Appendix A — California Specific Privacy Notice
Last Updated: December 31, 2021
Our California Specific Privacy Notice supplements the information in our Privacy Policy. The following material applies only to residents of California1. We have adopted this notice to comply with the California Consumer Privacy Act of 2018 ("CCPA"). Any terms defined in the CCPA have the same meaning when used in this notice. If at any time you have questions about this information, please contact Privacy Matters or call toll-free (844)783-8627.
YOUR RIGHTS UNDER THE CCPA
Except as otherwise provided by applicable California law, note that for purposes of these requests under this "Your Rights Under the CCPA" Section of this Notice, personal information does not include information about job applicants, employees and other of our personnel; information about employees and other representatives of third-party entities we may interact with; or information we have collected as a service provider. California residents may designate an authorized agent to make a request on their behalf. When submitting the request, please ensure the authorized agent is identified as an authorized agent.
Your Right to Request Information About Personal Information We Collected.
You have the right to request the following about personal information we collected about you over the past 12 months:
- The categories of your personal information we collected.
- The categories of sources from which we collected the personal information.
- Our business or commercial purpose for collecting or selling the personal information.
- The categories of third parties2 with whom we shared the personal information.
- The specific pieces of personal information we have collected about you.
Your Right to Request Disclosure of Personal Information We Sold3 or Disclosed for a Business Purpose.
You have the right to request that we disclose:
- The categories of your personal information that we sold and the categories of third parties to whom we sold the personal information.
- The categories of your personal information that were disclosed for a business purpose.
Your Right to Request Deletion of Certain Personal Information We Collected.
You have the right to request that we delete your personal information that we maintain about you, subject to certain exceptions.
Your Right to Request Opt-Out/Do Not Sell My Personal Information. You have the right, at any time, to direct us not to sell your personal information to third parties, as defined under the CCPA by clicking Do Not Sell My Personal Information. This is also referred to as your right to opt-out. For purposes of this Privacy Policy, "sell" means the sale of your personal information to an outside party for monetary or other valuable consideration, subject to certain exceptions set forth in applicable California law.
You have the right to opt-out of sales, within the meaning of the CCPA, of certain information subject to the CCPA. You are not required to have an account with us to exercise your right to opt-out of the sale of your personal information to third parties. Please submit your request to Privacy Matters. If you do not have an account, please include your name, address and e-mail address. You may also submit a Do Not Sell My Personal Information request by following the instruction indicated. We do not sell the personal information of consumers we actually know are less than 16 years of age.
We use tracking tools, including cookies, on our websites. Third parties also use cookies on our sites. Your browser may give you the ability to control cookies. How you do so depends on the type of cookie. Cookies are small files that download when you access certain websites. To learn more, visit [Needs data attributes here. Certain browsers can be set to reject browser cookies. These pages also explain how you can manage and delete cookies. To control flash cookies, which we may use on certain websites from time to time, you can go here. Why? Because flash cookies cannot be controlled through your browser settings. Our website offers users the convenience of a tool that will allow the user to set their tracking preferences for this website. To learn about cookies, tracking tools, and how you can manage these tools, please see About Our Ads.
Your Right to Nondiscrimination. We do not discriminate if you choose to opt-out or exercise any of your rights under the CCPA. This includes, but is not limited to (i) charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties, (ii) providing a different level or quality of goods or services, or (iii) suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services. If we offer you a financial incentive permitted under the CCPA and not prohibited by other applicable laws and regulations, we will notify you of the material terms of the incentive or incentive program. You will be given the opportunity to provide prior opt-in consent (which you may revoke at any time).
CATEGORIES OF PERSONAL INFORMATION
We have collected the following categories (as enumerated in the CCPA) of personal information from consumers within the last twelve (12) months:
|
Category |
Examples |
Collected |
|---|---|---|
|
A. Identifiers. |
A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers. |
YES |
|
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). |
A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment data, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories. |
YES |
|
C. 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). |
YES |
|
D. Commercial information. |
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. |
YES |
|
E. Biometric information. |
Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. |
NO |
|
F. Internet or other similar network activity. |
Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement. |
YES |
|
G. Geolocation data. |
Physical location or movements. |
YES |
|
H. Audio or Visual data. |
Audio, electronic, visual, or similar information. |
YES |
|
I. Professional or employment-related information. |
Current or past job history or performance evaluations. |
YES |
|
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). |
Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. |
YES |
|
K. Inferences drawn from other personal information. |
Profile reflecting a person's preferences, characteristics, household characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. |
YES |
CATEGORIES OF SOURCES
We obtain the categories of personal information listed above in the "Categories of Personal Information" section of this Notice from the following categories of sources:
- Direct interactions. We collect personal information when you request information about our products and services or sign up for an event. We might also collect information when, for example, you sign up to receive communications from us. You may give us your information by filling in forms or by corresponding with us by e-mail, phone, fax, mail or in-person. This includes, but is not limited to, personal data you provide when you:
- Purchase our products or services or request information;
- Discuss your interest in and/or your eligibility for our services with our staff, including but not limited to, personnel in Admissions, Academics, Financial Aid, Registrar’s Office, Student Advising, Faculty, Career Services or Student Accounts;
- Apply for financial aid, scholarships, grants or other types of financial aid (e.g., military tuition assistance, employer tuition assistance, etc.);
- Create or register for a user account on our website, virtual campus, mobile application or job/hiring information site;
- Subscribe to our publications such as newsletters, alumni communications, career services information, investor updates or webinars;
- Request marketing be sent to you such as by e-mail, mail, phone, live chat or text messaging;
- Interact with our website such as through our application center, FA calculator, live chat, or providing your contact information;
- Interact with our social media pages, commenting on or liking posts;
- Enter a competition, sweepstakes, or promotion;
- Complete a survey or other assessment tool;
- Provide information in-person at industry events, school events or other venues, or by phone, fax, online chat, text message, or e-mail; or
- Provide information or apply for a position on our job information website.
- Automated technologies or interactions. As you interact with our website or mobile applications, we may automatically collect data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We may also receive technical information about you if you visit other websites employing our cookies. Please see About Our Ads for further details.
- Vendors we engage to provide services on our behalf.
- Other parties or publicly available sources. We may receive personal information about you from various other parties and public sources.
- We may combine information that we have collected offline with information we collected online. Or we may combine information we get from another party with information we already have.
USE OF YOUR PERSONAL INFORMATION
We may use and/or disclose the categories of personal information we collect about you in the "Categories of Sources" Section of this Notice for one or more of the following business or commercial purposes described in Clause 2 of the Privacy Policy.
DISCLOSURE AND SALE OF PERSONAL INFORMATION
|
Category |
In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose: |
In the preceding twelve (12) months, we have “sold” the following categories of personal information (for both minors and non-minors). |
|---|---|---|
|
A. Identifiers. |
YES |
NO (We do not sell information to third parties as defined under the CCPA). |
|
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). |
YES |
NO (We do not sell information to third parties as defined under the CCPA). |
|
C. Protected classification characteristics under California or federal law. |
YES |
NO (We do not sell information to third parties as defined under the CCPA). |
|
D. Commercial information. |
YES |
NO (We do not sell information to third parties as defined under the CCPA). |
|
E. Biometric information. |
NO |
NO (We do not sell information to third parties as defined under the CCPA). |
|
F. Internet or other similar network activity. |
YES |
NO (We do not sell information to third parties as defined under the CCPA). |
|
G. Geolocation data. |
NO |
NO (We do not sell information to third parties as defined under the CCPA). |
|
H. Sensory data. |
NO |
NO (We do not sell information to third parties as defined under the CCPA). |
|
I. Professional or employment-related information. |
YES |
NO (We do not sell information to third parties as defined under the CCPA). |
|
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). |
YES |
NO (We do not sell information to third parties as defined under the CCPA). |
|
K. Inferences drawn from other personal information. |
YES |
NO (We do not sell information to third parties as defined under the CCPA). |
CATEGORIES OF THIRD PARTIES
- We may disclose your personal information for a business purpose to the following categories of third parties:
- Entities owned in whole or in part by us or our parent company and/or its shareholders.
- Government agencies, regulators, accreditors, law enforcement, and other authorities entitled to such personal information pursuant to law or regulation.
- Authorized distributors of our organizations’ products and/or services.
- A third party with a legitimate educational interest pursuant to FERPA or similar applicable state regulation.
- Service providers fulfilling a business purpose for us, such as:
- Professional advisers including, but not limited to, auditors, bankers, insurers, legal counsel, and professional subject matter experts.
- Organizations we contract with for articulation (e.g., transfer of credit agreements) and affiliation purposes (e.g., internship/externship agreements).
- Organizations we contract with to improve our platform, products, and services, improve student retention, our internal inquiry model system, and overall user experience.
- Organizations we contract with for employee benefit purposes.
- Background check providers for job candidates and/or students.
SUBMITTING A REQUEST
To exercise your access, disclosure, and deletion rights, as a California resident, you must submit a verifiable consumer request to us. We have outlined the procedure below.
1. You may submit your request6 online at: Privacy Data Request. This is the most efficient way to make your request. You may also contact us via our toll-free number (844) 783-8627 or at Privacy Matters.
2. You will be asked to provide certain personal information that we will review against our records to validate your identity.
We require this personal information to prevent identity theft or fraud. In some cases we may need to contact you for additional information or clarification to comply with your request. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. We will only use personal information provided to verify your identity or the requestor's authority to make the request, or as permitted by law.
HOW TO CONTACT US
If you have any questions about our privacy practices, contact us at Privacy Matters or by telephone at 847-781-3600. You may also write to us at the following address:
DigitalCraftsAttn: Privacy Matters
231 N. Martingale Road
Schaumburg, IL 60173
