Last updated: February 3, 2020
OUR COMMITMENT TO PRIVACY
The Site is owned and operated by Keypath Education, LLC (who we refer to, together with our affiliates, as “Keypath,” “us,” “we,” or “our,” depending in the context).
- What information we collect, how we collect that information, and how we use that information,
- When and with whom we may share information we collect, and
- Your choices regarding your personal information.
COLLECTION AND USE OF PERSONAL INFORMATION
How We Collect Personal Information
“Personal Information” refers to information that can be used to personally identify you, a specific individual. Different states and laws define Personal Information (or similar terms, such as “personally identifiable information”) differently, but Personal Information generally includes information such as your name, mailing address, e-mail address, and phone number. It may also include the IP address of your computer or mobile device if that IP address can be associated with other Personal Information and used to identify a particular person, or geo-location information, again if that information can be used to pinpoint a specific party.
We will collect Personal Information from you only if you voluntarily provide it to us. For example, when you contact us, such as through the “Contact Us” or similar links on the Site, or when you subscribe our resources, we will have access to your name, email address, and any other information you choose to include in your correspondence. If you participate in any other interactive area of our Site, we will collect any Personal Information that you include as a part of your participation.
In addition, some mobile network providers (“Mobile Provider”) in the U.S. are required to use technology that tracks the physical location of mobile devices that use their service. Depending on your Mobile Provider and mobile device, we may automatically receive this information, which, as noted above may be considered Personal Information. Most mobile devices provide users with the ability to disable location services. These controls are usually located in the mobile device's settings menu. If you have questions about how to disable your mobile device's location services, you should contact your Mobile Provider or your mobile device manufacturer.
How We Use Personal Information
We use the Personal Information we collect through the Site to respond to your inquiries, to provide you with the resources and services you request, and to contact you regarding other services we offer that may be of interest to you. We may also use Personal Information collected through the Site for research regarding the effectiveness of the Site and our business planning, marketing, advertising, and sales efforts. In addition, if we begin to offer services that use location tracking (“pinpointing”) information, then if we have your “opt-in” consent to do so we may use and store that information to provide location-based services, including location-targeted advertising.
You are in control over whether you provide us with any Personal Information. If you are not comfortable with our accessing and using the Personal Information as described, you should not provide it (and should take steps to disable any technology that automatically provides us with Personal Information). This may affect our ability to provide you with information and services through the Site; however, that is your choice.
COLLECTION AND USE OF NON-PERSONAL INFORMATION
How We Collect Non-Personal Information
We may also use “web beacons”, i.e. “web bugs” or “single–pixel” or “clear” GIFs, on the Site. Web beacons allow ad networks to provide anonymized, aggregated auditing, research, and reporting for us and for advertisers. Web beacons also enable ad networks to serve targeted advertisements to you when you visit other websites. Because your web browser must request these advertisements and web beacons from the ad network’s servers, these companies can view, edit, or set their own cookies, just as if you had requested a web page from their website.
How We Use Non-Personal Information
In addition to the uses described above for automatically-collected NPI, we may use this information to analyze trends, administer the Site, and gather broad demographic data for aggregate use.
We may also use NPI and other de-identified information (i.e. information that cannot be used to identify you) for any lawful business purpose without any obligation or accounting to you. For example, we can use NPI for developing products, services, and providing those offerings to other users and third parties.
HOW WE MAY SHARE INFORMATION
We may share information with third parties in the following circumstances:
- We may share your information, including Personal Information, so that we or others may provide you with periodic mailings, or may contact you regarding products, services, or events. If you do not wish for us to share your information in this manner, please let us know by contacting us at email@example.com.
- We may employ other companies and people to perform tasks on our behalf and we may need to share Personal Information with them to provide services to you. For example, such parties may handle our data management and/or email distribution. Unless we tell you differently, they do not have any right to use your Personal Information beyond what is necessary to assist us.
- We may share information, including Personal Information, with our corporate affiliates for our and their legitimate business purposes.
- We will share Personal Information with third parties for other purposes if we have your express “opt-in” consent to do so.
- We may disclose non-personal, aggregate, anonymous data in a de-identified format for any legitimate business purpose.
- We may disclose Personal Information at the request of law enforcement or government agencies or in response to subpoenas, court orders, or other legal process to establish, protect, or exercise our legal or other rights or to defend against a legal claim, or as otherwise required or allowed by law.
- We may disclose Personal Information if we believe that such action is appropriate to (a) protect the rights, property, or safety of a user of the Site or any other person, (b) investigate or prevent a violation by you of any contractual or other relationship with us, (c) investigate or prevent your actual or potential illegal, fraudulent, or harmful activity, or (d) detect, prevent, or otherwise address fraud, security, or technical issues.
- We may share information, including Personal Information, in connection with, during negotiations of, or as a part of the closing of any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
We do not sell, rent, or lease any Personal Information that we collect about you through the Site to anyone for any purpose, other than as disclosed.
HOW WE PROTECT YOUR INFORMATION
We use commercially reasonable security measures to prevent unauthorized persons from accessing our files or tampering with our technology and to secure your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure. However we cannot and do not guarantee the security of any information. This is especially true for any information that is transmitted electronically and that is unprotected until it reaches our servers.
YOUR COMMUNICATION PREFERENCES
Correcting, Updating, Accessing, or Removing Personal Information
In addition, please note that notwithstanding your email preferences, we may need to contact you as required by law, or to complete any open inquiries.
Your California Privacy Rights
If you are a California resident, please see the section below entitled “Additional Information for California Residents.”
DO NOT TRACK REQUESTS; THIRD PARTY SERVICES
Do Not Track
Currently, certain browsers (including Google Chrome, Safari, Firefox, and Internet Explorer) offer a “no not track” (“DNT”) option. The DNT option sends a signal to websites visited by the user about the user’s DNT preference, if any, set on the browser. We do not currently commit to responding to browsers’ DNT signals. We cannot make this commitment because no common industry standard for DNT has been adopted by industry groups, technology companies, or regulators.
Third Party Services
USERS FROM OUTSIDE THE UNITED STATES
A NOTE ABOUT CHILDREN
Our Site is not targeted to, and we have no interest in collecting information from, children, and we do not knowingly gather any Personal Information from children under the age of 13. If you are a parent or a legal guardian who believes that your minor child provided us with any Personal Information, please contact us at firstname.lastname@example.org.
ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS
Note that in the CCPA, “consumer” refers to residents of California, so this section only applies to you if you are a California resident.
The Categories of Personal Information We Collect
For purposes of the CCPA, the personal information we have collected during the past 12 months falls into the categories listed below. For each of these categories, we also provide information about the source(s) of that personal information, and our business and/or commercial purpose for collecting that information.
Category of Personal Information We Collect
Where Obtained (i.e., the Categories of Sources of the Information)
Business or Commercial Purpose of Collection
Real name, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, or other, similar, identifiers.
Personal information categories listed in the California Consumer Records statute (Cal. Civ. Code §1798.80(e))
Name, address, telephone number, education, education, employment, employment history.
Some personal information included in this category may overlap with other categories.
Protected classification characteristics under California or federal law
Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
Internet or other similar network activity
Browsing history, search history, information on interaction with a website, application, or advertisement.
Professional or employment-related information
Current or past job history or performance evaluations.
Third Parties to Whom We Disclose Information
We also share personal information with analytics providers, like Google Analytics, who may use tracking technologies to measure the effectiveness of our Site. In connection with their analytics services, they may receive information about your internet or other similar network activity. Also see the section above entitled “Third Party Services.”
We do not sell personal information to third parties.
Rights of California Consumers Under the CCPA
The CCPA provides California consumers with specific rights regarding their personal information. If you are a California resident, you have the rights described below. Please note that your rights are subject to limitations and exceptions described in the CCPA.
- Right to Access Certain Information – You have the right to ask us to provide you with information about our collection and use of your personal information over the past 12 months.
- Right to Data Portability – You have the right to ask us to provide you with copies of personal information that we have collected about you, in a portable and readily-usable format.
- Right to Request Deletion of Certain Information – You have right to ask us to delete personal information about you that we have collected and retained.
- Right to Non-Discrimination – You have the right not to be discriminated against for exercising any of your CCPA rights.
How to Exercise Your Rights Under the CCPA
To exercise any of the rights described above, you must submit a verifiable consumer request to us. You can do so by:
- Emailing us at email@example.com; or
- Calling us toll-free at 1-844-348-5248
Only you, or a person registered with the California Secretary of State that you expressly authorize to act on your behalf, can make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within any 12-month period.
We cannot respond to your request or provide you with information if we cannot identify you or confirm your authority to make the request, so any request will require you to provide sufficient information to allow us to reasonably verify your identity. We will only use any personal information provided in a verifiable consumer request to verify the requesting party’s identity or authority to make the request.
We will respond to any verifiable consumer request in the manner and within the timeframes required by the CCPA.
California’s “Shine the Light” Law
In addition to the CCPA, California’s “Shine the Light” law permits users that are residents of California to request the following information regarding our disclosure of your Personal Information to third parties for those third parties’ direct marketing purposes (a) a list of certain categories of personal information that we have disclosed to certain third parties for their direct marketing purposes during the immediately preceding calendar year; (b) the identity of certain third parties that received personal information from us for their direct marketing purposes during that calendar year; and (c) examples of the products or services marketed (if we have that information). If you are a California resident and would like to make such a request, please email us at firstname.lastname@example.org.