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“Personal Information” is information that identifies you as an individual or relates to an identifiable individual, such as:
COLLECTION OF PERSONAL INFORMATION
We and our service providers collect Personal Information in a variety of ways, including:
Through the Services
We collect Personal Information through the Services, for example, when you visit one of our sites, apply for admission, or maintain an ongoing relationship with us as a student.
From you during your course of study or period of enrollment with us.
We collect Personal Information from you offline, such as when you complete an application for admission, fill out a form at an education or career fair, apply for a student ID card, participate in a promotion, or contact us by phone.
From Other Sources
USE OF PERSONAL INFORMATION
We, our affiliates and our service providers use Personal Information for legitimate business purposes including:
Providing the functionality of the Services and fulfilling your requests.
Questions, Suggestions, or Complaints.
Providing you with our newsletter and/or other marketing materials and facilitating social sharing
Analysis of Personal Information for business reporting and providing personalized services.
We will provide personalized services either with your consent or because we have a legitimate interest.
Allowing you to participate in sweepstakes, contests or other promotions
Aggregating and/or anonymizing Personal Information.
Accomplishing our business purposes.
DISCLOSURE OF PERSONAL INFORMATION
We disclose Personal Information:
OTHER USES AND DISCLOSURES
We also use and disclose your Personal Information as necessary or appropriate, especially when we have a legal obligation or legitimate interest to do so:
To comply with applicable law.
To respond to requests from public and government authorities.
To cooperate with law enforcement.
For other legal reasons.
In connection with a sale or business transaction.
“Other Information” is any information that does not reveal your specific identity or does not directly relate to an identifiable individual
Browser and device information
App and/or Website usage data
Information collected through cookies, pixel tags and other technologies
Demographic information and other information provided by you that does not reveal your specific identity, such as your gender or date of birth
Information that has been aggregated in a manner such that it no longer reveals your specific identity
If we are required to treat Other Information as Personal Information under applicable law, then we may use and disclose it for the purposes for which we use and disclose Personal Information as detailed in this Policy.
COLLECTION OF OTHER INFORMATION
We and our service providers collect Other Information in a variety of ways, including:
Through your browser or device
Through your use of the Apps
Using pixel tags and other similar technologies
Using Adobe Flash technology (including Flash Local Shared Objects (“Flash LSOs”)) and other similar technologies
Your IP address is automatically assigned to your computer by your Internet Service Provid-er. An IP address may be identified and logged automatically in our server log files whenever a user accesses the Services, along with the time of the visit and the page(s) that were visited. Collecting IP addresses is standard practice and is done automatically by many websites, applications and other services. We use IP addresses for purposes such as calculating usage levels, diagnosing server problems and administering the Services. We may also derive your approximate location from your IP address.
We may collect the physical location of your device by, for example, using satellite, cell phone tower or WiFi signals. We may use your device’s physical location to provide you with personalized location-based services and content. We may also share your device’s physical location, combined with information about what advertisements you viewed and other information we collect, with our marketing partners to enable them to provide you with more personalized content and to study the effectiveness of advertising campaigns. In some instances, you may be permitted to allow or deny such uses and/or sharing of your device’s location, but if you do, we and/or our marketing partners may not be able to provide you with the applicable personalized services and content.
USES AND DISCLOSURES OF OTHER INFORMATION
We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. In some instances, we may combine Other Information with Personal Information. If we do, we will treat the combined information as Personal Information if it is combined.
We seek to use reasonable organizational, technical and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contacting Us” section below.
CHOICES AND ACCESS
Your choices regarding our use and disclosure of your Personal Information
We give you choices regarding our use and disclosure of your Personal Information for marketing purposes. You may opt-out from:
Receiving email marketing from us: If you no longer want to receive marketing-related emails from us on a going-forward basis, you may opt-out by following the instructions contained in each such email or by contacting us at firstname.lastname@example.org.
Receiving other types of marketing communications from us: If you no longer want to receive marketing-related communications from us on a going-forward basis, you may opt-out by contacting us at email@example.com.
Our sharing of your Personal Information with affiliates for their direct marketing purposes: If you would prefer that we discontinue sharing your Personal Information on a going-forward basis with our affiliates for their direct marketing purposes, you may opt-out of this sharing by contacting us at firstname.lastname@example.org.
Our sharing of your Personal Information with unaffiliated third parties for their direct marketing purposes: If you would prefer that we discontinue sharing your Personal Information on a going-forward basis with unaffiliated third parties for their direct marketing purposes, you may opt-out of this sharing by contacting us at email@example.com.
We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt-out of receiving marketing-related communications from us, we may still send you important administrative messages, from which you cannot opt-out.
HOW YOU CAN ACCESS, CHANGE OR DELETE YOUR PERSONAL INFORMATION
If you would like to request to review, correct, update, suppress, restrict or delete Personal Information that you have previously provided to us, or if you would like to request to receive an electronic copy of your Personal Information for purposes of transmitting it to another organization (to the extent this right to data portability is provided to you by applicable law), you may contact us using the “Contact Us” information below. We will respond to your request consistent with applicable law.
In your request, please make clear what Personal Information you would like to have changed, whether you would like to have your Personal Information suppressed from our database or otherwise let us know what limitations you would like to put on our use of your Personal Information. For your protection, we will only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.
Please note that we need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion (e.g., when you make a payment, you may not be able to change or delete the Personal Information provided until after the completion of such transaction).
If you are a resident of California, under 18 and a registered user of the Services, you may ask us to remove content or information that you have posted to the Services by writing to us at the Contact Us address below. Please note that your request does not ensure complete or comprehensive removal of the content or information, as, for example, some of your content may have been reposted by another user.
We retain Personal Information for as long as needed or permitted considering the purpose(s) for which it was obtained and consistent with applicable law.
The criteria used to determine our retention periods include:
The length of time we have an ongoing relationship with you and provide the Services to you (for example, for as long as you are a student of ours);
Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).
THIRD PARTY SERVICES
In addition, we are not responsible for the information collection, use, disclosure or security policies or practices of other organizations, such as Facebook, Apple, Google, Microsoft, RIM or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including with respect to any Personal Information you disclose to other organizations through or in connection with the Apps or our Social Media Pages.
THIRD PARTY ADVERTISING
We use third-party advertising companies to serve advertisements regarding goods and services that may be of interest to you when you access and use the Services and other websites or online services.
From Australia: http://www.youronlinechoices.com.au/
From Canada: https://youradchoices.ca/
From Europe: http://www.edaa.eu/
From the U.S.: http://optout.aboutads.info/#/ and http://optout.networkadvertising.org/#/.
If you are in the U.S., you may download the AppChoices app at www.aboutads.info/appchoices to opt out in mobile apps.
USE OF SERVICES BY MINORS
The Services are not directed to individuals under the age of sixteen (16), and we do not knowingly collect Personal Information from individuals under sixteen (16).
JURISDICTION AND CROSS-BORDER TRANSFER
Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services you understand that your information will be transferred to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Information.
If you are located in the European Economic Area (“EEA”): Some of the non-EEA countries are recognized by the European Commission as providing an adequate level of data protection according to EEA standards (the full list of these countries is available here). For transfers from the EEA to countries not considered adequate by the European Commission, we have put in place adequate measures, such as standard contractual clauses adopted by the European Commission to protect your Personal Information. You may obtain a copy of these measures by following this link.
THIRD PARTY PAYMENT SERVICE
ADDITIONAL INFORMATION FOR INDIVIDUALS IN THE EEA
If you are located in the EEA, you also may lodge a complaint with a data protection authority for your country or region or where an alleged infringement of applicable data protection law occurs.