(Effective October 26, 2018)
We respect your right of privacy and recognize the rising concerns around online privacy and data collection. This Policy describes when we collect information about you, the types of information we collect, and the choices available to you regarding the use of the information you provide.
When you visit the Website, we may automatically collect certain technical information in ways described below. We also voluntarily collect information through forms on the Website in order to make products and services available to you or to maintain a relationship with you during your enrollment and after graduation. Providing the requested information means you are consenting to the collection, use and disclosure of this information. The information we may ask you to provide could include:
- Telephone Number
- Payment information (e.g., credit card number and billing address)
If you access the Website from a mobile device, we may also collect information about the type of mobile device in use, the type of mobile Internet browser in use, and information about the location of the device in use.
We do not sell any of your personally identifiable information to any third party. However, we may share your personal information with our service providers when they have agreed to protect the confidentiality of your personal information from unauthorized use, access, or disclosure. The personal information provided is used for the purpose and within the scope of the data request and destroyed upon the expiration or termination of any contract we have with the service provider. We may also disclose your personal information with other entities when legally required to do so, to comply with an applicable law or regulation, at the request of governmental authorities conducting an investigation, and to protect or defend our rights, property, or interests.
- IP address
- Internet browser
- Browser setting
- Operating system
- Date, time and duration spent on the Website
- Navigation paths
We do not automatically record the email addresses of our Website visitors, and our generic tracking information is not linked to your specific email address in any data collection we perform in the aggregate.
A cookie (also called web cookie, Internet cookie, browser cookie or cookie) is a small piece of data sent from a website and stored on a user’s computer by the user’s web browser while the user is browsing. Cookies are designed to hold a modest amount of data specific to a particular client and website with the intended use of providing a webpage tailored to the user through the knowledge stored within the file.
Types of Cookies
Third-Party Cookies: These are cookies that are set by a website other than the one you are currently visiting.
Session Cookies: These are cookies stored in temporary memory and are not retained after a browser is closed.
Permanent Cookies: These cookies, also known as persistent cookies, are stored on a user’s hard drive and activate each time a user visits a specific website. Permanent cookies are stored until they expire or the user deletes the cookie.
- Cookie settings in Chrome
- Cookie settings in Firefox
- Cookie settings in Internet Explorer
- Cookie settings in Safari-OS
- Cookie settings in Safari-macOS
When you contact us as a potential customer, we may collect certain personally identifiable information to begin or continue a conversation related to your interest. We use remarketing information for AdWords Remarketing, Google Display Network Impression Reporting, Google Analytics Advertising Reporting Features, Facebook Conversion Tracking, and Facebook Custom Audiences. Users can opt out of Google Analytics for Display Advertising and customize Google Display Network ads by using Google Ads Settings. To opt out from
Initiative opt-out page or the Digital Advertising Alliance’s WebChoices tool.
We may also run lead generation advertising through partners including Facebook, LinkedIn and other third-party services. This type of advertising collects personally identifiable information as part of its data collection and reporting processes. This statement does not apply to and we are not responsible for these third parties. We encourage you to check the privacy policies of advertisers and ad services to learn more about their practices.
Surveys and Contests
From time to time, the Website requests certain information via surveys or contests. Participation in these surveys or contests is completely voluntary and you may choose whether or not to participate and, therefore, disclose this information. Information requested may include contact information (e.g., name and mailing address), and demographic information (e.g., zip code and age). Contact information will be used to notify the winners and award prizes. Survey information will be used for purposes of monitoring or improving the use and satisfaction of the Website.
We take the security of your personal information seriously. We have an Information Security Policy to provide general guidance and specific recommendations for the protection of our information technology resources and the information stored on those resources.
We have appropriate physical security measures in place to protect against the loss, misuse, or alteration of the information we collect from you at the Website. Nonetheless, the Internet is constantly changing and no transmission of data can be guaranteed to be completely secure. Once the information is received, we will use industry standards to safeguard and ensure the sensitivity of the data being stored on our systems is maintained.
Links to Other Websites
The Website may contain links to other websites not directly affiliated with us. We are not responsible for the content of these links and would advise you to read the privacy statement of other sites to guarantee their practices protect your privacy.
European Union General Data Protection Regulation Compliance
We are a data “controller,” as defined under the European Union’s General Data Protection Regulation (”GDPR”). As a data controller, we are dedicated to protecting the rights of individuals covered under GDPR.
Lawful Basis for Collecting and Processing Personal Data
Our legal basis for collecting and processing personal and sensitive data is based on Article 6 of the GDPR. Most of our collection and processing of personal data will fall under one or more of the following categories:
- The data subject has given consent to the processing of his or her personal data for one or more specific purposes;
- Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract;
- Processing is necessary for compliance with a legal obligation to which we are subject; or
- Processing is necessary for the purposes of the legitimate interest pursued by us or by a third party.
Collection of Personal Data and Why
We collect and retain a variety of personal and sensitive data to fulfill our lawful basis outlined within GDPR. This data typically includes your name, address, email, phone number, transcripts, financial information and work history. This data is used for admissions and enrollment, educational programs, job hiring, research and community outreach. Failure to provide personal data that is required by us in order to fulfill our lawful obligations may make it impossible for us to provide requested services.
Cookies and Analytics
Individuals covered under the GDPR have certain rights concerning their data. Your rights include:
- The right of access to your Personal Data
- The right to have your inaccurate Personal Data rectified
- The right to have your Personal Data erased
- The right to restrict the Processing (as defined in GDPR) of your Personal Data pending its verification or correction
- The right to object to the Processing of your Personal Data
- The right to receive copies of your Personal Data
- The right to file a complaint with an appropriate European Union supervisory authority
- The right to object to using your Personal Data for direct marketing, data mining or research purposes where the research is not in the public interest
Your Right to be Forgotten
You have the right to have your personal data deleted, when applicable, and when it does not conflict with our legal requirements. To have your collected personal identifiable information removed, contact email@example.com. We will respond to your request in a timely manner upholding any deadlines imposed by law. Deletion of data may impact certain services dependent on that information. We will decline your request for deletion if processing of your personal information is necessary:
- To comply with our legal obligations
- In pursuit of a legal action
- To detect and monitor fraud
- For continued performance of a contract
We keep the personal information we collect for the least amount of time necessary to fulfill the specific purpose for which it was collected. We may also retain your records where we are legally obligated to do so.
Updates to this Policy
From time to time, we my update this Policy. We encourage visitors to check this page for any changes. If we make changes to this Policy, we will post an updated effective date. Your continued use of this Website after any change will constitute your acceptance of such change.
If you have questions regarding this Policy or concerns about how we collect and process your personal information, please contact us firstname.lastname@example.org.