Notice to California Residents
The California Consumer Privacy Act, as amended by the California Privacy Rights Act of 2020 (“CCPA”), requires that we provide California residents with a privacy policy that contains a comprehensive description of our online and offline practices regarding the collection, use, disclosure, sale, sharing, and retention of personal information and of the rights of California residents regarding their personal information. This section of the Privacy Policy is intended solely for, and is applicable only as to, California residents. If you are not a California resident, this section does not apply to you and you should not rely on it.
The CCPA defines “personal information” to mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. Personal information does not include publicly available, deidentified or aggregated information or lawfully obtained, truthful information that is a matter of public concern.
This notice is intended to address both visitors to our website as well as the students and/or prospective students from which we may gather information in performing the Services.
Notice at Collection of Personal Information
We currently collect and have collected the following categories of personal information:
- Contact information
- Student and School Information
- Application Information
- Scholarship/Financial Aid Information
We collect personal information directly from California residents and from the following:
- The School to which you are applying and/or from which you are seeking information.
- References in an application for admission or scholarships.
- Government agencies for the purposes of financial aid or confirming residency.
We currently collect and have collected the above categories of personal information for the following business or commercial purposes:
- Providing, maintaining, and improving our services.
- Communicating with you and personalizing your experience.
- Fulfilling any purpose for which you consented to provide the data.
- In compliance with legal obligations, and to protect against fraud and misuse of our Services.
- Marketing purposes, and to analyze our service usage.
- Performing research to direct business operations or guide marketing activities.
- To protect the security and integrity of our services.
- To monitor compliance with policies and applicable agreements, defend our rights and others, and comply with applicable law.
- Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.
- Helping to ensure security and integrity to the extent the use of your personal information is reasonably necessary and proportionate for these purposes.
- Debugging to identify and repair errors that impair existing intended functionality.
- Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services.
- Providing advertising and marketing services, except for cross-context behavioral advertising, to you provided that, for the purpose of advertising and marketing, our service providers and/or contractors shall not combine the personal information of opted-out consumers that the service provider or contractor receives from us, or on our behalf with personal information that the service provider or contractor receives from, or on behalf of, another person or persons or collects from its own interaction with you.
- Undertaking internal research for technological development and demonstration.
- Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us.
Sale, Sharing, and Disclosure of Personal Information
The CCPA defines "sale" as the transfer of personal information for monetary or other valuable consideration. Although we do not "sell" personal information as that term may be commonly interpreted, we engage in online activities that may constitute a sale or a share of personal information under California law. This may include showing you advertisements on other websites.
The following table identifies categories of such personal information:
| Category of Personal Information | Categories of Recipients |
|---|---|
| Unique personal identifiers (device identifier; cookies, beacons, pixel tags, mobile ad identifiers, or other similar technology; customer number, unique pseudonym or user alias; telephone numbers, or other forms of persistent or probabilistic identifiers that can be used to identify a particular consumer or device) | Advertising network; data analytics provider |
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The following recipients will only receive the stated categories of personal information based on the particular business purpose of the relationship:
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We disclosed personal information for the following business or commercial purposes:
- Providing, maintaining, and improving our services.
- Communications with you and personalizing your experience.
- Marketing purposes, and to analyze our service usage.
- Performing research to direct business operations or guide marketing activities.
- In compliance with legal obligations, and to protect against fraud and misuse of our Services.
Retention of Personal Information
We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax, or accounting requirements). When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
Your Rights
If you are a California resident, you have the following rights with respect to your personal information:
- The right to know what personal information we have collected about you, including the categories of personal information, the categories of sources from which we collected personal information, the business or commercial purpose for collecting, selling or sharing personal information (if applicable), the categories of third parties to whom we disclose personal information (if applicable), and the specific pieces of personal information we collected about you.
- The right to delete personal information that we collected from you, subject to certain exceptions.
- The right to correct inaccurate personal information that we maintain about you.
- If we sell or share personal information, the right to opt out of the sale or sharing.
- If we use or disclose sensitive personal information for purposes other than those allowed by the CCPA and its regulations, the right to limit our use or disclosure.
- The right not to receive discriminatory treatment by us for the exercise of privacy rights the CCPA confers.
How to Submit a Request to Know, Delete, and/or Correct
You may submit a request to know, delete, and/or correct by contacting us as described below in this Privacy Policy.
If you submit a request to delete online, you may be asked to confirm separately that you want your personal information deleted.
If you are submitting a request on behalf of a California resident, please submit the request through one of the designated methods. After submitting the request, and if the request is not subject to an exemption or exception, we will require additional information to verify your authority to act on behalf of the California resident.
Our Process for Verifying a Request to Know, Delete, and/or Correct
We will comply with your request upon verification of your identity and, to the extent applicable, the identity of the California resident on whose behalf you are making such request. Our verification process may differ depending on whether you maintain a password-protected account with us.
If you maintain a password-protected account, we may verify your identity through existing authentication practices available through your account. Prior to disclosing or deleting the personal information, we will ask you to re-authenticate yourself with respect to that account.
If you do not maintain a password-protected account, or if you are an account-holder but we suspect fraudulent or malicious activity with your account, we will verify your identity either to a “reasonable degree of certainty” or a “reasonably high degree of certainty” depending on the sensitivity of the personal information and the risk of harm to you by unauthorized disclosure, deletion, or correction as applicable. To do so, we will ask you to verify data points based on information we have in our records concerning you.
Right to Opt Out of Sale or Sharing of Personal Information
If you are a California resident, you have the right to submit a request to opt out of sales or sharing by contacting us as described below in this Privacy Policy.
Right to Limit Use and Disclosure of Sensitive Personal Information
California residents have the right to limit our use or disclosure of their sensitive personal information for purposes other than those allowed by the CCPA and its regulations. You may submit a request to limit our use or disclosure of your sensitive personal information by contacting us as described below in this Privacy Policy.
Updates to this Notice
We may update this notice periodically. We will notify you of any changes by posting the new policy on this page. You are advised to review this notice periodically for any changes.
Contact Information
If you have any questions about this Privacy Policy, please contact us via email at [email protected].
To report a security issue or discovered vulnerability, please email [email protected] with a description of the issue, the steps you took to create the issue, and if known, mitigations for the issue. Our vulnerability management team will review all reports and acknowledge receiving your email.
To exercise your rights or choices regarding data access, correction, or deletion you may submit a request to [email protected].