Effective Date: December 1, 2018
ABC respects your privacy, and is committed to protecting your personal information from unauthorized use or disclosure.
COLLECTION OF PERSONAL INFORMATION
ABC may collect your personal information through one or more of the following methods:
- Personal Information You Provide. ABC may collect personal information when you register as a user of our website, sign up for or use our admission services, enroll in our marketing programs, contact us about a prior admission registration, use our mobile application, or email, call, or otherwise communicate with us. No personal information is gathered about you when you visit our web site, unless you voluntarily provide information to us (through an information request, registering an account, or providing information on an application). For example, if you contact us regarding admission registration, we may request that you provide personal information that will enable us to respond to your inquiry. If you do not provide such information, we may not be able to respond to your inquiry, or your participation in our programs may be limited.
- Automatically Collected Personal Information. When you register for or use our admission services, transactional information such as the date of your application, registration, or service usage, their descriptions, and the dollar amount or value of the application may be collected automatically. We treat all such automatically collected information as personal information if we combine it with or link it to other information that may identify you.
- Other Information. We may obtain information about you from third parties such as demographic marketing information, address verification, or mailing list information and combine it with other personal information pertaining to you.
OUR USE OF PERSONAL INFORMATION
ABC may use your personal information for a variety of purposes, including:
- Responding to your comments, requests, and questions;
- Processing and completing your application requests, including the delivery of your personal information to the academic institutions that you indicate or confirming application data;
- Attempting to contact you regarding application request issues;
- Sending you technical notices, updates, security alerts, and support and administrative messages;
- Verifying your identity;
- Keeping a record of our interactions with you if you place an application request or otherwise deal with our representatives over the telephone or online;
- Conducting statistical and demographic analysis;
- Preventing, investigating, or providing notice of fraud, unlawful or criminal activity, or unauthorized access to or use of personal information, our website or data systems, or to meet legal obligations;
- Protecting and defending ABC and its affiliates against legal actions or claims;
- Collecting debts;
- Satisfying contractual obligations;
- Evaluating your application request;
- Cooperating with law enforcement or other government agencies for purposes of national security, public safety, or matters of public importance when we believe that disclosure of information is necessary or appropriate to protect the public interest or as otherwise required by law;
- Conducting market research, surveys, and similar inquiries to help us understand trends and customer needs across service categories or customer groups;
- Evaluating and improving your application experience, online experience, or existing services, or to create new services;
- Communicating specials and discounts via email;
- Applying discounts for any marketing program specials when you apply;
- Monitoring and analyzing trends, usage, and activities; and
When it is possible to do so, we may link personal information (such as your name or e-mail address) with non-personal information (such as the unique identifier associated with your computer or mobile device). We may also link personal information with other generally or publicly available information to help us identify your preferences or interests. The information we collect may also be merged with information available from other sources such as (1) companies that match e-mail addresses with postal addresses and other information; (2) credit card verification and credit services; and (3) our affiliates.
DISCLOSURE OF PERSONAL INFORMATION
- With Your Consent. We may disclose your personal information to select academic institutions and other third parties with your consent. You may give your consent in several ways, such as through a written agreement that you sign or acknowledge; an online method, such as a “click-through” agreement or registration page; an oral statement, such as by way of an interactive voice response or orally authorized consent during a phone call; or through the terms and conditions under which we provide you with application requests. Sometimes your consent may be implicit. For example, if you complete an application request with a credit card, you implicitly consent to the disclosure of your name and credit card number to the credit card processor to authorize the transaction.
- Service Providers. We may disclose your personal information to third parties who complete transactions or perform services on our behalf or for your benefit. Information provided to such parties for payment authorization (including PayPal, Payeezy, and credit card information processors) or verification purposes may be retained by them in a database that is used to provide similar services to others. We may also utilize the services of third parties to verify customer data, such as mailing addresses or to supplement other information we have collected. We may also contract with third parties to host a website, retain customer data, conduct market research, or send you information regarding our services, or those of other companies with whom we conduct business.
- Legal Process. We may disclose your personal information to legal or government regulatory authorities in response to their requests for such information or to assist in investigations of theft, fraud, or abuse. We may also disclose your personal information to third parties in connection with claims, disputes, or litigation, or if we determine its disclosure is necessary in an emergency. This may include the disclosure of IP addresses, mobile device identifiers, or other information collected by us, with or without notice to you.
- Certain Business Transfers. Your personal information may be disclosed as part of an actual or proposed corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets, and could be transferred to a third party as one of the business assets in such a transaction. It may also be disclosed in the event of insolvency, bankruptcy, or receivership.
We may also ask you for financial information for payment purposes, including your billing name; billing address; credit, debit, bank card or PayPal account information; or any other information that we, in our sole discretion, deem appropriate (“Payment Information”). We will not store your Payment Information on our database. Once you provide us with your Payment Information, we will forward the information to our third party payment processor, who will only use your Payment Information to process your payment of the ordered products.
INFORMATION PERTAINING TO CHILDREN
ABC is the only operator of its website, and its contact information is listed in the “How to Contact Us” section below. ABC does not knowingly or intentionally collect personal information from children under the age of 13, and has taken steps to avoid doing so through its website. Accordingly, ABC does not enable children to make their personal information publicly available, knowingly or intentionally use their information in any manner, or knowingly or intentionally disclose their information to anyone. If a child under the age of 13 has or may have provided personal information to ABC, a parent or guardian may inform us of that fact by contacting us using one of the methods listed in the “How to Contact Us” section below, and we will then review our records and delete any such information from our database. If you are under the age of 13, do not provide us with any personal information either directly or indirectly (e.g., by posting personal information on our website). Any personal information that we receive from a person whom we believe is under the age of 13 will be deleted.
Users under the age of 18 must have the consent of their parent(s) or adult guardian(s) to complete ABC’s online application. Such users’ parent(s) or adult guardian(s) must complete the “Parent/Guardian Signature” in order to complete ABC’s online application process.
ACCESS TO AND RETENTION OF PERSONAL INFORMATION
ABC does not maintain all of your personal information in a form that you can access or update, and some items, such as transaction records, may not be changed. Accordingly, we will determine and may limit what may be accessed and how, subject to applicable law, and we may keep a record of changes (including deletions) and disclose them for compliance or other lawful purposes. We keep your personal information for only as long as necessary for the fulfillment of the purposes for which it is collected (but in no event less than eight (8) years), and we reserve the right to retain it to the full extent not prohibited by law. Upon our confirmation of your identity, you may request confirmation that your application is being processed, review your personal information that is readily accessible free of charge (provided that such request is not excessive or unfounded), or request that it be updated by contacting our ABC Customer Service Center using one of the methods listed under the “How to Contact Us” section below.
SECURITY OF PERSONAL INFORMATION
ABC uses various physical, electronic, and procedural measures to protect your personal information from unauthorized disclosure or misuse. Only authorized employees of ABC have access to our databases where your personal information is stored. We employ Secure Sockets Layer (SSL) and HTTP Secure (HTTPS) technology and other security measures to encrypt and securely transfer sensitive personal information you input, such as credit card numbers, during transmission. However, because no data security systems are completely secure, we do not warrant that any personal information that you provide to us will be secure or safe from unauthorized access. If you provide any personal information to us, you do so at your own risk. You may contact our privacy officer at firstname.lastname@example.org for more information or to file a complaint.
LINKS TO OTHER WEBSITES
CHANGES TO THIS POLICY
ABC’s website does not respond to “do not track” signals or similar mechanisms. ABC may send you email messages, direct mail offers, or other communications regarding products or services unless you specifically ask us not to do so when you enroll in our marketing program, access our website, or change your preferences by updating any accounts you may have with us. At any time, you may elect to discontinue receiving commercial messages from ABC by submitting an opt-out request to our ABC Customer Service Center (see “How to Contact Us” below) or by following the instructions in the form of the communication you received, as described below.
- Emails: To opt out of receiving marketing materials via email, use the method provided in the emails or contact us at email@example.com.
- Printed Materials: To opt out of receiving printed marketing materials at your postal address, such as catalogs, flyers, or postcards, contact us at firstname.lastname@example.org.
- Voice Messages: To opt out of receiving voice messages by telephone, you may follow the instructions stated in the pre-recorded voice message or contact us at email@example.com.
Our web site was created by and is controlled, operated, and administered by ABC, a California corporation, or its agents from offices within the United States of America utilizing servers located in the United States of America. We make no representation that materials at our web site are appropriate or available for transmission to or from, or use in, locations outside of the jurisdiction stated above, and accessing our web site from any jurisdiction where our web site’s contents are illegal is prohibited. You may not use our web site or export the materials in violation of import or export laws and regulations. If you access our web site from a location outside of the United States, you are responsible for compliance with all local laws. If you are located outside of the United States, please note that the personal data you provide to us will be transferred to the United States. Whenever you submit any personal data to us, you consent to this transfer.
Additionally, the applicable laws of our affiliated academic institutions may differ from the applicable laws of the United States. We do not express any opinion as to your rights, privileges, and duties under such applicable laws, and we advise you to consult your own attorney on such matters.
CALIFORNIA PRIVACY RIGHTS
Because we value your privacy, we have taken the necessary precautions to be in compliance with the California Online Privacy Protection Act and Shine the Light law. We therefore will not distribute your personal information to outside parties without your consent. This consent may be explicit, such as your selection of a certain academic institution to which you would like to submit your application, or implicit, such as your use of a third-party vendor’s payment system (e.g., PayPal, Payeezy, or other major credit card processor) Please note that the California Shine the Light law does not cover all information sharing. Our disclosure only includes information covered by the law.
CANADA PRIVACY RIGHTS
Canadian users have the right under PIPEDA to access and correct their personal information held by us, subject to the terms of PIPEDA. Such users may request their personal information held by us and request corrections thereto by submitting a request in writing to firstname.lastname@example.org.
EUROPEAN UNION PRIVACY RIGHTS
The GDPR (applicable from May 25, 2018) provides for certain rights to European Union citizens. Among these is the “right to be forgotten.” Upon receiving your request, we will delete your personal information from our databases to the full extent required by the GDPR and subject to the conditions therein. If we have sent your application to any requested educational institution, we will notify such educational institution(s) of the request for erasure.
Upon the conditions set out in the GDPR, including receiving a reasonable request or objection from you, ABC will restrict the processing of your personal information.
By submitting an application through our web site, you provide your informed consent to the transfer of your personal information to our servers in the United States. The transfer is necessary for ABC to process your application.
ABC processes personal information as both a Processor and as a Controller, as defined in the GDPR. ABC will be the Controller for user data as outlined above in the “Collection of Personal Information” section. ABC will be the Processor in accordance with the GDPR as outlined in the “Our Use of Personal Information” section above. All personal information collected will be hosted in secure hosting facilities in accordance with the highest security regulations.
In the event of a data breach, we will notify the relevant supervisory authority within seventy-two (72) hours.
We have taken all other steps required to comply with the GDPR.
HOW TO CONTACT US
Mailing Address: 3419 Via Lido, Suite 629, Newport Beach, CA 92663