Effective Date: September 1, 2023

Last Revised: September 1, 2023

1. Introduction

ScholarMatch, Inc. (“ScholarMatch”) relies on electronic communications, including e-mail messages, to conduct its business and communicate with both third party volunteers and student users of ScholarMatch’s services (“Recipients”). As such, ScholarMatch has certain legal and contractual obligations with respect to the use of such electronic communications, including obligations under the Controlling the Assault of Non-Solicited Pornography and Marketing Act of 2003 (“CAN-SPAM Act”). ScholarMatch is committed to adhering to the requirements set forth by this Electronic Communications Policy (the “Policy”) and will cause its employees and independent contractors involved in the creation or transmission of electronic communications to do the same. Questions regarding this Policy should be directed to info@scholarmatch.org.

2. Scope

This Policy applies to all electronic communications created or sent by ScholarMatch to Recipients the primary purpose of which is the advertisement or promotion of a product or service (“Emails”), including all transmission and receipt data, including email headers, summaries, and addresses associated with email records, and any attached files or text. In accordance with the ScholarMatch Privacy Policy, available at https://scholarmatch.org/sm-privacy-policy/, Recipients must be over the age of 13.

3. Email Content

The subject lines of any Emails, as well as the “From”, “To” and “Reply To” fields, should not contain any false or misleading information. Email subject lines should accurately reflect the content of the applicable Email. Emails should include the physical address of ScholarMatch, which is 849 Valencia Street, San Francisco, CA 94110. All Emails should also include clear and conspicuous explanations of how Recipients can opt-out of receiving Emails in the future, including the mechanisms described in Section 4 below as well as a link to the ScholarMatch Privacy Policy.

4. Opt-Out Requirements

All Emails must contain functioning return email addresses or an “unsubscribe” link that redirects to a single website page managed by either ScholarMatch or a third party (e.g. MailChimp) that a Recipient may use to opt-out of receiving Emails from ScholarMatch. The opt-out mechanism must be available for use at least thirty (30) days after transmission of the original Email. ScholarMatch shall not require Recipient to (a) provide any information except for Recipient’s email address and opt-out preferences or (b) pay a fee, in either case, in order for ScholarMatch to fulfill the opt-out request.

Opt-out requests must be addressed and fulfilled within ten (10) days of receipt. After such a period, ScholarMatch may (a) not further communicate with the recipient or (b) sell, lease, exchange or otherwise transfer or release the e-mail address of any recipient for any purpose other than compliance with applicable law.

5. Third Party Contractors

In the event that ScholarMatch engages a third party for purposes of sending Emails to Recipients, ScholarMatch should evaluate such third party’s compliance with the requirements set forth in this Policy.