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ACAMS ONLINE PRIVACY STATEMENT
ACAMS PRIVACY POLICY
Latest updated: January 2022
The Association of Certified Anti-Money Laundering Specialists (“ACAMS”, “we”,
or “us”) is headquartered in the United States and focused on promoting the
development and implementation of anti-money laundering policies and procedures.
It is the largest international membership organization dedicated to help
improve the professional knowledge, skills and experience of those dedicated to
the detection and prevention of money laundering around the world. ACAMS is a
subsidiary group company of Adtalem Global Education, Inc.
This Privacy Policy describes how we collect, use, process, and disclose your
personal information and the choices you can make about how we collect, use,
process, and disclose your personal information. This Privacy Policy applies to
information collected on this website, our digital properties, services we
offer, our events, certifications, e-certificates, webinars and seminars, and
anywhere the Policy is posted (collectively, our “Services”). If you reside or
are located in the European Economic Area ("EEA") or the United Kingdom (“UK”)
ACAMS is the data controller of all personal information collected via the
Services.
TABLE OF CONTENTS
Personal Information We Collect
How We Use the Personal Information Collected
Disclosing Personal Information
Cookies and Similar Technologies
Security
International Transfer of Personal information
Retention
Third-Party Websites
EEA and UK Data Subject Privacy Rights
China Data Subject Privacy Rights
Notice for Nevada Residents
Parents/Guardians
Changes to this Privacy Policy
How to Contact Us
Notice for California Residents
PERSONAL INFORMATION WE COLLECT
We collect personal information to provide and improve the Services we offer and
to communicate with you about our Service offerings. We collect personal
information in the following ways:
* Information you provide to us: We collect personal information you provide to
us as part of the Services, such as when you create an account with us, join
an ACAMS local chapter, obtain a certification, request informational
materials [or publications such as our white papers, or attend an event.
Examples of the type of information you may provide to us are:
* Personal information, such as your name, personal and professional mailing
address, email and phone number, and professional and educational history
* Payment and billing information
* Account or course login credentials
* Transaction details about purchases and the content of your communications
when you interact with our customer service team
* Information that you provide in community forums, in directories, on social
media, or in response to promotions and surveys, such as photos, comments,
and reviews
* Audio recordings from customer service calls
* Information collected automatically: We automatically collect and store
certain types of information about your use of the Services, such as through
the use of “cookies,” pixels and other tracking technologies. Examples of the
type of information we may collect automatically include:
* Course enrollment information, course access dates/times and course
completion data
* IP address of the device you are using
* Device ID
* Location of your device
* Browser type
* Internet service provider
* Audio recordings when you make customer service calls for quality and
training purposes
* Video recordings from CCTV security monitoring
* Content interaction information, such as files or content viewed, time
spent viewing content, and download information
* Information from other sources: We may receive information from other
sources, such as employers with enterprise accounts, testing centers, social
media, third-party platforms and forums, contacts, and business partners.
Examples of the type of information we may receive from other sources are:
* Personal information, such as your name, personal and professional mailing
address, email and phone number, and professional and educational history
* Testing attendance, identity verification documents, testing duration, and
test results
* Profile information, comments, and similar information provided to or on
social networks and other forums that connect to us
* Interests, demographic data, and purchasing behavior
* Offline data collection: We may collect information from you offline. For
example:
* When you attend a conference, event, or other in-person function.
* Over the phone, such as when we discuss donations and fundraising with you
Some of the information we collect may, when combined with other information, be
personal information that could be used to identify you. Such information is
treated as personal information.
You are responsible for ensuring the accuracy of personal information you
provide to us. Inaccurate information may affect your ability to use the
Services, the information you receive when using the Services, and our ability
to contact you.
Where we need to collect personal information by law, or under the terms of a
contract we have with you or in order to provide you with information you have
requested, and you do not provide this information when requested, we may be
prevented from complying with our legal obligations or we may not be able to
perform all or part of the contract we are entering into with you or provide you
with the information requested. For example, we require (a) certain information
under law in order to process payment, (b) certain information in order to
enroll you in a course, (c) your contact details in order to send you any
information you have requested.
HOW WE USE THE PERSONAL INFORMATION COLLECTED
We use, store, and process the personal information we collect to provide and
improve the Services, to support our business functions, as well as to
personalize, provide, measure and improve our advertising and marketing.
Some examples of how we use personal information include:
* To provide you with information, products, or services that you request from
us such as membership enrollment, managing certifications and
recertifications, and registration for online and in-person events (necessary
for the performance of our contract with you or otherwise in our legitimate
interests to provide you with the relevant information, products, or
services)
* To assess your eligibility for certain certifications and exams (necessary in
order for us to enter into a contract with you)
* For customer service and customer support purposes (our legitimate interests
in providing you with a good service and support)
* To carry out our obligations and enforce our rights arising from any
contracts entered into between you and us, including for billing and
collection activities (necessary for the performance of our contract with
you)
* To process payment or facilitate delivery of services requested (necessary
for the performance of our contract with you)
* To provide you with support and respond to your inquiries, such as to
investigate and address your concerns, and monitor and improve our responses
(our legitimate interests in providing you with support, responding to your
inquiries, and developing and improving our service)
* To manage your account and provide you with notices regarding the Services,
including expiration and renewal notices (necessary for the performance of
our contract with you or otherwise in our legitimate interests to provide you
with the relevant information, products, or services)
* To provide, personalize, measure, and improve our website experience and to
deliver content and product and service offerings based on your advertising
customization preferences (our legitimate interests in operating our website
and keeping it updated and relevant)
* To send you information about our products, services, and promotions (either
your consent (where applicable law requires us to obtain your consent for
marketing to you) or our legitimate interests in promoting our products and
services and growing our business)
* To administer promotional activities, such as surveys, sweepstakes, contests,
and referrals (either your consent where we request this or our legitimate
interests in running such activities in order to promote our business)
* To help maintain and improve the safety, security, and integrity of our
website and applications (our legitimate interests in maintaining network
security)
* For testing, research, analysis, and product development, such as to develop
and improve our websites, products and services, databases and other
technology assets, and offerings (our legitimate interests in developing our
business and product lines)
* To support our general business operations (our legitimate interests in
running and operating our business in a proper manner)
* As described to you when collecting your personal information to fulfill any
other purpose for which you provide it
DISCLOSING PERSONAL INFORMATION
We may disclose your personal information to other businesses or entities where
it is required in order for the performance of our contract with you, where it
is required by law, or where we have another legitimate interest in doing so, as
follows:
* To our parent organization only for use in the manner described in this
Privacy Policy;
* To service providers that perform services on our behalf, such as process
credit card payments, event planners and coordinators, data management and
storage providers, marketers and advertisers, analytics and research
companies, and professional advisors;
* To ACAMS chapter boards for communicating with its members;
* To law enforcement agencies, regulators, and courts in response to a court
order, subpoena, regulatory requirements or similar legal process, to report
any activities we reasonably believe to be unlawful, or as otherwise required
by law;
* To combat fraud or criminal activity, and to protect our rights, users, and
business partners, or as part of legal proceedings affecting ACAMS;
* To another entity in connection with a merger, transfer of data assets,
reorganization, divestiture, financing, dissolution, or similar corporate
event involving all or part of our business;
* To the public when we publish our graduate lists on our website (with your
consent); and
* Otherwise with your consent.
COOKIES AND SIMILAR TECHNOLOGIES
We, as well as third parties that provide content or other functionality for our
Services, may use cookies, pixel tags, local storage, and other technologies to
automatically collect information through the Services. These tracking
technologies are small data files downloaded to or stored on your computer,
tablet, mobile phone or other internet-enabled device that enable us to record
certain pieces of information whenever you visit or interact with our website,
applications, and tools. These technologies allow us to understand who has
interacted with us and also help us to operate our Services more efficiently.
These technologies also help us deliver online advertising to you.
* Cookies. Our website uses cookies that fall into the following categories:
Strictly Necessary, Functionality, Performance, Third-Party and Marketing and
Advertising. For more information on cookies, please read our Online Cookie
Policy.
* Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece
of code embedded on the website that collects information about users’
engagement on that web page. The use of a pixel allows us to record, for
example, that a user has visited a particular web page.
* Interest-based advertising. We permit third parties to use technologies on
our website to collect information about your device and your use of our
Services to advertise products and services to you that are tailored to your
perceived interests, as well as to provide advertising-related services such
as reporting, attribution, analytics and market research. Such third parties
may act on our behalf, and we may grant them the right to use your
information for their own purposes. For example, one such third party vendor,
Google, shows our ads and uses cookies to serve ads based on a user’s prior
visits to this website. We also use data analytics to serve ads based on a
user’s prior visits to this website. Click here for more information about
Google Ads.
* Analytics. We also use Google Analytics and Google Analytics Demographics and
Interest Reporting to collect information regarding visitor behavior and
visitor demographics for some of our Services and to develop content. Click
here for more information about Google Analytics.
* Social Media. This website may include social media features, such as
Twitter, Facebook, Instagram, LinkedIn, YouTube or other widgets. These
social media companies may recognize you and collect information about your
visit to our website, and they may set a cookie or employ other tracking
technologies. Your interactions with those features are governed by the
privacy policies of those companies.
Your Choices in Relation to Tracking and Online Advertising
* Users can visit Google Ad for more information about its settings.
* Users can visit Google Analytics for information on how to opt-out of Google
Analytics.
* To opt-out of third-party interest-based advertising from advertisers and
third parties that participate in certain self-regulatory programs, please
visiting the Network Advertising Initiative and the Digital Advertising
Alliance. Alternatively, you may opt-out of this advertising if you are
located in the European Union by visiting Your Online Choices. Opt-outs are
generally device and browser specific, meaning that you will need to opt-out
on each device and browser you use. Please note, even if you opt-out of
interest-based advertising, you will continue to receive generic ads.
* Users can manager their cookie preferences by utilizing the online cookie
preference center: Cookies Settings
* For California users, please see our California Notice at Collection and
Privacy Notice.
SECURITY
To help protect the privacy and security of your personal information we use
reasonable security measures, including administrative, technical, and physical
measures. These measures help protect against loss, misuse or unauthorized
access, disclosure, alteration or destruction of your personal information.
Additionally, we train our colleagues about the importance of confidentiality
and maintaining the privacy and security of your personal information.
While we do our best to protect your personal information, please be aware that
no security measures are perfect or impenetrable. If you know or have reason to
believe that your personal information has been lost, stolen, misappropriated,
or otherwise compromised, please see the final section of this policy for ways
to contact us.
INTERNATIONAL TRANSFER OF PERSONAL INFORMATION
ACAMS operates and processes personal information in multiple jurisdictions.
Personal information may be collected, used, disclosed, stored, and processed in
a jurisdiction other than where you reside or are located, including in the
United States where we are based and in other countries including Portugal,
United Kingdom, France, and Germany where the parties listed above are based for
the purposes outlined above. These jurisdictions may have data protection laws
that differ from your home jurisdiction. If you require further information
about this you can contact us on the contact details listed at the end of this
Privacy Policy.
RETENTION
We keep personal information for as long as necessary to fulfill the purposes
for which it was collected, including for the purposes of satisfying any legal,
regulatory, accounting or reporting requirements and our legitimate interests in
maintaining such personal information in our records. In doing this we will have
regard to the amount, nature, and sensitivity of the personal information, the
purposes for which we process your personal information and whether we can
achieve those purposes through other means, and applicable legal requirements.
THIRD-PARTY WEBSITES
Any links to third-party websites on our site are provided solely as a
convenience to you. We do not endorse or make any representations about these
websites or any products, materials, or services. Any personal information you
provide on these third-party websites is subject to the privacy practices and
policies of those sites. We do not accept any responsibility or liability for
the privacy practices or content of any websites or services that are not
operated by or for us.
EEA AND UK DATA SUBJECT PRIVACY RIGHTS
If you are an individual located in the EEA or UK, you have the following
rights:
* The right to request access to your personal information,
* The right to edit, correct, and update your personal information,
* The right to request erasure of your personal information,
* The right to restrict processing of your personal information,
* The right to object to the processing of your personal information,
* The right to data portability, and/or
* The right to withdraw your consent, to the extent that we have collected your
personal information based on your affirmative informed consent.
We will only use your personal information when the law allows us to. Most
commonly, we will use your personal information in the following circumstances
and as identified above:
* Where it is necessary for our legitimate interests. This can include
processing your personal information for the purposes of providing and
enhancing the provision of our Services, as well as advertising our products,
credentials, designations, services, and information to you
* Where we need to perform the contract we have entered into or are about to
enter with you
* Where we need to comply with legal obligations, resolve disputes, and enforce
our contractual agreements
* Where we have your express opt-in consent
If you wish to contact us in connection with the exercise of your rights listed
above, click here. Unless we notify you at the time of your request, we will not
charge any fee in connection with the exercise of your rights. You also have the
right to complain to or seek advice from a supervisory authority for data
protection issues and/or bring a claim against us in any court of competent
jurisdiction.
CHINA DATA SUBJECT PRIVACY RIGHTS
If you are an individual located in China, you have the following rights:
* The right to receive information related to your personal information,
* The right to access your personal information
* The right to correct and rectify your personal information,
* The right to erasure of your personal information,
* The right to object and restrict processing of your personal information,
* The right to data portability, as stipulated by the Cyberspace Administration
in China,
* The right not to be subject to automated decision-making
* The right to withdraw your consent, to the extent that we have collected your
personal information, based on your affirmative informed consent, and
* The right to lodge a complaint with the regulator in China.
We will only use your personal information when the law allows us to. Most
commonly, we will use your personal information in the following circumstances
and as identified above:
* When you have consented to the use of your personal information,
* Where it is necessary to enter into or perform a contract to which you are a
party, or where necessary to conduct human resources management according to
lawfully formulated internal labor policies and lawfully concluded collective
labor contracts.
* Where it is necessary to perform legal responsibilities or obligations.
* Where it is necessary to respond to a public health emergency, or in an
emergency, to protect the safety of your health and property.
* To a reasonable extent, for purposes of carrying out news reporting and media
monitoring for public interests.
* To process your personal information, which is already disclosed by you or
otherwise lawfully disclosed, within a reasonable scope, in accordance with
the Personal Information Protection Law in China (PIPL).
* Other circumstances as required by law.
If you wish to contact us in connection with the exercise of your rights listed
above, click here.
NOTICE FOR INDIVIDUALS IN NEVADA
If you are a Nevada resident, you can opt out of sales of certain covered
information that a website operator has collected or will collect about the
resident. You can opt-out by clicking Do Not Sell My Personal Information and
managing your preferences in the Cookies Settings
PARENTS/GUARDIANS
Our Services are not directed to children under the age of 16. We do not
knowingly collect any personal information from children under 16. If we become
aware that we have unknowingly collected personal information from a child under
the age of 16, and do not have parent or guardian consent on file, we will
endeavor to delete such personal information from our records. If you believe we
are incorrectly processing the personal information of a child under the age of
16, we recommend you contact us as provided in the final section of this policy.
CHANGES TO THIS PRIVACY POLICY
This Privacy Policy may be updated periodically. If we make material changes, we
will attempt to let you know via email or other communication. We encourage you
to periodically review this page for the latest information on our privacy
practices. As long as you continue to use the Services, you agree to this
Privacy Policy and any updates we make to it. We will not, however, use your
personal information in a manner that is materially different than what we
disclosed to you at the time the personal information was collected without your
consent.
HOW TO CONTACT US
If you have any questions or concerns about this Privacy Policy, contact us at:
Adtalem Global Education
500 W. Monroe Street
28th Floor
Chicago, IL 60661
Email Us: privacy@adtalem.com
CALIFORNIA NOTICE AT COLLECTION AND PRIVACY NOTICE
Last Updated: January 2022
This ACAMS California Notice at Collection and Privacy Notice (“California
Privacy Notice”) should be read in conjunction with the main ACAMS Privacy
Policy. This California Privacy Notice applies to information collected on this
website and anywhere the policy is posted (collectively, our “Services”). We
have adopted this notice pursuant to the California Consumer Privacy Act of 2018
(“CCPA”) and it applies only to residents of the State of California (“you”).
SCOPE
Some personal information we collect from you may not be covered by this
California Privacy Notice because certain personal information collection and
processing activities are exempt from the CCPA. Therefore, this California
Privacy Notice and the California privacy rights set out below may not apply to
you or to all of your personal information.
NOTICE AT COLLECTION
We may collect the following categories of personal information about :
* Identifiers, such as, name, postal address, email address, phone numbers,
online identifiers, IP address;
* California Customer Records, such as name, driver’s license or other photo
identification, postal address, phone numbers, employment, employment
history;
* Characteristics of Protected Classifications Under California or Federal Law,
such as, age, national origin, disability;
* Commercial Information, such as, products or services purchased or
considered, other purchasing or consuming tendencies;
* Internet or Other Electronic Network Activity, such as, browsing history,
search history, website or advertisement interaction;
* Geolocation Data, such as, IP address, physical location;
* Audio, Video and Other Electronic Data, such as, photos, call recordings, and
CCTV footage;
* Professional and Employment-related Information, such as, current or past job
history, business contact details, job title or employer; and
* Inferences, drawn from online activities and the other data listed in this
section such as a profile reflecting preferences, characteristics,
psychological trends, predispositions, behavior, attitudes, intelligence,
abilities, and aptitudes.
We may use your personal information for the following purposes:
* To provide you with information, products, or services that you request from
us
* To assess your eligibility for certain certifications and exams (necessary in
order for us to enter into a contract with you)
* For customer service and customer support purposes
* To carry out our obligations and enforce our rights arising from any
contracts entered into between you and us
* To process payment or facilitate delivery of services requested
* To provide you with support and respond to your inquiries, such as to
investigate and address your concerns, and monitor and improve our responses
* To manage your account and provide you with notices regarding the Services
* To provide, personalize, measure, and improve our website experience and to
deliver content and product and service offerings based on your advertising
customization preferences
* To send you information about our products, services, and promotions
* To administer promotional activities, such as surveys, sweepstakes, contests,
and referrals
* To help maintain and improve the safety, security, and integrity of our
website and applications
* For testing, research, analysis, and product development, such as to develop
and improve our websites, products and services, databases and other
technology assets, and offerings
* To support our general business operations
* As described to you when collecting your personal information or to fulfill
any other purpose for which you provide it
You can opt-out by clicking Do Not Sell My Personal Information and managing
your preferences in the Cookies Settings
COLLECTION, USE AND SHARING OF PERSONAL INFORMATION
This table sets out the categories of personal information that we have
collected from you, the sources from which we have obtained it, the purpose for
which we collect it and the categories of third parties and other entities with
whom we have shared it. It sets out our relevant practices over the last 12
months. Our collection, use and disclosure of personal information depends
on your relationship with us and your interaction with the Services.
Category of Personal Information
Categories of Sources
Identifiers, such as, name, postal address, email address, phone numbers, online
identifiers, or IP address.
* Directly from you
* Automatically, such as via cookies and other tracking technologies
* Our business partners and affiliates
* Third parties
* Your browser or device
* Social media and third-party platforms
California Customer Records, such as name, driver’s license or other photo
identification, postal address, phone numbers, employment, employment history
* Directly from you
* Our business partners and affiliates
* Third parties
Characteristics of Protected Classifications Under California or Federal Law,
such as age, national origin, or disability.
* Directly from you
* Our business partners and affiliates
Commercial Information, such as, products or services purchased or considered
and other purchasing or consuming tendencies.
* Directly from you
* Automatically, such as via cookies and other tracking technologies
* Our business partners and affiliates
Internet or Other Electronic Network Activity, such as, browsing history, search
history, or website or advertisement interaction.
* Directly from you
* Automatically, such as via cookies and other tracking technologies
* Our business partners and affiliates
* Your browser or device
* Social media and third-party platforms To provide, personalize, measure, and
improve our website experience
* To customize content
* For our marketing and advertising purposes
For testing, research, analysis, and product development
Geolocation Data, such as, IP address or physical location.
* Automatically, such as via cookies and other tracking technologies
* Your browser or device
Audio, Video and Other Electronic Data, such as, photos, call recordings, or
CCTV footage.
* Directly from you
* Our business partners and affiliates
Professional and employment-related information, such as current or past job
history, business contact details, job title, or employer.
* Directly from you
* Our business partners and affiliates
Inferences drawn from this information, such as, a profile reflecting
preferences, characteristics, psychological trends, predispositions, behavior,
attitudes, intelligence, abilities and aptitudes.
* Directly from you
* Automatically, such as via cookies and other tracking technologies
* Our business partners and affiliates
* Third parties
* Your browser or device
* Social media and third-party platforms
Category of Personal Information
Business or Commercial Purpose
Identifiers, such as, name, postal address, email address, phone numbers, online
identifiers, or IP address.
* To fulfill any other purpose for which you provide it
* To protect our rights and meet our legal obligations
* To provide you with support and respond to your inquiries
* To provide, personalize, measure, and improve our website experience
* To customize content
* For our marketing and advertising purposes
* For testing, research, analysis, and product development
* To support our general business operations
* Other uses about which we notify you
* To administer promotional activities, such as surveys, sweepstakes, contests,
and referrals
* To assess your eligibility for admission to certain institutions and programs
* For customer service and customer support purposes
* To analyze student performance
California Customer Records, such as name, driver’s license or other photo
identification, postal address, phone numbers, employment, employment history
* To fulfill your requests for products or services
* To fulfill any other purpose for which you provide it
* To protect our rights and meet our legal obligations
* To provide you with support and respond to your inquiries
* To support our general business operations
* Other uses about which we notify you
* To assess your eligibility for admission to certain institutions and programs
* For customer service and customer support purposes
Characteristics of Protected Classifications Under California or Federal Law,
such as age, national origin, or disability.
* To protect our rights and meet our legal obligations
Commercial Information, such as, products or services purchased or considered
and other purchasing or consuming tendencies.
* To fulfill your requests for products or services
* To provide you with support and respond to your inquiries
* To provide, personalize, measure, and improve our website experience
* To customize content
* For our marketing and advertising purposes
* For testing, research, analysis, and product development
* To support our general business operations
* For customer service and customer support purposes
* To analyze student performance
Internet or Other Electronic Network Activity, such as, browsing history, search
history, or website or advertisement interaction.
* To provide, personalize, measure, and improve our website experience
* To customize content
* For our marketing and advertising purposes
* For testing, research, analysis, and product development
Geolocation Data, such as, IP address or physical location.
* To provide, personalize, measure, and improve our website experience
* To customize content
* For our marketing and advertising purposes
* For testing, research, analysis, and product development
Audio, Video and Other Electronic Data, such as, photos, call recordings, or
CCTV footage.
* To fulfill your requests for products or services
* As security measures for our offices and campuses
* To protect our rights and meet our legal obligations
* To provide you with support and respond to your inquiries
* For our marketing and advertising purposes
* For customer service and customer support purposes
Professional and employment-related information, such as current or past job
history, business contact details, job title, or employer.
* To fulfill your requests for products or services
* To fulfill any other purpose for which you provide it
* For testing, research, analysis, and product development
* To support our general business operations
Inferences drawn from this information, such as, a profile reflecting
preferences, characteristics, psychological trends, predispositions, behavior,
attitudes, intelligence, abilities and aptitudes.
* To provide, personalize, measure, and improve our website experience
* To customize content
* For our marketing and advertising purposes
* For testing, research, analysis, and product development
* To support our general business operations
* Other uses about which we notify you
* To analyze student performance
Category of Personal Information
Categories of Third Parties and Other Entities With Whom We May Share
Identifiers, such as, name, postal address, email address, phone numbers, online
identifiers, or IP address.
* Our affiliates
* Our service providers and business partners
* Third parties
* As may be permitted or required by law, such as with law enforcement and
third parties pursuant to legal request or legal proceedings
* In connection with the sale or restricting of all our part of our business
* At your request or with your consent
California Customer Records, such as name, driver’s license or other photo
identification, postal address, phone numbers, employment, employment history
* Our affiliates
* Our service providers and business partners
* Third parties
* As may be permitted or required by law, such as with law enforcement and
third parties pursuant to legal request or legal proceedings
* In connection with the sale or restricting of all our part of our business
* At your request or with your consent
Characteristics of Protected Classifications Under California or Federal Law,
such as age, national origin, or disability.
* Our service providers and business partners
* Law enforcement and third parties pursuant to legal request or legal
proceedings, as may be permitted or required by law.
* As may be permitted or required by law, such as with law enforcement and
third parties pursuant to legal request or legal proceedings
* In connection with the sale or restricting of all our part of our business
* At your request or with your consent
Commercial Information, such as, products or services purchased or considered
and other purchasing or consuming tendencies.
* Our affiliates
* Our service providers and business partners
* As may be permitted or required by law, such as with law enforcement and
third parties pursuant to legal request or legal proceedings
* In connection with the sale or restricting of all our part of our business
* At your request or with your consent
Internet or Other Electronic Network Activity, such as, browsing history, search
history, or website or advertisement interaction.
* Our affiliates
* Our service providers and business partners
* Third parties
* As may be permitted or required by law, such as with law enforcement and
third parties pursuant to legal request or legal proceedings
* In connection with the sale or restricting of all our part of our business
* At your request or with your consent
Geolocation Data, such as, IP address or physical location.
* Our affiliates
* Our service providers and business partners
* Law enforcement and third parties pursuant to legal request or legal
proceedings, as may be permitted or required by law.
* As may be permitted or required by law, such as with law enforcement and
third parties pursuant to legal request or legal proceedings
* In connection with the sale or restricting of all our part of our business
* At your request or with your consent
Audio, Video and Other Electronic Data, such as, photos, call recordings, or
CCTV footage.
* Our affiliates
* Our service providers and business partners
* Law enforcement and third parties pursuant to legal request or legal
proceedings, as may be permitted or required by law.
* As may be permitted or required by law, such as with law enforcement and
third parties pursuant to legal request or legal proceedings
* In connection with the sale or restricting of all our part of our business
* At your request or with your consent
Professional and employment-related information, such as current or past job
history, business contact details, job title, or employer.
* Our affiliates
* Our service providers and business partners
* As may be permitted or required by law, such as with law enforcement and
third parties pursuant to legal request or legal proceedings
* In connection with the sale or restricting of all our part of our business
* At your request or with your consent
Inferences drawn from this information, such as, a profile reflecting
preferences, characteristics, psychological trends, predispositions, behavior,
attitudes, intelligence, abilities and aptitudes.
* Our affiliates
* Our service providers and business partners
* Third parties
* As may be permitted or required by law, such as with law enforcement and
third parties pursuant to legal request or legal proceedings
* In connection with the sale or restricting of all our part of our business
* At your request or with your consent
Category of Personal Information
Categories of Sources
Business or Commercial Purpose
Categories of Third Parties and Other Entities With Whom We May Share
Identifiers, such as, name, postal address, email address, phone numbers, online
identifiers, or IP address.
* Directly from you
* Automatically, such as via cookies and other tracking technologies
* Our business partners and affiliates
* Third parties
* Your browser or device
* Social media and third-party platforms
* To fulfill any other purpose for which you provide it
* To protect our rights and meet our legal obligations
* To provide you with support and respond to your inquiries
* To provide, personalize, measure, and improve our website experience
* To customize content
* For our marketing and advertising purposes
* For testing, research, analysis, and product development
* To support our general business operations
* Other uses about which we notify you
* To administer promotional activities, such as surveys, sweepstakes, contests,
and referrals
* To assess your eligibility for admission to certain institutions and programs
* For customer service and customer support purposes
* To analyze student performance
* Our affiliates
* Our service providers and business partners
* Third parties
* As may be permitted or required by law, such as with law enforcement and
third parties pursuant to legal request or legal proceedings
* In connection with the sale or restricting of all our part of our business
* At your request or with your consent
California Customer Records, such as name, driver’s license or other photo
identification, postal address, phone numbers, employment, employment history
* Directly from you
* Our business partners and affiliates
* Third parties
* To fulfill your requests for products or services
* To fulfill any other purpose for which you provide it
* To protect our rights and meet our legal obligations
* To provide you with support and respond to your inquiries
* To support our general business operations
* Other uses about which we notify you
* To assess your eligibility for admission to certain institutions and programs
* For customer service and customer support purposes
* Our affiliates
* Our service providers and business partners
* Third parties
* As may be permitted or required by law, such as with law enforcement and
third parties pursuant to legal request or legal proceedings
* In connection with the sale or restricting of all our part of our business
* At your request or with your consent
Characteristics of Protected Classifications Under California or Federal Law,
such as age, national origin, or disability.
* Directly from you
* Our business partners and affiliates
* To protect our rights and meet our legal obligations
* Our service providers and business partners
* Law enforcement and third parties pursuant to legal request or legal
proceedings, as may be permitted or required by law.
* As may be permitted or required by law, such as with law enforcement and
third parties pursuant to legal request or legal proceedings
* In connection with the sale or restricting of all our part of our business
* At your request or with your consent
Commercial Information, such as, products or services purchased or considered
and other purchasing or consuming tendencies.
* Directly from you
* Automatically, such as via cookies and other tracking technologies
* Our business partners and affiliates
* To fulfill your requests for products or services
* To provide you with support and respond to your inquiries
* To provide, personalize, measure, and improve our website experience
* To customize content
* For our marketing and advertising purposes
* For testing, research, analysis, and product development
* To support our general business operations
* For customer service and customer support purposes
* To analyze student performance
* Our affiliates
* Our service providers and business partners
* As may be permitted or required by law, such as with law enforcement and
third parties pursuant to legal request or legal proceedings
* In connection with the sale or restricting of all our part of our business
* At your request or with your consent
Internet or Other Electronic Network Activity, such as, browsing history, search
history, or website or advertisement interaction.
* Directly from you
* Automatically, such as via cookies and other tracking technologies
* Our business partners and affiliates
* Your browser or device
* Social media and third-party platforms To provide, personalize, measure, and
improve our website experience
* To customize content
* For our marketing and advertising purposes
For testing, research, analysis, and product development
* To provide, personalize, measure, and improve our website experience
* To customize content
* For our marketing and advertising purposes
* For testing, research, analysis, and product development
* Our affiliates
* Our service providers and business partners
* Third parties
* As may be permitted or required by law, such as with law enforcement and
third parties pursuant to legal request or legal proceedings
* In connection with the sale or restricting of all our part of our business
* At your request or with your consent
Geolocation Data, such as, IP address or physical location.
* Automatically, such as via cookies and other tracking technologies
* Your browser or device
* To provide, personalize, measure, and improve our website experience
* To customize content
* For our marketing and advertising purposes
* For testing, research, analysis, and product development
* Our affiliates
* Our service providers and business partners
* Law enforcement and third parties pursuant to legal request or legal
proceedings, as may be permitted or required by law.
* As may be permitted or required by law, such as with law enforcement and
third parties pursuant to legal request or legal proceedings
* In connection with the sale or restricting of all our part of our business
* At your request or with your consent
Audio, Video and Other Electronic Data, such as, photos, call recordings, or
CCTV footage.
* Directly from you
* Our business partners and affiliates
* To fulfill your requests for products or services
* As security measures for our offices and campuses
* To protect our rights and meet our legal obligations
* To provide you with support and respond to your inquiries
* For our marketing and advertising purposes
* For customer service and customer support purposes
* Our affiliates
* Our service providers and business partners
* Law enforcement and third parties pursuant to legal request or legal
proceedings, as may be permitted or required by law.
* As may be permitted or required by law, such as with law enforcement and
third parties pursuant to legal request or legal proceedings
* In connection with the sale or restricting of all our part of our business
* At your request or with your consent
Professional and employment-related information, such as current or past job
history, business contact details, job title, or employer.
* Directly from you
* Our business partners and affiliates
* To fulfill your requests for products or services
* To fulfill any other purpose for which you provide it
* For testing, research, analysis, and product development
* To support our general business operations
* Our affiliates
* Our service providers and business partners
* As may be permitted or required by law, such as with law enforcement and
third parties pursuant to legal request or legal proceedings
* In connection with the sale or restricting of all our part of our business
* At your request or with your consent
Inferences drawn from this information, such as, a profile reflecting
preferences, characteristics, psychological trends, predispositions, behavior,
attitudes, intelligence, abilities and aptitudes.
* Directly from you
* Automatically, such as via cookies and other tracking technologies
* Our business partners and affiliates
* Third parties
* Your browser or device
* Social media and third-party platforms
* To provide, personalize, measure, and improve our website experience
* To customize content
* For our marketing and advertising purposes
* For testing, research, analysis, and product development
* To support our general business operations
* Other uses about which we notify you
* To analyze student performance
* Our affiliates
* Our service providers and business partners
* Third parties
* As may be permitted or required by law, such as with law enforcement and
third parties pursuant to legal request or legal proceedings
* In connection with the sale or restricting of all our part of our business
* At your request or with your consent
HOW WE SHARE PERSONAL INFORMATION
In the last twelve months, we have disclosed each of the categories of personal
information listed above for business purposes, as set out above.
SALES OF PERSONAL INFORMATION
We disclose the following categories of personal information to event sponsors
for them to use for their own marketing purposes. Such disclosures may be
considered a sale for purposes of the CCPA.
* Identifiers
We also disclose the following categories of personal information to third-party
cookie and other ad-tech providers, who may further disclose your information
throughout the digital advertising ecosystem. Such disclosures may be considered
a sale for purposes of the CCPA.
* Identifiers
* Internet or other electronic activity information
* Geolocation data
* Inferences drawn from personal information such as preferences,
characteristics and behaviors.
CALIFORNIA PRIVACY RIGHTS
To the extent provided for by law and subject to applicable exemptions, you have
the following rights in relation to the personal information about you that we
have collected:
Right to Know: You have the right to request the following information relating
to our collection and use of your personal information over the past 12 months:
* Categories of personal information we have collected about you;
* Categories of sources of the personal information we collected about you;
* Business and/or commercial purposes for collecting or, if applicable, selling
that personal information;
* Categories of third parties to whom we have disclosed or sold that personal
information;
* Specific pieces of personal information we have collected about you;
* Categories of personal information that we have disclosed or sold to a third
party for a business purpose; and
* Categories of third parties to whom the residents’ personal information was
sold.
Right to Delete: You have the right to request that we delete your personal
information. Subject to certain exceptions, we will endeavor to delete your
personal information and direct any service provider to delete your personal
information.
Right to Opt-Out: You have the right to direct us not to sell your personal
information. If you are under the age of 16, you have the right to opt in, or to
have a parent or guardian opt in on your behalf, to such sales.
Right to Non-Discrimination: You have the right not to receive discriminatory
treatment for exercising any of the rights described above.
TO EXERCISE YOUR RIGHT TO KNOW OR RIGHT TO DELETION
Right to Know: California residents may make up to two requests to know within a
12-month period. If you would like to exercise your rights, you can fill out
our online webform or call us 1-866-653-5656.
Right to Deletion: California residents may fill out our online webform or call
us at 1-866-653-5656 to request that we delete your personal information.
Verification: We will need to verify your identity before processing your
request. In order to verify your identity, we will generally either require you
to login to your account or we must be able to match certain information you
provide us to the information we maintain about you. Certain requests may
require us to obtain additional personal information from you. In certain
circumstances, we may decline a request to exercise the right to know and/or
right to deletion, particularly where we are unable to verify your identity or
locate your information in our systems, or as permitted by law.
TO EXERCISE YOUR RIGHT TO OPT-OUT
You can opt-out by clicking Do Not Sell My Personal Information and managing
your preferences in the Cookies Settings
MINORS UNDER AGE 16
We do not “sell” the personal information of consumers we know to be under 16
years of age.
REQUESTS SUBMITTED BY AUTHORIZED AGENTS
In certain circumstances, you are permitted to use an authorized agent, as that
term is defined by the CCPA (“Authorized Agent”), to submit requests on your
behalf where you provide sufficient evidence that the requestor is an authorized
agent with written permission to act on your behalf and you successfully verify
your own identity with us. An Authorized Agent can make a request on a
California resident’s behalf by:
* For requests to know and delete: (1) providing a valid power of attorney
under the laws of California; or (2) providing sufficient evidence to show
that the California resident has (i) provided the Authorized Agent signed
permission to act on their behalf, (ii) verified their own identity directly
with us, and (iii) directly confirmed with us that they have provided the
Authorized Agent permission to submit the request on their behalf.
* For requests to opt out: submitting a signed permission demonstrating that
the Authorized Agent has been authorized by the California resident to act on
their behalf.
NOTICE OF FINANCIAL INCENTIVES
From the time to time, we may run sweepstakes, contests, or other offers and
promotions (collectively, “Programs”) that may be deemed “financial incentives”
in relation to our collection of personal information under CCPA. a business may
offer financial incentives for the collection, sale or deletion of California
residents’ personal information, provided it is not unjust, unreasonable,
coercive or usurious, and is made available in compliance with applicable
transparency, informed consent, and opt-out requirements. We may run sweepstakes
or contests from time to time. Please refer to the terms and conditions of each
Program for additional information about the Program, including how eligible
consumers can opt-in or opt-out of the Program at any time. In order to enter a
Program, you may be required to provide us or a service provider acting on our
behalf with certain personal information, such as identifiers including your
name and contact information (“Rewards Data”). If you submit your entry in
accordance with the applicable Program’s rules, you may be entered into the
Program and will get a chance to win a prize or receive another benefit from us.
The value of Rewards Data is related to the value of your information and the
costs associated with offering the Program.
CALIFORNIA “SHINE THE LIGHT”
In addition to the rights described above, California’s “Shine the Light” law
permits California residents to request certain information regarding our
disclosure, if any, of certain categories of personal information to third
parties for their direct marketing purposes during the immediately preceding
calendar year. To make such a request, please send an email
to privacy@adtalem.com. This request may be made no more than once per calendar
year.
DO NOT TRACK
Some web browsers may transmit “do-not-track” signals to websites with which the
user communicates. We honor and respond to “do-no-track” signals.
CHANGES TO THIS PRIVACY NOTICE
This California Privacy Notice may be updated periodically. If we make material
changes, we will attempt to let you know via email or other communication. We
encourage you to periodically review this page for the latest information on our
privacy practices. As long as you continue to use the Services, you agree to
this California Privacy Notice and any updates we make to it. We will not,
however, use your personal information in a manner that is materially different
than what we disclosed to you at the time the personal information was collected
without your consent.
HOW TO CONTACT US
If you have any questions or concerns about this California Privacy Notice,
contact us at:
Adtalem Global Education
500 W. Monroe Street
28th Floor
Chicago, IL 60661
Email Us: privacy@adtalem.com
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