Privacy Policy

Effective Date: January 31, 2021

Last Revised: July 31, 2021

The Personal Information We Collect and How We Use It

We collect personal information as defined in the CCPA, which generally means any information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device. Please note that personal information does not include the following:

  • Publicly available information that we access from government records;
  • Deidentified or aggregated consumer information; and
  • Other information that is expressly excluded from the CCPA’s scope such as personal information covered by certain sector-specific privacy laws, such as the Fair Credit Reporting Act, the Gramm-Leach-Bliley Act, the Health Insurance Portability and Accountability Act, or the Driver’s Privacy Protection Act of 1994.

The table below describes the categories of personal information we collect, the categories of sources of thatinformation, and our business or commercial purpose for collecting the information, all with respect to the last 12 months.

Where we say above that we collect information so that we can operate our business and provide services to you and to others, we mean that we use the information for one or more of the following purposes:

  • To create, maintain, customize, and secure our students’ online enrollment.
  • To provide, support, personalize, and develop our services.
  • To launch, maintain, and improve programs.
  • To contact prospective, current, and former students regarding programs.
  • To research, design, and develop programs and course offerings.
  • To market programs and courses.
  • To recruit, support, retain, and place students.
  • To assess the effectiveness of our outreach and marketing efforts.

In addition to the business purposes of collection of personal information described above, we may use any of the personal information we collect for the following purposes:

  • To prevent transaction or user fraud, and to help maintain the safety, security, and integrity of the Site and our and our Partner School’s business.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets in which personal information held by use about our Site users is among the assets transferred.
  • As otherwise described to you when collecting your personal information.

We will not use the personal information we have collected for any materially different, unrelated, or incompatible purposes not disclosed in this California Privacy Notice without providing you notice and, if required by the CCPA, the opportunity to consent to such use.

How and Why We Share Personal Information

Disclosures of Personal Information for a Business Purpose

With respect to the personal information we have collected, in the past 12 months we have shared information in the following categories (which are listed by reference to the categories identified above) with third parties, in each case for a business or commercial purpose:

  • Category 1 – Identifiers

  • Category 2 – Personal information categories listed in the California Consumer Records statute (Cal. Civ. Code §1798.80(e))

  • Category 3 – Protected classification characteristics under California or Federal law

  • Category 9 – Professional or employment-related information

  • Category 10 – Non-public education information (per the Family Educational Rights and Privacy Act, 20 U.S.C. §1232g, 34 C.F.R. Part 99

  • Category 11 – Inferences drawn from other personal information

The categories of third parties with whom we share this information (other than our contracted service providers as described below) are the State Agencies we report to, regulators, your employer (if your employer is paying for your enrollment in a program), and our business partners.

In addition to the above, we also share personal information in the categories identified above with our service providers, such as companies who handle our data management and/or email distribution, parties who provide us with data enrichment services, our website and infrastructure hosting providers and our managed information technology support service provider, and also to third parties to whom you authorize us to disclose your personal information in connection with our services.

Other Disclosures of Personal Information

In addition, you should be aware that we may share information with third parties in the following circumstances:

  • We may disclose non-personal, aggregate, anonymous data in a de-identified format for any legitimate business purpose.

  • We may disclose personal information at the request of law enforcement or government agencies or in response to subpoenas, court orders, or other legal processes to establish, protect, or exercise our legal or other rights or to defend against a legal claim, or as otherwise required or allowed by law.

  • We may disclose personal information if we believe that such action is appropriate to (a) protect the rights, property, or safety of a user of the Site or any other person, (b) investigate or prevent a violation by you of any contractual or other relationship with us or our Partner School, (c) investigate or prevent your actual or potential illegal, fraudulent, or harmful activity, or (d) detect, prevent, or otherwise address fraud, security, or technical issues.

  • We may share information, including personal information, in connection with, during negotiations of, or as a part of the closing of any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

Sales of Personal Information

We will never sell your personal information.

How Long We Keep Personal Information

We will keep your Personal Information as long as we have a business need to do so and/or as necessary to meet the purpose for which the information was collected and used, unless a longer period is required by law. For example, we will keep Personal Information for at least as long as you continue to be enrolled in any Program. And, if any Site allows you to create an account, we will keep the Personal Information associated with your account for as long as you maintain it. Business needs for which Personal Information may be retained include legal, tax, accounting, risk management, and other business purposes.

Photos and Videos

It is important to note that some information may be made public. For example, with your consent we may use your image and testimonials in promotional materials. Accordingly, your information will be able to be seen and republished for as long as the marketing materials continue to be posted online, or as long as the hard copies remain in existence. In these cases, once posted the information will be able to be seen and republished by others for as long as the web page/social media account remains active. Even if web pages are deleted, they may continue to be accessed if they are archived or cached. Therefore, you should think carefully before giving your consent to the use of your name, image, and comments in any materials and, if applicable, before posting anything in any public area.

California Consumers' Rights and Choices

The CCPA provides California residents with specific rights regarding their personal information. If you are a California resident, this section describes your CCPA rights, and explains how to exercise them.

Rights to Access Certain Information

You have the right to ask us to provide you with information about our collection and use of your personal information over the past 12 months. You may request the following information:

  1. The categories of personal information we collect about you;

  2. The categories of sources of personal information we collect about you;

  3. Our business purpose for collecting that personal information’

  4. The categories of third parties with whom we share that personal information;

  5. The specific pieces of personal information we collected about you (also called a “data portability right”);

Rights to Request Deletion of Certain Information

You have the right to ask us to delete any of your personal information that we collected from you and have retained. However, there are certain exceptions to our obligation to delete the information, which we describe below.

We may deny your deletion request if we or our service providers need to keep the information to:

  • Complete the transaction for which we collected the personal information, provide you with a product orservice you have requested, take other actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract with you;

  • Detect security incidents, protect against illegal or fraudulent behavior, or engage in legal actions with persons responsible for such activities;

  • Debug products to identify and repair errors impacting the functionality of our Site or services;

  • Exercise free speech or ensure other consumers’ rights to free speech, or otherwise exercise rights provided by law;

  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code §1546)

  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent;

  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;

  • Comply with a legal obligation; or

  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

How to Submit a Verifiable Consumer Request and Exercise Your Rights

To exercise any of the rights described above, you must submit a verifiable consumer request to us by either:

Only you, or a person registered with the California Secretary of State that you expressly authorize to act on your behalf, can make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within any 12-month period. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify that you are the person about whom we

  • requested personal information, or are an authorized representative of that person, which may include (by way of example, but not limited to) verification of your current address, Student ID, date of birth, email address, or telephone number; and

  • Describe your request with sufficient detail that enables us to understand, evaluate, and respond to it.

** We cannot respond to your request or provide you with information if we cannot identify you or confirm your authority to make the request.

** We will only use any personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

How and When We Will Respond to Verifiable Consumer Requests

We will confirm receipt of a verifiable consumer request within 10 days, and with that confirmation, we will include a description of our verification process and will provide an expected response timeframe. Generally, we will respond to each verifiable consumer request within 45 days of receipt. If we require more time, subject to the limitations imposed by the CCPA, we will inform you of the reason and extension period in writing.

We will deliver our written response by mail or electronically using the contact information you have provided. Any disclosure we provide in response will only cover the 12-month period preceding our receipt of the request. If we cannot comply with your request, we will explain why. If you request that we provide you with a copy of your data, we will select a format in which to provide your personal information that is readily usable, and should allow you to transmit the information from one entity to another without undue difficulty.

We do not generally charge a fee to process or respond to requests, unless the request is excessive, repetitive, or manifestly unfounded. If we determine that a fee is warranted by the circumstances, we will tell you why, and will provide you with a cost estimate before completing your request.

Changes to this California Privacy Notice

Because of changes in Internet technology and practices, this California Privacy Notice may change from time to time. We will post any changes we make to this California Privacy Notice on this page, and any changes will be effective once the new notice is posted. It is your responsibility to check this for updates.

By using the Site after we post any changes to this California Privacy Notice, you agree to accept those changes, whether or not you have reviewed them.