Definitions
“Personal Data” means information relating to an identified or identifiable individual; an identifiable individual is one who can be identified, directly or indirectly, by use of any identifier or characteristic specific to that individual.

“Processing” means the collection, use, transformation or sharing of Personal Data.

“Relevant Law” means any non-U.S. jurisdiction’s personal data protection law that applies to the processing of Personal Data.

A. How We Collect and Use Personal Data
We use the Personal Data that we collect to conduct and promote educational activities as described in more detail below. This Privacy Policy describes how and why we collect and use Personal Data, including circumstances that may involve Processing.

1. Personal Data We Collect
Websites and Mobile Applications
As a membership-based digital learning platform, we obtain certain data automatically when you use our websites or mobile applications, such as your IP address, browser type and device type; and we collect Personal Data you provide, for example when you enter data into form fields or discussion chats. We also Process data through this website or mobile application, as described below. 

We collect your Personal Data when you register for or participate in online courses, programs, video calls, discussions, and other online activities. In some cases, our collection of Personal Data from you in connection with online education activities takes place as part of a “hybrid” program in which you also may participate in person, or as part of a course or program that is ordinarily conducted in person. 

Partners and Service Providers
We use various third party technology partners and service providers, such as payment processors, our hosting provider, an email service, and social networks.

We and our third-party providers use this Personal Data for the primary purposes of providing educational services, managing and improving our services, responding to your requests, and providing you with relevant information including future program offerings.

3. Additional Uses of Personal Data
In addition to the uses described above, we may use your Personal Data for the following purposes. These additional uses may under certain circumstances be based on your consent, or may be necessary to fulfill our contractual commitments to you, for legal compliance, or to pursue our legitimate interest in the following activities:

• Conducting our operations and administering and developing our educational offerings;
• Responding to your requests for assistance or inquiries;
• Providing you with newsletters, articles, service alerts or announcements, event invitations, opportunities, and other information that we believe may be of interest to you;
• At your request, processing and fulfilling transactions for merchandise or other products;
• Providing travel-related services to you at your request;
• Alerting you about a safety or security announcement;
• Conducting research, surveys and similar inquiries to help us understand trends and needs of our applicants, students and others;
• Performing marketing, promotions and advertising, either directly or through third-parties. These activities may include interest-based advertising, targeted advertising and online behavioral advertising in order to increase the likelihood that the content will be of interest to you;
• Ensuring the rights, safety and security of our students, faculty, fellows, employees and others;
• Preventing, investigating, taking action regarding or providing notice of fraud, unlawful or criminal activity, other misconduct, security or technical issues, or unauthorized access to or use of Personal Data, our website or data systems; or
• Responding to subpoenas, court orders, or other legal process; fulfilling and enforcing our agreements and legal rights; protecting the health, safety, rights or property of you, us or others; and meeting legal obligations.

4. Data Retention
We may generally retain Personal Data as follows:

• For as long as may be required under applicable law;
• As needed to resolve disputes or protect our legal rights;
• Where Processing is based on your consent, for the period of time necessary to carry out the Processing activities to which you consented;
• Consistent with the foregoing guidance, some data may be retained indefinitely.

B. How We Share and Disclose Personal Data
Additionally, we may share information as described below:

Service Providers
We share your Personal Data with third-party service providers that complete transactions or perform services on our behalf or for your benefit, such as:

• Payment and contribution processing;
• Customer relationship management services;
• Marketing and analytics;
• Event registration and coordination;
• Providing course platforms or tools that enable or enhance our offerings;
• Course registration and administration;
• Educational operations and collaborations;
• Performing workforce administration and operations;
• System maintenance and security;
• Facilitating other transactions with you; and
• Assisting with our legal compliance.

Third-Party Mobile App Providers
If you use certain of our mobile applications, your mobile device may gather and transfer your Personal Data, including location information, to other applications, functions and tools within your mobile device.

Social Media Platforms
We use services provided by social media platforms (Facebook, Youtube, Google, and LinkedIn, at present) for login credential services, discussion groups and informational pages, to serve targeted ads or sponsored content.  Interaction with your account on these platforms is governed by your respective service agreements on these platforms.

Legal Process, Safety and Terms Enforcement
We may disclose your Personal Data to legal or government regulatory authorities as required by law. We may also disclose your Personal Data to third parties in connection with claims, disputes or litigation, when required by law, or if we determine that disclosure is necessary to protect the health, safety, rights or property of you, us or others.

E. Cookies and Similar Technologies
Whenever you visit or use our websites or online services, we may deploy cookies and related technologies (“Cookies”) to collect certain personal information about you. We use the information in order to enhance and personalize the experience, to help provide our services, to analyze website and service usage, and to help improve the websites and our related services.

We may use third party analytics such as Google Analytics or similar analytics services. For information on how Google processes and collects information using Google Analytics, please see www.google.com/policies/privacy/partners/, and for how to opt out, please see https://tools.google.com/dlpage/gaoptout.

If you have any questions regarding our use of cookies and other similar technologies, please contact us as set forth in the “Contact Us” section below.

F. Rights You May Have
To the extent required by Relevant Law, upon your reasonable and good faith request, we will inform you whether we hold any of your Personal Data and the nature of any Processing. With respect to your Personal Data collected and related Processing, under the Relevant Law you may also be able to:

• request the deletion of your Personal Data; and
• request that we transmit your Personal Data to another party.
• obtain a copy of your Personal Data in an easily accessible format;
• request that we correct or update any of your Personal Data that is inaccurate;
• restrict or limit the ways in which we use your Personal Data;

To submit a request, please complete contact our privacy officer, noted below. Because we want to avoid taking action regarding your Personal Data at the direction of someone other than you, we may need to ask you for information verifying your identity. We will respond to your request within a reasonable timeframe.

Please note that, in certain cases, we may continue to process your Personal Data after you have withdrawn consent or requested that we delete your Personal Data, if we have a legal basis to do so. For example, we may need to retain certain data to comply with an independent legal obligation, for achieving the lawful purposes for which we obtained the data, or for such reasons as keeping our services and operations safe and secure or safeguarding our rights or the rights or safety of others.

If you have any complaints regarding our privacy practices, you may be able to make a complaint to your national data protection authority or other legal authority.

G. User Generated Content
Some of our online activities, such as course websites, discussion areas and our bulletin board Forum, enable users to submit their own content. Please remember that any Personal Data you submit or post as user-generated content in these circumstances could in some cases be seen by others or become public. You should exercise caution when deciding to disclose your personal, financial or other information in such submissions or posts. We cannot prevent others from using that information in a manner that may violate these Disclosures, the law or your personal privacy and safety. We are not responsible for the results of such postings.

H. Updates to the Disclosures
We may update these Disclosures from time to time without prior notice by posting revised Disclosures. You can determine when these Disclosures were last revised by checking the Last Updated date.

I. Our Representative in the European Union is: John F. Greco