LAST UPDATED: January 3, 2020
“Personal Information” is information that identifies you as an individual or relates to an identifiable individual, such as:
- Postal address
- Email address
- Telephone number
- Educational records
- Work history
- Emergency contact details
- Demographic data, including, where relevant, racial and ethnic origin, health and disability information
- National and student ID numbers, such as a social security or tax ID
- Membership in professional or industry associations
- Credit and debit card number
- Bank account details
- Profile picture
- Social media account ID
Collection of Personal Information
We and our service providers collect Personal Information in a variety of ways, including:
- Through the Services
–We collect Personal Information through the Services, for example, when you visit one of our sites, apply for admission, or maintain an ongoing relationship with us as a student.
–From you during your course of study or period of enrollment with us.
–We collect Personal Information from you offline, such as when you complete an application for admission, fill out a form at an education or career fair, apply for a student ID card,
participate in a promotion, or contact our call center.
- From Other Sources
–We receive your Personal Information from other sources, for example:
- our affiliates, partners and services providers, including, but not limited to the Common Application System (CAS);
- private and publicly available databases;
- application references and/or recommendation writers; and
- other educational institutions.
–If you connect your social media account to your Services account, you will share certain Personal Information from your social media account with us, for example, your name, email address, photo, list of social media contacts, and any other information that may be or you make accessible to us when you connect your social media account to your Services account.
Use of Personal Information
We, our affiliates and our service providers use Personal Information for legitimate business purposes including:
- Providing the functionality of the Services and fulfilling your requests.
–To provide the Services’ functionality to you, such as arranging access to your registered account and providing you with related assistance.
–To respond to your inquiries and fulfill your requests, when you contact us via one of our online contact forms or otherwise, for example, when you send us questions, suggestions, or complaints.
–To complete your transactions and provide you with related assistance.
–To send administrative information to you, such as changes to our terms, conditions and policies.
–To allow you to send messages to another person if you choose to do so.
We will engage in these activities to manage our contractual relationship with you and/or to comply with a legal obligation.
- Providing you with our newsletter and/or other marketing materials and facilitating social sharing
–To send you marketing related emails, with information about our services and other news about us.
–To facilitate social sharing functionality that you choose to use.
We will engage in this activity with your consent or where we have a legitimate interest.
- Analysis of Personal Information for business reporting and providing personalized services.
–To analyze or predict our users’ preferences in order to prepare aggregated trend reports on how our digital content is used, so we can improve our Services.
–To better understand you, so that we can personalize our interactions with you and provide you with information and/or offers tailored to your interests.
–To better understand your preferences so that we can deliver content via our Services that we believe will be relevant and interesting to you.
We will provide personalized services either with your consent or because we have a legitimate interest.
- Allowing you to participate in sweepstakes, contests or other promotions.
–We may offer you the opportunity to participate in a sweepstakes, contest or other promotion.
–Some of these promotions have additional rules containing information about how we will use and disclose your Personal Information.
We use this information to manage our contractual relationship with you.
- Aggregating and/or anonymizing Personal Information.
–We may aggregate and/or anonymize Personal Information so that it will no longer be considered Personal Information. We do so to generate other data for our use, which we may use and disclose for any purpose.
- Accomplishing our business purposes.
–For data analysis, for example, to improve the efficiency of our Services;
–For audits, to verify that our internal processes function as intended and are compliant with legal, regulatory or contractual requirements;
–For fraud and security monitoring purposes, for example, to detect and prevent cyberattacks or attempts to commit identity theft;
–For developing new services;
–For enhancing, improving, or modifying our current services;
–For identifying usage trends, for example, understanding which parts of our Services are of most interest to users;
–For determining the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users; and
–For operating and expanding our business activities, for example, understanding which parts of our Services are of most interest to our users so we can focus our energies on meeting our users’ interests.
We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or because we have a legitimate interest.
Disclosure of Personal Information
We disclose Personal Information:
- To partnering institutions that receive services from us.
- To our third-party service providers, to facilitate services they provide to us.
–These can include providers of services such as website hosting, data analysis, payment processing, order fulfillment, information technology and related infrastructure provision, customer service, email delivery, auditing, and other services.
- To third parties, to permit them to send you marketing communications, consistent with your choices.
- To third-party sponsors of sweepstakes, contests, and similar promotions.
- By using the Services, you may elect to disclose Personal Information
–On message boards, classroom discussion forums, chat, profile pages, blogs and other services to which you are able to post information and content (including, without limitation, our Social Media Pages). Please note that any information you post or disclose through these services will become public and may be available to other users and the general public.
Other Uses and Disclosures
We also use and disclose your Personal Information as necessary or appropriate, especially when we have a legal obligation or legitimate interest to do so:
- To comply with applicable
–This can include laws outside your country of residence.
- To respond to requests from public and government authorities.
–These can include authorities outside your country of residence.
- To cooperate with law enforcement.
–For example, when we respond to law enforcement requests and orders.
- For other legal reasons.
–To enforce our terms and conditions; and
–To protect our rights, privacy, safety or property, and/or that of our affiliates, you or others.
- In connection with a sale or business transaction.
–We have a legitimate interest in disclosing or transferring your Personal Information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings). Such third parties may include, for example, an acquiring entity and its advisors.
“Other Information” is any information that does not reveal your specific identity or does not directly relate to an identifiable individual
- Browser and device information
- App and/or Website usage data
- Information collected through cookies, pixel tags and other technologies
- Demographic information and other information provided by you that does not reveal your specific identity, such as your gender or date of birth
- Information that has been aggregated in a manner such that it no longer reveals your specific identity
If we are required to treat Other Information as Personal Information under applicable law, then we may use and disclose it for the purposes for which we use and disclose Personal Information as detailed in this Policy.
Collection of Other Information
We and our service providers collect Other Information in a variety of ways, including:
- Through your browser or device
- Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version and the name and version of the Services (such as the App) you are using. We use this information to ensure that the Services function properly.
- Through your use of the Apps
- When you download or use the Apps, we and our service providers may track and collect App usage data, such as the date and time the App on your device accesses our servers and what information and files have been downloaded to the App based on your device number.
- Using cookies
- Using pixel tags and other similar technologies
- Pixel tags (also known as web beacons and clear GIFs) may be used to, among other things, track the actions of users of the Services (including email recipients), measure the success of our marketing campaigns, and compile statistics about usage of the Services and response rates.
- Using Adobe Flash technology (including Flash Local Shared Objects (“Flash LSOs”)) and other similar technologies
- We may use Flash LSOs and other technologies to, among other things, collect and store information about your use of the Services. If you do not want Flash LSOs stored on your computer, you can adjust the settings of your Flash player to block Flash LSO storage using the tools contained in the Website Storage Settings Panel. You can also go to the Global Storage Settings Panel and follow the instructions (which may explain, for example, how to delete existing Flash LSOs (referred to as “information”), how to prevent Flash LSOs from being placed on your computer without your being asked, and how to block Flash LSOs that are not being delivered by the operator of the page you are on at the time). Please note that setting the Flash Player to restrict or limit acceptance of Flash LSOs may reduce or impede the functionality of some Flash applications.
- IP Address
- Your IP address is automatically assigned to your computer by your Internet Service Provider. An IP address may be identified and logged automatically in our server log files whenever a user accesses the Services, along with the time of the visit and the page(s) that were visited. Collecting IP addresses is standard practice and is done automatically by many websites, applications and other services. We use IP addresses for purposes such as calculating usage levels, diagnosing server problems and administering the Services. We may also derive your approximate location from your IP address.
- Physical Location
- We may collect the physical location of your device by, for example, using satellite, cell phone tower or Wi-Fi signals. We may use your device’s physical location to provide you with personalized location-based services and content. We may also share your device’s physical location, combined with information about what advertisements you viewed and other information we collect, with our marketing partners to enable them to provide you with more personalized content and to study the effectiveness of advertising campaigns. In some instances, you may be permitted to allow or deny such uses and/or sharing of your device’s location, but if you do, we and/or our marketing partners may not be able to provide you with the applicable personalized services and content.
Uses and Disclosures of Other Information
We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. In some instances, we may combine Other Information with Personal Information. If we do, we will treat the combined information as Personal Information as long as it is combined.
We seek to use reasonable organizational, technical and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contacting Us” section below.
CHOICES AND ACCESS
Your choices regarding our use and disclosure of your Personal Information
We give you choices regarding our use and disclosure of your Personal Information for marketing purposes. You may opt-out from:
- Receiving email marketing from us: If you no longer want to receive marketing-related emails from us on a going-forward basis, you may unsubscribe at any time; however, we may continue to send you transactional or relationship messages, such as press releases, newsletters, or account information
- Receiving other types of marketing communications from us: If you no longer want to receive marketing-related communications from us on a going-forward basis, you may unsubscribe at any time; however, we may continue to send you transactional or relationship messages, such as press releases, newsletters, or account information
- Our sharing of your Personal Information with affiliates for their direct marketing purposes: If you would prefer that we discontinue sharing your Personal Information on a going-forward basis with our affiliates for their direct marketing purposes, you may unsubscribe at any time; however, we may continue to send you transactional or relationship messages, such as press releases, newsletters, or account information
- Our sharing of your Personal Information with unaffiliated third parties for their direct marketing purposes: If you would prefer that we discontinue sharing your Personal Information on a going-forward basis with unaffiliated third parties for their direct marketing purposes, you may unsubscribe at any time; however, we may continue to send you transactional or relationship messages, such as press releases, newsletters, or account information.
We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt-out of receiving marketing-related communications from us, we may still send you important administrative messages, from which you cannot opt-out.
How you can access, change or delete your Personal Information
If you would like to request to review, correct, update, suppress, restrict or delete Personal Information that you have previously provided to us, or if you would like to request to receive an electronic copy of your Personal Information for purposes of transmitting it to another organization (to the extent this right to data portability is provided to you by applicable law), you may contact us using the “Contact Us” information below. We will respond to your request consistent with applicable law.
In your request, please make clear what Personal Information you would like to have changed, whether you would like to have your Personal Information suppressed from our database or otherwise let us know what limitations you would like to put on our use of your Personal Information. For your protection, we will only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.
Please note that we need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion (e.g., when you make a payment, you may not be able to change or delete the Personal Information provided until after the completion of such transaction).
If you are a resident of California, under 18 and a registered user of the Services, you may ask us to remove content or information that you have posted to the Services by writing to us at the Contact Us address below. Please note that your request does not ensure complete or comprehensive removal of the content or information, as, for example, some of your content may have been reposted by another user.
We retain Personal Information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law.
The criteria used to determine our retention periods include:
- The length of time we have an ongoing relationship with you and provide the Services to you (for example, for as long as you are a student of ours);
- Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
- Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).
THIRD PARTY SERVICES
In addition, we are not responsible for the information collection, use, disclosure or security policies or practices of other organizations, such as Facebook, Apple, Google, Microsoft, RIM or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including with respect to any Personal Information you disclose to other organizations through or in connection with the Apps or our Social Media Pages.
THIRD PARTY ADVERTISING
We use third-party advertising companies to serve advertisements regarding goods and services that may be of interest to you when you access and use the Services and other websites or online services.
If you are in the U.S., you may download the AppChoices app at www.aboutads.info/appchoices to opt out in mobile apps.
Use of Services by Minors
The Services are not directed to individuals under the age of sixteen (16), and we do not knowingly collect Personal Information from individuals under sixteen (16).
Jurisdiction and CROSS-BORDER TRANSFER
Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services you understand that your information will be transferred to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Information.
If you are located in the European Economic Area (“EEA”): Some of the non-EEA countries are recognized by the European Commission as providing an adequate level of data protection according to EEA standards (the full list of these countries is available here). For transfers from the EEA to countries not considered adequate by the European Commission, we have put in place adequate measures, such as standard contractual clauses adopted by the European Commission to protect your Personal Information. You may obtain a copy of these measures by following this link.
THIRD PARTY PAYMENT SERVICE
ADDITIONAL INFORMATION FOR INDIVIDUALS IN THE EEA
If you are located in the EEA, you also may lodge a complaint with a data protection authority for your country or region or where an alleged infringement of applicable data protection law occurs.
PRIVACY NOTICE FOR CALIFORNIA RESIDENTS
Your Rights and Choices: The CCPA provides consumers with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
- Access to Specific Information and Data Portability Rights. You have the right to request that University of St. Augustine for Health Sciences disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable request, we will disclose to you: (i) the categories of personal information we collected about you; (ii) the categories of sources for the personal information we collected about you; (iii) our business or commercial purpose for collecting or selling that personal information; (iv) the categories of third parties with whom we share that personal information, if any; (v) the specific pieces of personal information we collected about you (also called a data portability request); (vi) if we sold or disclosed your personal information for a business purpose, two separate lists disclosing: (a) sales, identifying the personal information categories that each category of recipient purchased; and (b) disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
- Deletion Request Rights. You have the right to request that University of St. Augustine for Health Sciences delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct all appropriate service providers to delete) your personal information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to: (i) complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you; (ii) detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities; (iii) debug products to identify and repair errors that impair existing intended functionality; (iv) exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law; (v) comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.); (vi) engage in public or peer-reviewed research in accordance with Section 1798.105 (d)(6) of the CCPA; (vii) enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us; (viii) comply with a legal obligation; or (ix) make other internal and lawful uses of that information that are compatible with the context in which you provided it.
- Exercising Access, Data Portability, and Deletion Rights. To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by email: Privacy@usa.edu
Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must: (i) provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative; and (ii) describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. 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 in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
- Response Timing and Format. We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Non-Discrimination. We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not: (i) deny you goods or services; (ii) charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties; (iii) provide you a different level or quality of goods or services; (iv) suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services. However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.
Changes to Our Privacy Notice. We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the website and update the notice’s effective date.
Contact Information: If you have any questions or comments about this notice, the ways in which University of St. Augustine for Health Sciences collects and uses your information described in this section, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:
University of St. Augustine for Health Sciences
700 Windy Point Drive
San Marcos, CA 92069