APPENDIX A - STATE SPECIFIC PRIVACY INFORMATION & RIGHTS
This Appendix contains additional information relevant to specific state laws and regulations regarding data privacy, including the rights that may be available to residents of these states. The information below applies if you are a resident of the specific state, and the relevant rights will be available from the date that the state laws and regulations become effective. This Appendix supplements the content provided in our Privacy Policy and should be read in conjunction with our Privacy Policy.
CALIFORNIA RESIDENTS: YOUR CALIFORNIA PRIVACY RIGHTS
The California Consumer Privacy Act of 2018, as amended, and any implementing regulations (collectively, the “CCPA”) provides consumers residing in California with rights relating to the access, deletion, correction, sharing, and selling of personal information for California residents. We have adopted this information to comply with the CCPA, inform you of your rights under the CCPA and how to submit a request. Any terms defined in the CCPA have the same meaning when used in this notice. The Notice at Collection for California residents can be found in Section 1 of the Privacy Policy. If at any time you have questions about this information, please contact privacymatters@trident.edu or call toll-free 888-983-3498. Residents of California have the following rights subject to applicable exceptions and limitations set forth in the CCPA:
Your Right to Know. You have the right to request that we disclose personal information that we have collected about you. This includes a request for any or all of the following:
- The categories of personal information we have collected about you;
- The categories of sources from which the personal information is collected;
- The categories of personal information that we sold or disclosed for a business purpose about you;
- The categories of third parties to whom the personal information was sold or disclosed for a business purpose; and The specific pieces of personal information that we have collected about you on or after January 1, 2022.
Your Right to Delete. You have the right to request that we delete any personal information that we have collected from you, subject to certain exceptions.
our Right to Correction. You have the right to request that we correct inaccurate personal information about you.
Your Right to Opt-Out of Sale/Sharing. You have the right to request that we not “sell” or “share” your personal information to or with third parties, as defined under the CCPA. As described in the Privacy Policy, cookies and other technologies may be used on our sites to recognize you and receive information about your activity on our websites. This helps customize content and show you more relevant ads. Please note that if you make a request to opt-out of sale or sharing and you would like to opt-out of cookie-based tracking for behavioral advertising purposes, you can manage your cookie preferences on our site. Additionally, you can opt-out of certain uses of cookies for advertising purposes by visiting www.aboutads.info/choices and https://optout.privacyrights.info. Your selections are specific to the device, website and browser you are using. Your selections are deleted whenever you clear your cookies or browser's cache.
Your Right to Nondiscrimination. You have the right not to receive discriminatory treatment for the exercise of privacy rights conferred by the CCPA. We do not discriminate if you choose to opt-out or exercise your rights under the CCPA. 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. Participation is voluntary and you may withdraw at any time by emailing us at privacymatters@trident.edu.
Additional Information for California Residents:
Sensitive Personal Information. Depending on your level of interaction with us, we may collect sensitive personal information, such as Social Security numbers, driver's license, state identification and passport data, race, ethnicity, medical information, and account information. We do not use or disclose sensitive personal information other than to provide you with our Services, as permitted by California law. For example, sensitive personal information may be used to process admissions and financial aid applications. We do not sell or share sensitive personal information for the purpose of cross-context behavioral advertising.
Categories of Personal Information. The categories of personal information collected from and about consumers are listed in Section 4 of the Privacy Policy.
Categories of Sources. The categories of sources from which we may obtain your personal information are listed in Section 3 of the Privacy Policy.
Use and Disclosure of Your Personal Information. We may use and/or disclose the following categories of personal information we collect about you for one or more business or commercial purposes.
|
Category |
In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose: |
|---|---|
|
A. Identifiers. |
YES |
|
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). |
YES |
|
C. Protected classification characteristics under California or federal law. |
YES |
|
D. Commercial information. |
YES |
|
E. Biometric information. |
NO |
|
F. Internet or other similar network activity. |
YES |
|
G. Geolocation data. |
YES |
|
H. Sensory data. |
YES |
|
I. Professional or employment-related information. |
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)). |
YES |
|
K. Inferences drawn from other personal information. |
YES |
|
L. Sensitive Personal Information. |
YES |
Categories of Third Parties. We may disclose your personal information for a business purpose to the categories of third parties described in Section 6 of the Privacy Policy, including:
- 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 organization's 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 Services, improve student retention, our internal inquiry model system, and overall user experience.
- Background check providers for job candidates and/or students.
“Sales” and “Sharing” of Personal Information. The following categories of personal information may have been sold or shared with a third-party for advertising purposes:
- Personal identifiers, such as name, phone number and e-mail address;
- Internet or other electronic network activity information, such as IP address, type of browser, device identifiers, device event information, make and model of the device, and mobile advertising identifiers; and
- Information about your use of the Services.
Each of the categories of personal information listed above may be sold to or shared with the following categories of third parties: advertising publishers that place advertisements on our behalf, advertising partners, and education partners.
Exercising Your California Privacy Rights. To exercise any privacy rights under California law, a California resident may submit their request as follows:
- Complete the online Privacy Request Form. This method is the most efficient way to make your request. You can also choose to contact us by sending an e-mail to privacymatters@trident.edu or calling us via our toll-free number: 888-983-3498.
- Current and former employees, job applicants, and contractors should send an e-mail to the HR Service Center.
For certain requests, you will be asked to provide certain personal information that we will review against our records to validate your identity and eligibility. We will take reasonable steps to verify your identity prior to responding to your requests. The verification steps may vary depending on the sensitivity of the personal information and whether you have an account with us. 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. We may deny certain requests, or fulfill a request only in part, based on our legal rights and obligations.
The California "Shine the Light" law of 2003 provides consumers residing in California the right to ask us one time each year if we have disclosed their personal information to third parties for the third parties' direct marketing purposes. To make a request, please send us an e-mail at privacymatters@trident.edu or call toll-free 888-983-3498. You may also write to us at the address listed below. Indicate in your e-mail or letter that you are a California resident making a "California Shine the Light" inquiry.
COLORADO RESIDENTS: YOUR COLORADO PRIVACY RIGHTS
The Colorado Privacy Act (“CPA”) gives residents of Colorado certain rights around the collection, use, and sharing of their personal data.
Your Rights. If you are a resident of Colorado, you have the right under the CPA, subject to several exceptions and limitations, to:
- Request to know what personal data has been collected about you and to access that information;
- Request to correct inaccuracies in your personal data;
- Request deletion of your personal data (subject to certain exemptions);
- Request a copy of your personal data;
- Request to opt-out of the sale (as defined in the CPA) of your personal data;
- Request to opt-out of targeted advertising; and
- Appeal a denial of any request
A Colorado resident may submit their request by completing the online Privacy Request Form. This is the most efficient way to make your request. You can also submit your request by contacting us at privacymatters@trident.edu or calling us via our toll-free number: 888-983-3498. To request to opt-out of “targeted advertising” (as defined in the CPA), you can separately update your cookie preferences on our site. Additionally, you can opt-out of certain uses of cookies for advertising purposes by visiting www.aboutads.info/choices and https://optout.privacyrights.info. Your selections are specific to the device, website and browser you are using. Your selections are deleted whenever you clear your cookies or browser's cache.
You will be asked to provide certain personal information that we will review against our records to validate your identity and eligibility. We will take reasonable steps to verify your identity prior to responding to your requests. The verification steps will vary depending on the sensitivity of the personal data and whether you have an account with us. We may deny certain requests, or fulfil a request only in part, based on our legal rights and obligations. If you are not satisfied with the outcome of your request, you may submit an appeal by sending an e-mail to privacymatters@trident.edu with “Colorado Appeal” in the subject line.
Note that for purposes of this section, personal data does not include information about job applicants, employees and other of our personnel; or information about employees and other representatives of third-party entities we may interact with.
CONNECTICUT RESIDENTS: YOUR CONNECTICUT PRIVACY RIGHTS
The Connecticut Data Privacy Act (“CTDPA”) gives residents of Connecticut certain rights around the collection, use, and sharing of their personal data.
Your Rights. If you are a resident of Connecticut, you have the right under the CTDPA, subject to several exceptions and limitations, to:
- Request to know what personal data has been collected about you and to access that information;
- Request to correct inaccuracies in your personal data;
- Request deletion of your personal data (subject to certain exemptions);
- Request a copy of your personal data;
- Request to opt-out of the sale (as defined in the CTDPA) of your personal data;
- Request to opt-out of targeted advertising; and
- Appeal a denial of any request
You will be asked to provide certain personal information that we will review against our records to validate your identity and eligibility. We will take reasonable steps to verify your identity prior to responding to your requests. The verification steps will vary depending on the sensitivity of the personal data and whether you have an account with us. We may deny certain requests, or fulfil a request only in part, based on our legal rights and obligations. If you are not satisfied with the outcome of your request, you may submit an appeal by sending an e-mail to privacymatters@trident.edu with “Connecticut Appeal” in the subject line.
Note that for purposes of this section, personal data does not include information about job applicants, employees and other of our personnel; or information about employees and other representatives of third-party entities we may interact with.
NEVADA RESIDENTS: YOUR NEVADA PRIVACY RIGHTS
If you reside in Nevada, you have the right to ask us at any time to review the personal information that we have collected through our website(s) or the Services we provide and to request changes. Subject to the terms of applicable Nevada law, you may also submit a request directing us not to sell certain covered personal information we have collected or will collect about you. To make a request, please send us an e-mail at privacymatters@trident.edu or write to us at the address listed below. Indicate in your e-mail or letter that you are a Nevada resident making a "Nevada Internet Privacy" inquiry.
VIRGINIA RESIDENTS: YOUR VIRGINIA PRIVACY RIGHTS
The Virginia Consumer Data Protection Act (“CDPA”) gives residents of Virginia certain rights around the collection, use, and sharing of their personal data.
Your Rights. If you are a resident of Virginia, you have the right under the CDPA, subject to several exceptions and limitations, to:
- Request to know what personal data has been collected about you and to access that information;
- Request to correct inaccuracies in your personal data;
- Request deletion of your personal data (subject to certain exemptions);
- Request a copy of your personal data;
- Request to opt-out of the sale (as defined in the CDPA) of your personal data;
- Request to opt-out of targeted advertising; and
- Appeal a denial of any request
A Virginia resident may submit their request by completing the online Privacy Request Form. This is the most efficient way to make your request. You can also submit your request by contacting us at privacymatters@trident.edu or calling us via our toll-free number: 888-983-3498. To request to opt-out of “targeted advertising” (as defined in the CDPA), you can separately update your cookie preferences on our site. Additionally, you can opt-out of certain uses of cookies for advertising purposes by visiting www.aboutads.info/choices and https://optout.privacyrights.info. Your selections are specific to the device, website and browser you are using. Your selections are deleted whenever you clear your cookies or browser's cache.
You will be asked to provide certain personal information that we will review against our records to validate your identity and eligibility. We will take reasonable steps to verify your identity prior to responding to your requests. The verification steps will vary depending on the sensitivity of the personal data and whether you have an account with us. We may deny certain requests, or fulfil a request only in part, based on our legal rights and obligations. If you are not satisfied with the outcome of your request, you may submit an appeal by sending an e-mail to privacymatters@trident.edu with “Virginia Appeal” in the subject line.
Note that for purposes of this section, personal data does not include information about job applicants, employees and other of our personnel; or information about employees and other representatives of third-party entities we may interact with.
