Adtalem Online Privacy Statement
Changes to this Statement
This Online Privacy Statement (“Statement”) may be updated periodically to reflect changes to our information practices. Any changes will be effective immediately upon the posting of the revised Statement on our site. When we make changes to this Statement, we will revise the “Latest update” below. If the changes are significant, we will notify you by providing notice on this website prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices. If you do not agree to the new Statement, the best way to exercise your privacy rights is to stop using this site – you may also request that we remove your personal data.
Latest update: July 25, 2018
Adtalem Global Education and its related companies or affiliates (“Adtalem,” “we,” or “us”) respect the privacy of every individual who visits our web sites or responds to our promotions. As a data controller, we intend to act reasonably to protect your privacy, but we cannot guarantee security against issues beyond our control. To better protect your privacy, we provide this Statement explaining our online information practices and the choices you can make about the way your information is collected and used. This notice applies to all information collected or submitted on our web site, unless otherwise posted.
Information Collected From You
For purposes of this Statement, personal data means information that is collected about you. We do not collect any personal data from you unless you freely consent to provide it. Examples of personal data that we may collect from you include name, email address, age, and phone number. If you do not want your personal data collected, do not submit it to us.
As is true of most sites, we gather certain information automatically. This information may include Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/or clickstream data to analyze trends in the aggregate and administer the site.
We do not intend to collect any personal data from a child under the age of 16. If we become aware that we have unknowingly collected personal data from a child under the age of 16, and do not have parent or guardian consent on file, we will delete such personal data from our records. If you have a question, or would like to review or delete your child’s personal data, contact us at the address below.
Where Personal Data is Processed
We process personal data at our operating offices and in any other places where the parties involved with the processing are located. For questions, please contact us at the address below.
Personal Data Retention
Personal data will be kept for the time necessary to fulfill the purposes for which it is processed or as required by applicable laws or regulations. You may request that we suspend or remove your personal data at any time by contacting us at the address below.
How We Use the Personal Data We Collect and on Which Legal Basis
We use the personal data we collect from you for a variety of different business purposes and according to the appropriate legal basis for processing. The following is a summary of how and under which legal basis we may use your personal data.
- We use your personal data to fulfill a contract with you and provide you with our services. This includes to:
- Provide payment processing and account management, including registration for online and in person events
- Contact you regarding your inquires or to resolve a dispute
- Troubleshoot problems with your account or as otherwise necessary to provide you customer services
- Recruit and evaluate potential candidates to join Adtalem
- We use personal data to pursue our legitimate interests where your rights and freedoms do not outweigh these interests. This includes to:
- Personalize, measure, and improve our advertising based on your advertising customization preferences
- Deliver targeted marketing, service updates, event announcements, and promotional offers based on your communications preferences
- Measure the performance of our email marketing campaigns
- Monitor and improve the information security of our site and mobile applications
- With your consent, we may use your personal data to:
- Provide you with marketing communications via telephone calls, email, SMS or text
- Provide you with marketing communications from third parties
- Customize third party advertising you might see on third party websites
- We may use your personal data to comply with applicable legal obligations to which we are subject.
Sharing Personal Data That You Provide With Others
We may share your personal data with companies (including our affiliates) that perform services on our behalf, for example, companies that help process credit card payments. Our service providers are required by contract to protect the confidentiality of the personal data we share with them and to use it only to provide specific services on our behalf.
Generally we do not give or sell our information, including your personal data, to outside companies except in the following situations:
- Blogs and Online Communities
You may choose to submit information as part of a blog or online community offered by us. Any information you choose to post there, including personal data, can be read, collected, or used by other members of the blog or online community.
- Social Media Features
Our websites include links to social media sites. These links do not collect your IP address nor set cookies on your computer. The social media links are hosted directly on our website. When you click these links, your interactions with those third-party social media sites are governed by the privacy statement of the company(ies) providing them.
- Surveys and Contests
We may provide you the opportunity to participate in surveys or contests on our website. If you participate, we will request certain personal data from you. Participation in these surveys or contests is completely voluntary and you therefore have a choice whether or not to disclose your information. The requested personal data includes contact information (such as name and email address), and demographic information (such as zip code).
We use third-party service providers for marketing purposes and to conduct surveys or contests. These companies are prohibited from using our participants’ personal data for any other purpose. We will not share the personal data you provide through a contest or survey with other third parties without your express consent.
We use voluntary third-party surveys to collect customer/member feedback for a variety of our products, services and offerings, such as, but not limited to:
- Conferences (both attendee feedback and to assess topics and speakers for upcoming conferences)
- Certificate courses
- Virtual classroom series
Additionally, information collected by our voluntary third-party surveys is used to:
- market, validate, and promote customer/attendee use of products
- to customize and improve the website
- to assess the quality of our customer service
In some cases, with the member’s permission, participant feedback collected in surveys is used as testimonial content on our website.
We may post your feedback concerning our website and/or products on our websites or on other social media sites. Such feedback may contain personal data such as your name, when you freely consent. If you wish to remove your feedback, contact us at firstname.lastname@example.org.
We may share your personal data with subcontractors that provide us with services. These services may include, among other things, helping to provide services that you request, helping to create or maintain our databases, helping to research and analyze the people who request services or information from us, helping to provide marketing or solicitation materials for our products or services, and/or helping to process payment card information.
- Law Enforcement
We may report to law enforcement agencies any activities that we reasonably believe to be unlawful, or that we reasonably believe may aid a law enforcement investigation into unlawful activity. In addition, we reserve the right to release your personal data to law enforcement agencies if we determine, in our sole judgment, that either you have violated our policies, or the release of your personal data may protect the rights, property or safety of you or another person.
- Permitted by Law
We may share your personal data with others as required by, or permitted by law. This may include sharing your personal data:
- With governmental entities
- With third parties in response to subpoenas or court orders
- For other legal process
- To exercise our legal rights
- To defend against legal claims that have been brought against us
- To defend against legal claims that we determine might be brought against us
- To disclose the personal data we collect through this site to prevent or investigate a possible crime, such as fraud or identity theft
- To enforce our Terms and Conditions or other agreements that govern your use of this site
- To protect the rights, property or safety of our company, our users, or others
Your personal data may be transferred to another entity (either an affiliated entity or an unrelated third party) in connection with a merger, reorganization, dissolution or similar corporate event. If such a transfer were to occur, the acquiring entity’s use of your personal data will be subject to this Statement. In such a situation, you will be provided with notice that a transfer of your personal data may occur, and you will be given an opportunity to opt-out of the transfer of your personal data.
We may collect other personal data from you that is not collected along with your name. Although most of this information is collected from you when you freely consent to submit it, some of it may be collected automatically by use of a “cookie.”
Cookies are small text files that are downloaded onto your computer or other device when you access a website. Cookies allow the website to recognize your device and store information about your preferences or past actions. For instance, cookies may enable us to remember your viewing preferences without requiring you to re-type a user name and password or be used by third party content providers such as news feeds. Cookies may also allow us to track your status or progress when ordering products from us.
What kinds of Cookies do we use?
- Strictly Necessary Cookies
Certain cookies we use are necessary for the website to function. Strictly necessary cookies are typically set in response to actions or services that you request, such as setting your privacy preferences or putting items in a shopping basket. If you set your browser to block these cookies, some parts of the site will not work.
- Functionality Cookies
We use functionality cookies to remember the choices you make, such as your user name, language or text size. These cookies help to improve your experience on the site by providing a more personalized service.
- Performance Cookies
- Third Party Cookies
Some of our webpages use third-party services or software, such as maps, online videos, or social networking features. Many of these services may set cookies on your device. These third party cookies help us enhance your website experience and improve our services by tracking your online activity. We have no direct control over the information that is collected by these cookies.
- Marketing and Advertising Cookies
We partner with third party advertisers may use tracking pixels that set cookies to assist with delivering online advertising that is relevant to your interests. We, or our advertising partners, may build a profile of your interests and show you targeted advertisements on other sites. You can opt out of almost all advertising cookies by updating your preferences on youronlinechoices.com or aboutads.info. Opting out of advertising cookies won't stop you seeing adverts, just that they won't be tailored specifically to you.
Can Cookies be Blocked?
If you choose, you can set your browser to reject cookies or you can manually delete individual or all of the cookies on your computer by following your browser’s help file directions. However, if your browser is set to reject cookies or you manually delete cookies, this may alter your access and use of some of the pages and features on our website.
Third-Party Websites – Remember the Risks When You Use the Internet
Any links to third-party websites on our site are provided solely as a convenience to you. If you use these links, you will leave our site. We do not endorse or make any representations about these websites, or any information, or other products or materials found there, or any results that may be obtained from using them. If you follow a link to any of these websites, please note that these websites have their own privacy and cookie statements. We do not accept any responsibility or liability for these privacy and cookie statements. Please check these privacy and cookie statements before you submit any personal data to these websites.
How We Protect Personal Data
We take appropriate security measures by maintaining certain administrative, technical, and physical measures to help protect against loss, misuse or unauthorized access, disclosure, alteration or destruction of the personal data in our control.
While we do our best to protect your personal data, we cannot guarantee the security of any information that you disclose to us. You are solely responsible for maintaining the secrecy of any passwords or other account information.
If you have any questions about our website security, you can email us at email@example.com.
Do Not Track Signals
Some web browsers and devices permit you to broadcast a preference that you not be “tracked” online. At this time we do not modify your experience based upon whether such a signal is broadcast.
We may participate in behavioral-based advertising. This means that a third party may use technology, such as a cookie on your browser or a web beacon, to identify you on our website so that they can provide advertising about products and services tailored to your interest. If you would like to opt-out of third-party behavioral advertising that collects information on your use of this website, 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 preferences-mgr.truste.com or if located in the European Union by visiting youronlinechoices.eu. Please note, you will continue to receive generic ads.
Google Analytic Data
- Google Analytics for Display Advertising
- DoubleClick cookie for interest-based advertising
- or customize Google Display Network ads by using the Ads Preferences Manager
If you are an individual located in the EEA only, you will have the following rights with regard to your personal data:
- Right of Access
You may request details of your personal data that we hold. We will confirm whether we are processing your personal data and we will disclose supplementary information including:
- the categories of personal data;
- the sources from which it originated;
- the purpose and legal basis for the processing;
- the expected retention period; and
- the safeguards regarding personal data transfers to non-EEA countries, subject to the limitations set out in applicable statutes, regulations and other laws.
- Right of Correction
We will comply with your request to edit and update incorrect personal data promptly.
- Right to be Forgotten
At your request, we will delete your personal data promptly if
- it is no longer necessary to retain your personal data;
- you withdraw the consent which formed the basis of your personal data processing;
- you object to the processing of your personal data and there are no overriding legitimate grounds for such processing;
- the personal data was processed illegally; or
- the personal data must be deleted for us to comply with our legal obligations.
We will inform any third parties we might have shared your personal data with of your deletion request.
We will decline your request for deletion if processing of your personal data is necessary:
- to comply with our legal obligations;
- in pursuit of a legal action;
- to detect and monitor fraud; or
- for the performance of a task in the public interest.
- Right to Restrict Processing of your Personal Data
At your request, we will limit the processing of your personal data if:
- you dispute the accuracy of your personal data;
- your personal data was processed unlawfully and you request a limitation on processing, rather than the deletion of your personal data;
- we no longer need to process your personal data, but you require your personal data in connection with a legal claim; or
- you object to the processing pending verification as to whether an overriding legitimate ground for such processing exists.
- Right to Notice Related to Correction, Deletion, and Limitation on Processing
In so far as it is practicable, we will notify you of any correction, deletion, and/or limitation on processing of your personal data.
- Right to Data Portability
At your request, we will provide you free of charge with your personal data in a structured, commonly used and machine readable format, if:
- You provided us with personal data;
- The processing of your personal data is based on your consent or required for the performance of a contract; or
- The processing is carried out by automated means.
- Right to Object
Where we process your personal data based upon our legitimate interest then you have the right to object to this processing.
- Right Not to be Subject to Decisions Based Solely on Automated Processing
You will not be subject to decisions with a legal or similarly significant effect (including profiling) that are based solely on the automated processing of your personal data, unless you have given us your explicit consent or where they are necessary for a contract with us.
- Right to Withdraw Consent
You have the right to withdraw any consent you may have previously given us at any time. If you withdraw your consent, this will not affect the lawfulness of our collecting, using and sharing of your personal data up to the point in time that you withdraw your consent. Even if you withdraw your consent, we may still use your information that has been fully anonymized and does not personally identify you.
- Right to Complain to a Supervisory Authority
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.
If you wish to contact us in connection with the exercise of your rights listed above, please email us at firstname.lastname@example.org. We will respond to your written request as soon as possible. Unless we notify you at the time of your request, we will not charge you any fee in connection with the exercise of your rights.
International Transfer of Personal Data
Personal data provided to us by users outside of the United States (“U.S.”) may be transferred to other countries such as the U.S., where data protection laws may differ from those of your home country. By providing us with your information you acknowledge that your information will be transferred to the U.S. and processed on servers in the U.S. However, all reasonable steps will be taken to protect your privacy in accordance with the applicable data protection laws.
How You Can Request, Correct or Update Your Personal Data
If you would like to initiate a request for information Adtalem has collected about you and/or request modification or deletion of personal data, click here to access our Data Privacy Request Portal.
How to Contact Us
Should you have other questions or concerns about this Statement, contact us at:
Adtalem Global Education
3005 Highland Parkway
Downers Grove, IL 60515-5799