Updated June 18, 2019
1. INFORMATION WE COLLECT FROM YOU
• Personal Information – we collect your personal information when you complete forms on our website, and when you communicate with us via contact forms, email, live chat, telephone, or text. The personal information we collect from you includes Name, Address, Phone Numbers, Email, Communication Preferences, Time Zone, Social Security Number, Date of Birth, Military Status/Affiliation, and Demographics Information (such as Age, Gender, Income, etc). We only collect Personal Information that you provide to us voluntarily. Your personal information is only collected with your consent and it is collected for the purpose of responding to inquiries regarding our school and services, providing our services and information about our services, processing orders and contacting you regarding promotions and offers that you are opted in to receive. We also collect personal information from our Students and Graduates in order to keep contact information current, respond to requests and process orders. Documents, materials or computer screens that display Social Security numbers shall be shown only to authorized employees and shall be kept out of public view at all times. Social Security numbers may only be used by authorized employees for legitimate business reasons.
• Non-Personal Information – we collect your non-personal information to track our website usage. The non-personal information we collect from you includes Computer and Server IP Addresses, Browser Versions, Devices used to access the Sites, Geographic Location, Time Spent on Site, Pages Visited, Website Searches and any custom events (e.g. clicking a link, filling out a form, etc). This information is used only with your consent and we use it to help ABC evaluate and improve our Sites for future visitors as well as assist with marketing campaigns and business analysis.
• Personal Financial Information – we collect Personal Financial Information from you if you are enrolling in an ABC educational program or purchasing some kind of a product from our Sites. The financial information we collect from you includes Credit Card Numbers, Expiration Dates, Security Codes, Bank Account Number, Routing Number, Credit Scores, and your Personal Billing Information associated with your credit card and bank accounts which is your name, billing address, telephone number. All financial information is used only with your consent in relation to the purchases and transactions you authorize through our institution. Your Personal Financial Information is collected for the purposes of completing enrollment applications, processing purchases and tuition payments, applying for payment plans and other purchases made on our Sites. Financial information is securely stored internally by ABC, as required by law and best business practices.
• Additional Information – In addition to the above-mentioned categories, we also collect additional information via our student or alumni portals, our enrollment applications and pre-enrollment surveys. The information we collect includes your Education Status and Grades (Transcripts, Diploma, GED, Certificates, etc), Work Status, Opinions on Programs, Opinions on Employees, Opinions on Affiliates, Education Goals, Exam Grades, Vocational Rehabilitation File Numbers, Blog Comments, Name Change Documents (Marriage Certificate, Licenses, Passport, IDs, etc) and Business Information (Name, Phone Number, Website, Email, Hours, etc) This Additional Information is collected from you only with your consent and for the purpose of updating our student and graduate records, complying with licensing and approval requirements, improving our programs and Sites and assisting with our marketing campaigns and business analysis.
2. HOW WE COLLECT YOUR PERSONAL DATA
• Direct interactions – we collect your personal data when you fill out our forms online on our Sites. We may also collect your personal data via phone, email, text message, live chat, via your student or alumni center, via an e-commerce payment or purchase, an online enrollment application, or all other forms of tuition payments.
• Automated technologies – We collect your computer and server IP addresses, browser versions, devices used to access the Sites, referral sources that brought you to our site and geographic location. This is non-individual specific information that is commonly tracked by most many websites. We collect Non-Personal Information via commonly used website tools, such as cookies and IP logs. See section 7 below that describes Cookies.
3. TRANSFER OF YOUR INFORMATION
We transfer your Personal Information, Non-Personal Information, Financial Information, and Additional Information (described in section 1) to the United States and to Canada, from the country you are located in when you visit our Sites. ABC does not transfer your data to a separate organization or individual, though cookies may collect your information directly when you visit the Site. ABC collects and stores your data in its databases in California. That means if you visit the Site while you are in Europe, your personal data is stored in our databases in another country—the United States of America. We only perform this transfer to the United States in a non-repetitive manner, and this transfer is necessary to ABC’s compelling legitimate interests which relate to answering inquiries for more information about our school and programs, update student/graduate contact information, improve our programs and Sites, improve our marketing campaigns, process payments or purchases and provide our services.
4. HOW WE STORE YOUR INFORMATION
We protect your information by security safeguard, including physical, organizational, and technological measures, appropriate to the sensitivity of the information.
• Personal Information – Personal Information collected is stored in our databases and server, only accessible by select members of ABC Inc. staff. We save this category of information for an indefinite period of time.
• Non-Personal Information – Non-Personal Information collected is stored in our databases and server, only accessible by select members of ABC Inc. staff. We save this category of information for an indefinite period of time.
• Personal Financial Information – All Personal Financial Information is digitally encrypted and stored in our databases and server, with restricted access available only to certain members of ABC’s staff. It is common that we store this category of information for 90 days, but this time frame varies, and we may save this information for an indefinite period of time.
• Additional Information – Additional information is stored in our databases and server, only accessible by select members of ABC Inc. staff. We save this category of information for an indefinite period of time.
5. HOW WE USE YOUR PERSONAL DATA
• Personal Information – We use your Personal Information to deliver services you purchase, to respond to your requests for information, to contact you regarding services in which we believe you may be interested and to ask you questions about your interests and your experience on the Sites. If at any point you wish to no longer be contacted, you can opt out from these communications. You may opt out of email communication by clicking here and submitting the required information. You can also opt out of communications through sending us an email or calling us on the telephone at (800) 795-3294. If you are a student, we will also use your Personal Information and Student Records to support and monitor your progress through the academic program in which you are enrolled, offer you various student support services, ask you questions regarding your satisfaction with the program, maintain your academic records and contact you regarding services that we believe may be of interest.
• Non-Personal Information – We use Non-Personal information to do market research on what pages you visit on our website, what devices you used to access our website, what browsers you prefer, and other online activity / browsing preferences. Collecting this data allows us to know what we can do to improve the user experience for our website visitors. We store non-personal information securely internally and do not share this information with any other third-party company.
• Personal Financial Information – Financial Information we collect is used only to complete a financial transaction. This information is used to process tuition payments, complete an e-commerce transaction or apply for financing options. If you are not currently enrolled in a program and have no outstanding, pending, or contractual financial obligation, you may ask that we delete your financial information and we will do so subject to legal, regulatory, licensing and accreditation obligations.
• Additional Information – We use all additional information only in relation to the students’ or graduates’ internal school records. We use demographic information we collect to improve our educational programs and marketing campaigns in the future. Exam grades, student transcripts, attendance information, and more are shared with 3rd parties (such as higher education institutes) only with written approval from the student/graduate.
6. SHARING YOUR INFORMATION
“We may choose to disclose nonpublic personal information about you, the consumer, to a third party for compensation.”
ABC works with other animal organizations, non-profits, rescues, and various pet-related businesses. We may share the Personal Information we have collected with these pet-related organizations & businesses. We collaborate with these organizations so they can reach out to you with special offers and/or courses in your region that relate to the topic you expressed interest in with ABC. You have the right, at any time, to prompt us to discontinue sharing your Personal Information with third parties.
ABC also will share your personal information with other organizations that we work with on a need to know basis or as required by regulatory laws. This includes but may not be limited to third party service providers or contractors such as I.T. professionals and computer programmers (whom we hire to help perform services to visitors of our Sites), licensing, certifying or accrediting organizations (whom we work with to maintain our educational institution) and law enforcement like police departments or parties to a lawsuit or similar legal proceeding (in the event information is subpoenaed due to some kind of an investigation or court case). ABC will share personal information (such as names, grades, transcripts,) with third party organizations (higher education organizations,.) only with your written approval.
8. PRIVACY FOR USERS UNDER AGE 18
The Sites do not knowingly collect information from (a) users under the age of 17 and does not offer products, services or activities targeted at users under the age of 17, or (b) individuals older than 17, but not yet legal majority, whose registration or participation on the Sites has not been authorized by their parent or legal guardian.
9. YOUR PRIVACY RIGHTS
Your California Privacy Rights: California residents have the right to obtain once a year (1) a list of the categories of your personal information disclosed by ABC, if any, to third parties for direct marketing purposes during the immediately preceding calendar year, and (2) the names and addresses of all third parties’ that received personal information from ABC, if any, for the third parties’ direct marketing purposes during the prior calendar year. You can contact us at Animal Behavior College, 25104 Rye Canyon Loop, Santa Clarita, CA 91355, via email at firstname.lastname@example.org, or by telephone at (800) 795-3294 to request this information.
For Canadian residents, you are entitled to a copy of our policies and practices relating to management of personal information and you may obtain a copy by contacting us at Animal Behavior College, 25104 Rye Canyon Loop, Santa Clarita, CA 91355, via email at email@example.com. In addition, you may request information about the existence, use, and disclosure of your personal information and given access to your personal information that we have. You may challenge our compliance with Canada’s Personal Information Protection and Electronic Documents Act, Schedule 1 Section 5 (S.C. 2000 c. 5) by contacting the Administrative Department, at 25104 Rye Canyon Loop, Santa Clarita, CA 91355, via email at firstname.lastname@example.org, or by telephone at (800) 795-3294.
For those located in the EU, you have the rights of:
• Access: this means you have the right to obtain from ABC confirmation as to whether or not personal data concerning you is being processed and obtain access to your personal data. You are also entitled to the following information 1. The categories of personal data collected about you; 2. The recipients or categories of recipient to whom your personal data have been or will be disclosed; 3. Where possible, the period of time your personal data will be stored, or, if not possible, the criteria used to determine that period; 4. The right to request from the ABC rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing; 5. The right to lodge a complaint with a supervisory authority; 6. Where the personal data are not collected from you, any available information as to their source; and 7. The existence of automated decision-making, including profiling, and if so, meaningful information about the logic involved, as well as the significance and the consequences of such processing.
• Rectification: you have the right without undue delay to have ABC correct inaccurate personal data concerning you.
• Erasure: you have the ‘right to be forgotten’ where the retention of such data infringes the General Data Protection Regulation or other European Union Law which ABC must obey. In particular, you have the right to have your personal data erased and no longer processed where the personal data are no longer necessary in relation to the purposes for which they are collected or otherwise processed, where you have withdrawn your consent or objects to the processing of personal data concerning you, or where the processing of your personal data does not otherwise comply with the GDPR.
• Restriction on processing: You have the right to restrict processing of your personal data by ABC where 1. You dispute the accuracy of your personal data but ABC shall have sufficient time to verify the accuracy of your personal data processed by ABC; 2. ABC’s use of your personal data is unlawful but you do not want ABC to erase it and request restriction of use of your personal data instead; 3. ABC no longer needs your personal data for the purposes of the processing, but you need ABC to hold your personal data because you need it to establish, exercise, or defend legal claims; 4. You have objected to ABC processing your data but we need to verify whether we have overriding legitimate grounds to use your personal data.
• Objection to processing: You have the right to object at any time to processing of your personal data for direct marketing purposes. You also have the right to object to processing of your personal data by ABC where ABC (1) processes your data for ABC’s legitimate interest or (2) where the processing is necessary for the performance of a task carried out in the public interest unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims.
• Portability: you have the right to receive the personal data you have provided to ABC in a structured, commonly used and machine-readable format, and you have the right to transmit your personal data to another controller without hindrance from ABC where you initially provided consent to us to use your personal data or where we used your personal data to perform a contract with you, and where the processing is carried out by automated means. You have the right to have your personal data transmitted directly from ABC to another controller where it is technically feasible to do so.
EU residents also have the right to lodge a complaint of an alleged infringement of the General Data Protection Regulation (“GDPR”) with a supervisory authority in your member state where you are a habitual resident or work or where the alleged infringement occurred.
10. OBJECTION TO PROCESSING
For EU residents, you have the right to object to processing at any time. You also have the right to withdraw your consent to the processing of your personal data at any time where ABC’s processing of your data is based on your consent. You may object to the processing of your personal data or withdraw your consent to the processing of your personal data by contacting us at email@example.com and submitting the required information. You can also send us an email or call us on the telephone at (800) 795-3294.
For all individuals, if you have been receiving emails, calls, texts or similar communications from us, it is because at some point you shared your information with ABC. When you request additional information on any one of our programs, you opt in and consent to being contacted with additional information. If at any point you wish to no longer be contacted, you can opt out from these communications. You may opt out of email communication by clicking here and submitting the required information. You can also opt out of communications through sending us an email or calling us on the telephone at (800) 795-3294.You can also request have any information collected on you removed by ABC at any time. Once removal is requested, a system administrator will delete the appropriate data from our databases and server. ABC, Inc. reserves the right to not remove your information if (1) ABC is required by any law to maintain @this information, (2) if ABC needs this information to establish, exercise or defend against legal claims, (3) if the data is still necessary in relation to the purpose for which it was collected and processed, or (4) if the data is necessary for exercising the right of freedom of expression and information.
12. CONTACT INFORMATION
Our full details are Animal Behavior College, 25104 Rye Canyon Loop, Santa Clarita, CA 91355. You may contact us via email at firstname.lastname@example.org, or by telephone at (800) 795-3294.
Last Updated: June 18, 2019