Last updated: April 30, 2021
Ross University School of Medicine (“RUSM”, “we”, or “us”) is committed to educating a diverse group of medical students to help them become skilled physicians to serve as leaders in the U.S. healthcare system. RUSM students complete their foundational studies in Barbados, before completing their clinical training in one of RUSM’s affiliated teaching hospitals throughout the United States. RUSM is a subsidiary group company of Adtalem Global Education, Inc.
If you reside or are located in the European Economic Area ("EEA") or the United Kingdom (“UK”) RUSM 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
- International Transfer of Personal information
- Third-party Websites
- EEA and UK Data Subject Privacy Rights
- Notice for Nevada Residents
- 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,] 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, utilize our online portal or mobile app, online or offline resources, attend a conference, event or other in-person function, chat with a representative on our website, or otherwise interact with us either online or offline.
- Examples of the type of information you may provide to us are:
- Personal 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;
- Account or course login credentials;
- Demographic information, job application or career preferences, interests, veteran or military status, and information provided in your applications for admissions or housing materials;
- Payment information;
- 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.
- Information collected automatically:
- Course and webinar 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; 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 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; and
- Interests, demographic data, and internet browsing behavior.
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 a financial aid application, (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.
Special categories of data
When you make an application for admission to one of our courses of programs, our application form asks you about your racial/ethnic origin. You are not required to give us this information but if you choose to do so we only use it for equal opportunities monitoring and share it with the Department of Education for this purpose. Our legal basis for processing this data is your explicit consent.
Acceptance into the Ross Med pre-licensure program is dependent on the clearance of a drug and alcohol screen, background and fingerprint check including immunization record. Through these checks, we may potentially process health data, criminal convictions and offences data, and we will process your biometric fingerprint information using a third-party background check provider. We will ask you whether we can do this. We only use this data for the purposes of conducting a fraud and security check and clearing your application to the Ross Med pre-licensure program. We retain this data while you are active in the program and for six years after you leave the program.
In addition, once your application to one of our courses or programs has been accepted, we collect details of any medical conditions you may have, your health insurance information and we may be able to infer information about your racial or ethnic origin from your nationality or from your passport. We only use this information for assisting students with any conditions you may tell us about so that we can arrange any additional support or make any necessary arrangements for you (this is for our legitimate interests in ensuring we provide equal opportunities for all applicants and for carrying out obligations in the field of social protection law.
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 details about our programs, enrollment, ongoing education, financial aid, student services, and career services (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 administer applications, enrollment, registration, housing, financial services, and alumni programs (necessary in order for us to enter into and for the performance of our contract with you and otherwise in our legitimate interests to administer such products or services)
- To assess your eligibility for admission to RUSM (necessary in order for us to enter into a contract with you)
- To analyze student performance (our legitimate interests in understanding more about student performance in order to operate our business and improve our Services)
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection purposes (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 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 for 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 facilities, website(s), 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 service providers that perform services on our behalf, such as credit card payment processors, 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, 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 RUSM;
- 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; and
- Otherwise with your consent.
Cookies and Similar Technologies
- 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.
- 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 Facebook, LinkedIn, Twitter, Instagram, YouTube, Pinterest, Snapchat 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 manager their cookie preferences by utilizing the online cookie preference center: Cookie Settings
- For California users, please see our California Notice at Collection and Privacy Notice insert link.
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 Contact Us section below for information about how to contact us.
International Transfer of Personal information
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.
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, contact us at firstname.lastname@example.org. 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.
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 Cookie Settings
Our Services are not directed to children under the age of 16 and we do not knowingly collect any personal information from 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 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.
Last Updated: April 30, 2021
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 you:
- Identifiers, such as, name, postal address(es), email address, phone numbers, date of birth, social security number, passport details, driver’s license number, online identifier, IP address;
- California Customer Records, such as name, postal address, email address, phone numbers, date of birth, driver’s license number, social security number, passport details, education information, employment information, employment history, bank account number, financial information, medical information, health insurance information;
- Characteristics of Protected Classifications Under California or Federal Law, 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 or considered, other purchasing or consuming tendencies;
- Biometric Information, such as fingerprint information.]
- 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 information, including photos, call recordings, and CCTV footage;
- Professional or Employment-related Information, such as, current or past job history;
- Education Information, such as education records directly related to students maintained by us or a third-party acting on our behalf, such as, grades, transcripts, class lists, student schedules, student identification codes, and disciplinary records. This also includes student directory information, including information such as a student’s name, address, telephone listing, date and place of birth, major field of study, participation in officially recognized activities and sports, weight and height of members of athletic teams, dates of attendance, degrees and awards received, and the most recent previous educational agency or institution attended by the student; 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 administer applications, enrollment, registration, financial services, and alumni programs
- To assess your eligibility for admission to RUSM
- To analyze student performance
- 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 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
- 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 Cookie 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||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.
California Customer Records, such as, name, address, or phone numbers.
|Categories of Personal Information pursuant to 1798.80(e), such as, name, address, or phone numbers.]||
|Characteristics of Protected Classifications Under California or Federal Law, such as race, sex, gender, sexual orientation, marital status, military or veteran status, nationality||
|Commercial Information, such as, products or services purchased and other purchasing or consuming tendencies.||
|Biometric Information, such as fingerprint information.||
|Internet or Other Electronic Network Activity, such as, browsing history, search history, or website or advertisement interaction.||
|Geolocation Data, such as, IP address or physical location.
|Audio, Video and Other Electronic Data, such as, photos, call recordings, or CCTV footage.
|Professional and employment-related information, such as business contact details, job title or employer;||
|Education information, meaning education records directly related to students maintained by us or a party acting on our behalf, such as grades, transcripts, class lists, student schedules, student identification codes, and student disciplinary records.
This also includes student directory information, including information such as a student’s name, address, telephone listing, date and place of birth, major field of study, participation in officially recognized activities and sports, weight and height of members of athletic teams, dates of attendance, degrees and awards received, and the most recent previous educational agency or institution attended by the student.
|Inferences drawn from this information, such as, a profile reflecting preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes.||
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.
Sale of Personal Information
We disclose the following categories of personal information with 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.
- California Customer Records
- 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 with 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 with a third party for a business purpose; and
- Categories of third parties to whom the residents’ personal information was sold.
- Right to Deletion: 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 to third parties. 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, email us at email@example.com or call us 1-866-653-5656.
Right to Deletion: California residents may email us at firstname.lastname@example.org or call us at 1-866-653-5656 to request that we delete your personal information.
Verification: We will need to verify your identify 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 Cookie 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 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 the CCPA. 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 email@example.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
Chicago, IL 60661
Email Us: firstname.lastname@example.org