Privacy Policy Addendum For California Residents & Notice At Collection
[This Special Notice is not applicable to CA job applicants or personnel.]
Persons with disabilities may obtain this notice in alternative format by contacting us at privacy.universitypartners@kaplan.com or calling (877) 881-7313.
Your California Privacy Rights. This Special Notice for California residents supplements our Privacy Policy and applies only to California residents.
NOTICE AT COLLECTION
California Consumer Privacy Act/California Privacy Rights Act
The California Consumer Privacy Act (“CCPA”) and as expanded by the California Privacy Rights Act (“CPRA”) provides California residents with rights to receive certain disclosures regarding the collection, use, and sharing of their “Personal Information,” as well as rights to know/access, delete, and limit sharing of Personal Information. 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 consumer or household.” Certain information we collect may be exempt from the CCPA because it is considered public information (i.e., it is made available by a government entity) or covered by a specific federal privacy law, such as the Gramm–Leach–Bliley Act, the Health Insurance Portability and Accountability Act, or the Fair Credit Reporting Act. The Personal Information we collect about you will depend upon how you interact with our Sites and the information you voluntarily provide us. Accordingly, we may not collect all of the below information about you. In addition, we may collect and/or use additional types of information after providing notice to you and obtaining your consent to the extent such notice and consent is required by the CCPA.
To the extent that we collect Personal Information that is subject to the CCPA, that information, our practices, and your rights are described below.
Categories of CA Personal Information We Collect and Purposes for Collection. You have the right to receive notice of the categories of Personal Information we collect and the purposes for which those categories of Personal Information will be used. The categories we use to describe the information are those enumerated in the CCPA. Consistent with the "Information We Collect" and “Use of Your Personal Data” sections in the general privacy policy, we may collect certain categories of information about California consumers ("CA Personal Information"), specifically as follows:
- Personal Identifiers:
We collect your name, phone number(s), postal address(es) and email address(es) that you provide to us when you engage with our website. We use this information to fulfill or meet the reason for which the information was provided to us; to provide the services you request; manage payments, fees and charges; provide you with support and to respond to your inquiries, including to investigate and address your concerns; to monitor and improve our responses; to provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you; to report your attendance, performance, and completion data; to respond to law enforcement requests and as required by applicable law, court order, or governmental regulations. We use the information to personalize your website experience, to improve and deliver content and product and service offerings relevant to your interests through our website, third party sites, and via email or text messages. As an education and enablement service provider with consumers from middle school through professional school, we store this information to optimize your experience with us and assist you in achieving your lifetime and career goals. We retain this information indefinitely to provide lifelong learners information of interest, until we receive a request that it be deleted. - Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)):
In addition to information in the Personal Identifiers section above, our service providers collect your credit card number, debit card number, or any other financial information you submit to process payments, fees, charges, billing and collections, so that we provide you with information, products or services that you request from us. We may use this information, to respond to law enforcement requests and as required by applicable law, court order, or governmental regulations. We do not retain this information in our systems. The service provider processes payment only and may not use the information for any other purpose. We may also collect information regarding your education (graduation date, school of attendance) to optimize additional products and services that may be of interest to you. To the extent permitted by law, we retain this information indefinitely to provide lifelong learners information of interest and opportunities for development, until we receive a request that it be deleted. - Protected classification characteristics under California or federal law:
From sources other than you, we may also collect age, gender, marital status, occupation and demographics (any additional email/postal addresses or phone numbers you may have used), to further understand our customers and personalize offerings of products or services. To the extent permitted by law, we retain this information indefinitely to optimize your experience with us and assist you in achieving your lifetime and career goals, until we receive a request that it be deleted. - Commercial Information
We may collect information about online activity data, products or services purchased or considered, or other purchasing or consuming histories or tendencies, to provide you with information, products or services that you request from us and to improve them. To the extent permitted by law, we retain this information indefinitely to provide lifelong learners information of interest and opportunities for development, until we receive a request that it be deleted. - Internet or Other Electronic Network Activity Information:
We automatically collect information about your browsing history and your interaction with the content of our Sites or services, to measure activity, determine the effectiveness of our services, and improve them. We retain this information indefinitely at a de-identified, aggregate level. - Sensory Data:
We may collect your audio or voice recordings if you submit or post a recording with the application or an assignment in the program, for instance in a personal statement, project, or discussion board. We retain recordings you submit or post as part of your educational record. To the extent permitted by law, we retain this information indefinitely as part of your educational record, until we receive a request that it be deleted.
We may collect your audio or voice recordings if your class program is recorded and you appear in it as part of the delivery of services. We retain class recordings for the benefit of other participants in the program, internal research and quality assurance. We delete program recordings after approximately seven years. - Inferences drawn from other personal information.
We may collect information from sources other than you, to build a consumer profile of your preferences and characteristics to determine how best to serve you over your lifetime, how you may achieve success when using our products, and how we may modify our offerings for the success of others. Some of this information is collected at a household level such as number of children or estimated household income. To the extent permitted by law, we retain this information indefinitely to provide lifelong learners information of interest and opportunities for development, until we receive a request that it be deleted. - Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))
We collect information in education records (such as attendance, grades, performance and completion data) as a service provider acting on the behalf of a higher education institution. To the extent permitted by law, we retain this information for the length required by our service agreement.
We may use any of the categories of information listed above for other business or operational purposes compatible with the context in which the Personal Information was collected.
We may share any of the above-listed information with service providers, for the limited purpose of our engagement with them as described in the section titled “Use of Your Personal Data”. Service providers are restricted from using Personal Information for any purpose unrelated to our engagement.
Sources of CA Personal Information. We may collect CA Personal Information from the following sources:
Directly from you: such as when you voluntarily provide CA Personal Information to us or our service providers, or affiliate companies, when enrolling in programs, purchasing subscriptions or publications or services or registering for an account on our Sites, or when it is collected automatically from your device;
Third-Party Business Partners: such as marketing partners;
Data Analytic Firms: such as market research or market intelligence firms, data augmentation and data aggregators.
Right to Know About Personal Information Collected, Disclosed, or Sold. You have the right to request information regarding your CA Personal Information that we have collected, used, disclosed, or “sold” (as defined under CCPA) within the preceding 12 months. Our collection, use, disclosure, and sale of Personal Information is described in our Privacy Policy.
Right to Know/Access Information/Correct Inaccurate Personal Information. You have the right to request access to Personal Information collected about you and information regarding the source of that information, the purposes for which we collect it, and the third parties and service providers with whom we share it. Additionally, you have the right to correct inaccurate or incomplete Personal Information. You may submit such a request as described below.
Right to Request Deletion of Information. You have the right to request in certain circumstances that we delete any Personal Information that we have collected directly from you. You may submit such a request as described below. We may have a reason under the law why we do not have to comply with your request, or why we may comply in a more limited way than you anticipated. If we do, we will explain that to you in our response.
How to Exercise Your Rights.
You may submit a request to exercise your rights to know/access, correct or delete your Personal Information through any of the following means:
(1) By filling out a Consumer Data Request Form available here
(2) By sending us an email at privacy.universitypartners@kaplan.com
(3) By calling us at (877) 881-7313.
To protect consumers’ Personal Information, and to comply with the CCPA, we will use a verification process to confirm your identity before we act on your request. If you use an authorized agent to submit a request on your behalf, we may require that you (1) provide the authorized agent written permission to do so, and (2) provide us a copy of the authorization or a copy of a power of attorney.
In verifying requests, we employ reasonable measures to detect fraudulent requests and prevent unauthorized access to your personal information. To meet our obligations, we are required to verify your identity, and the identity of your authorized agent, if the request is submitted via an agent, by associating the information provided in your request to personal information previously collected by us.
If we suspect fraudulent or malicious activity on or from the password-protected account, we may decline a request or request that you provide further verifying information.
You may only make a verifiable consumer request twice within a 12-month period. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify your identity or authority to make the request.
Right to Opt Out of Sale of Personal Information to Third Parties. You have the right to opt out of any sale of your Personal Information by Kaplan to third parties at “Do Not Sell or Share My Personal Information”. We do not sell information to third parties. We do not knowingly sell CA Personal Information of consumers younger than the age of 16.
Right to Information Regarding Participation in Data Sharing for Financial Incentives. You have the right to be free from discrimination based on your exercise of your CCPA rights. We do not discriminate against anyone who chooses to exercise their CCPA rights.
Shine the Light Law
While we do not provide your personal information to third parties for their use in marketing, under California law, California residents have the right to opt-out of such use of your personal information if it occurred. California residents are entitled once a year, free of charge, to request and obtain certain information regarding our disclosure, if any, of certain categories of personal information to third parties for their direct marketing purposes in the preceding calendar year. To obtain this information, please send an email to privacy.universitypartners@kaplan.com with the phrase “California Privacy Request” in the subject line and in the body of your message.
Published August 2024