOP and HELP

Message and data rates may apply. Message frequency may vary (up to about 8 messages a month, depending on the topics you choose). Text START to join at 877-550-1444, or opt in with the form on our Get Started or text updates page. Consent is not a condition of purchase or of using the Services.

• STOP: Reply STOP to any message to opt out (STOPALL, UNSUBSCRIBE, CANCEL, END and QUIT also work). You will get one confirmation text and then no more messages.
• HELP: Reply HELP to any message for help, or contact us by email at [email protected] or by phone at 877-550-1444.

Mobile information and text-message opt-in data are not sold or shared. We do not sell, rent, or share mobile phone numbers, text-message opt-in data, or consent records with third parties or affiliates for marketing or promotional purposes. Service providers (such as our messaging platform and carriers) may handle this information only to deliver messages and operate the program for us.

Our text-message number is 877-550-1444.

7.Cookies, analytics, and similar technologies

Only the cookies and similar tools the Site needs to work and stay secure are used. We serve fonts and images ourselves instead of loading them from third parties. No advertising or cross-site tracking cookies are used.

If we enable privacy-focused analytics in the future (for instance, counts of page views), we will use it only to understand how the Site performs, and we will update this section. You can control cookies through your browser settings. We follow the Global Privacy Control (GPC) signal as a request to opt out of sale or sharing where applicable. Because we never sell or share personal information, there is nothing further to opt out of.

8.Your choices

• Text messages: reply STOP to any text.
• Email: use the unsubscribe link in any email or write to [email protected].
• Update or correct your information: contact us at the address below.
• Delete your information: ask us, and we'll delete it unless we need to keep it for the reasons described under "Retention."

Opting out of one channel does not opt you out of others. Tell us if you'd like to opt out of everything.

9.Retention

We keep personal information only as long as needed for the purposes in this Policy, among them to honor opt-outs and to meet legal and recordkeeping duties. As a general guide:

• Contact details and preferences: until you ask for them to be removed or you have been inactive for 24 months, whichever comes first.
• Text-message consent records and opt-out records: kept for at least 4 years after your last interaction, so we can show you consented and respect your opt-out.
• Support messages: up to 3 years.
• Server logs: up to 12 months.

We delete or de-identify data once we have no further need for it.

10.Security

We use sensible administrative, technical, and physical safeguards, such as encryption in transit (HTTPS), access controls, and vendor due diligence. No method of transmission or storage is completely secure, and we cannot guarantee absolute security. Text messages are not encrypted, so we ask that you never reply with sensitive personal or policy information.

11.Your privacy rights (California and other states)

Depending on where you live (including California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia), you may have the right to:

• Know and access the personal details we hold about you, and the categories of sources and recipients.
• Correct inaccurate information.
• Delete your personal information, subject to legal exceptions.
• Port your information in a usable format.
• Opt out of the sale or sharing of personal data, targeted advertising, and profiling. We do none of these.
• Limit the use of sensitive personal details. We use it only to provide the Services you ask for.
• Not be discriminated against for exercising your rights.

How to make a request

Email [email protected] with the subject "Privacy Request," or write to us at the address below. We will verify your identity by matching information you provide against what we hold, and we reply within 45 days (we may extend once by up to 45 more days with notification). An authorized agent may submit a request on your behalf with your written permission. If we deny a request, you may appeal by replying to our decision, and you may contact your state attorney general.

California disclosures

In the past 12 months we have gathered the categories of information listed in Section 2 for the purposes listed in Section 3, and revealed them only to service providers (Section 4). We have not sold or shared personal details. California residents may also request data about disclosures of personal information to third parties for their direct marketing purposes (California "Shine the Light" law). We make no such disclosures. We will not knowingly sell or share the personal data of anyone under 16.

Nevada

Nevada residents may submit a request to opt out of the sale of covered information. We never sell covered data.

12.Children's privacy

Adults 18 or older are the intended audience for the Services. Nobody under 18 is knowingly asked for personal details, and the Services are not directed to children. Think a child has sent us personal data? Contact us and we will delete it.

13.Consent to communications and the TCPA

We send educational text messages through automated technology only after you give prior express written consent by checking the separate, unchecked SMS consent box on our forms or by texting START to 877-550-1444. Your consent is not required to use the Services or to buy anything, and you can revoke it at any time by replying STOP, or by any other reasonable means, such as emailing [email protected]. We honor opt-out requests promptly. Your phone number will be used only for the reasons outlined in this Policy and the SMS Terms.

We comply with the Telephone Consumer Protection Act (TCPA), the CTIA Messaging Principles and Best Practices, and the carrier code of conduct, and we keep consent records as outlined above.

14.Third-party links and public resources

Our Site may link to other sites, for example public and government resources such as StudentAid.gov or your state higher-education agency. We do not control them and are not responsible for their privacy practices. Please read their policies.

15.U.S. operations

The Services are intended for people located in the United States, and data is processed in the United States. If you use the Services from elsewhere, you do so at your own initiative and are responsible for local law.

16.Changes to this policy

We may update this Policy from time to time. We will change the "Last updated" date above, and if changes are material we will give notification by email or on the Site. Where mandated by law, we will ask for your consent again.

17.Contact us

Questions, requests, or complaints about privacy? You can reach us by mail, email, phone, our online contact form, or by replying HELP to any text: