Last updated: July 1, 2020
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 us: We collect personal information you provide to us as part of the Services, such as when you request informational materials, submit an application, enroll in our programs or courses, apply for financial aid, participate in a promotion or survey, use career services, set up profiles for online educational or administrative tools, register for housing, or utilize our mobile, online or offline resources . Examples of the type of information you may provide to us are:
- Personal identifying information, such as your name, mailing address, email and phone number, emergency contact, social security number, date of birth, passport details, sex, national origin, medical condition, educational and employment history, photo, fingerprints, financial information, and health insurance information;
- Demographic information, job application or career preferences, interests, and information provided in your admissions or housing materials;
- Information that you provide in course discussion boards, community forums, in directories, on social media, or in response to promotions and surveys, such as photos, comments, and reviews; and
- Audio from customer service calls.
- Log-in, email address, and password;
- IP address of the device you are using;
- Device ID;
- Location of your device;
- Browser type;
- Internet service provider;
- Audio recordings for quality and training purposes;
- Video recordings from CCTV security monitoring; and
- 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 education partners that administer exams and courses, provide scholarships or financial services or manage educational records, service providers, testing centers, social media, third-party platforms and forums, and business partners. Examples of the type of information we may receive from other sources are:
- Personal identifying information, such as your name, personal and professional mailing address, email and phone number, and professional and educational history;
- Educational performance, professional history, information contained in letters of reference, and student loan or grant information related to your attendance at RUSM;
- Profile information, comments, and similar information provided to or on social networks and other forums that connect to us; and
- Interests, demographic data, and internet browsing behavior.
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.
How We Use the Personal Information Collected
We use, store, and process the personal information we collect to provide and improve the Services, administering application, enrollment, registration, housing and financial 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 details about our programs, enrollment, ongoing education, financial aid, student services, and career services;
- To administer applications, enrollment, registration, housing, financial services, and alumni programs;
- To fulfill any other purpose for which you provide it;
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
- 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 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 facilities, website(s), 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; and
- As described to you when collecting your personal information.
Disclosing Personal Information
We may disclose your personal information to other businesses or entities, in accordance with other regulatory requirements, as follows:
- To service providers that perform services on our behalf, such as process credit card payments, event planners and coordinators, data management and storage providers, property managers, marketers and advertisers, analytics and research companies, and professional advisors;
- To clinical affiliates and residency programs;
- To law enforcement agencies, regulators, and courts in response to a court order, subpoena, 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 RUSM;
- To another entity in connection with a merger, reorganization, divestiture, financing, dissolution, or similar corporate event; and
- Otherwise with your consent.
Cookies and Similar Technologies
- Cookies. Cookies are small text files downloaded on your browser that store your preferences. Most browsers allow you to block and delete cookies. However, if you do that, the website may not work properly.
- 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.
- Behavioral-based advertising. A third party may use technology, such as a cookie on your browser or a web beacon, to identify you so that they can provide advertising about products and services tailored to your interests. If you would like to opt-out of third-party behavioral advertising that collects information on your use, you can do so by visiting the Network Advertising Initiative and the Digital Advertising Alliance. Alternatively, you may opt out of this advertising by visiting http://preferences-mgr.truste.com/ or if located in the European Union by visiting http://www.youronlinechoices.eu/. Please note, you will continue to receive generic 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. This analytics data is not tied to any personal information. For more information about Google Analytics, please visit https://policies.google.com/technologies/partner-sites. You can opt-out of Google’s collection and processing of data generated by your use of the Services by going to https://tools.google.com/dlpage/gaoptout.
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 Contact Us.
International Transfer of Personal information
RUSM 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. These jurisdictions may have data protection laws that differ from your home jurisdiction. By using our Services, you consent to the transfer, storage, and processing of your personal information to a jurisdiction other than where you reside or are located. For individuals located in the EEA, we are committed to protecting the privacy and confidentiality of your personal information when it is transferred and use appropriate safeguards for personal information transferred outside of the EEA.
We keep personal information only for as long as necessary to fulfill the purposes for which it was collected or as required by applicable laws or regulations.
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.
International Privacy Practices
If you are an individual located in the EEA, 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:
- 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, contact us at email@example.com. Unless we notify you at the time of your request, we will not charge any fee in connection with the exercise of your rights. If you are not satisfied with our response, you have the right to complain to or seek advice from a supervisory authority and/or bring a claim against us in any court of competent jurisdiction.
California Privacy Rights
Beginning January 1, 2020, and pursuant to the California Consumer Privacy Act of 2018 (“CCPA”) California residents have the right to know what personal information is collected about them, request deletion of their personal information, opt out of the sale of their personal information, and not be discriminated against if they choose to exercise any of their rights. If a California resident would like to exercise any of the rights afforded to them, you may contact us at firstname.lastname@example.org. We do not discriminate against anyone who exercises their CCPA rights. This section describes your CCPA rights and explains how to exercise those rights.
Notice of Collection: Although the personal information we collect and how we use it is described in greater detail in the sections titled Personal Information We Collect and How We Use the Personal Information Collected, the categories of personal information we may have collected about you in the prior 12 months are:
- Identifiers, such as, name, postal address(es), email address, phone numbers, social security number, passport details, driver’s license number, online identifier, IP address;
- Customer Records, name, postal address, email address, phone numbers, date of birth, social security number, passport details, education, employment, employment history, bank account number, financial information, medical information, health insurance information;
- Protected Classifications, such as, race, sex, age, national origin, citizenship status, marital status, sexual orientation, veteran or military status, medical condition;
- Commercial Information, such as, products or services purchased, 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, audio, visual, or electronic, such as photos, call recordings, and CCTV footage;
- Professional or Employment-related Information, such as, current or past job history;
- Non-public Education Information, related to past and present education, such as, grades, transcripts, class lists, schedules, student identification, disciplinary records, institutions attended, years of attendance, courses of study; and
- Inferences, such as, a profile reflecting preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Request to Know: California residents have the right to request, subject to certain exemptions, that we disclose certain information to them about our collection and use of their personal information over the past 12 months. As a California resident, you have the right to request the following without charge:
- Categories of personal information collected about you;
- Categories of sources for the personal information we collected about you;
- Business and/or commercial purposes for collecting and selling that personal information;
- Categories of third parties/with whom we have disclosed or shared that personal information;
- Specific pieces of personal information we have collected about you;
- Categories of personal information that we have disclosed or shared with a third party for a business purpose; and
- Categories of third parties to whom the residents’ Personal Information was sold.
California residents may make up to two requests to know within a 12-month period. If you would like to exercise your rights, email us at email@example.com or call us 1-866-653-5656.
Request to Delete: A California resident has the right to request deletion of the personal information we have collected about them and we will delete such personal information, except where an exemption applies. You may email us at firstname.lastname@example.org to request that we delete your personal information.
No Sale of Personal Information: We do not sell your personal information as those terms are defined under the CCPA.
Incentives: 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. Each contest or sweepstakes has its own terms and conditions that describe how an eligible consumer can opt-in, as well as withdraw from the contest or sweepstakes. In order to enter a sweepstakes or contest, you may be required to provide us (or our service provider) with certain personal information, such as your name and contact information. If you submit your entry in accordance with the applicable promotion’s rules, you will be entered into the promotion and will get a chance to win a prize. These promotions may be deemed a “financial incentive” under California law. We will not discriminate against you if you exercise your rights under CCPA. However, if you ask us to delete your information, you may not be able to participate in the sweepstakes or contest for which the deleted information was required to administer the promotion.
Our Services are not directed to children under the age of 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 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.
Adtalem Global Education
500 W. Monroe Street
Chicago, IL 60661
Email Us: email@example.com