Last Updated: December 31, 2021
Residents of California should also review Appendix A – California Specific Privacy Notice below for information about your rights and how to submit a privacy request, including requests that we not “sell” your personal information by clicking Do Not Sell My Personal Information.
This Policy does not apply to our privacy obligations under FERPA and similar state laws. To learn more, please visit here.
1. WE COLLECT INFORMATION ABOUT YOU IN SEVERAL WAYS
We collect information directly from you. For example, when you request information about, apply for, or enroll in our Services. We might also collect information when you sign up for an event or to receive communications from us. Categories of personal information we may collect about you include:
- full name
- email address
- physical postal address
- billing address
- phone number(s)
- social security number
- tax identification number
- identification number
- date of birth
- education records, including transcripts, course assignments (e.g., papers), and tests
- job title
- alien registration number
- financial data and documents
- academic data and documents
- identity verification data and documents
We collect information you post or submit. We collect information you post in a public space while using our Services. This may include posts you make on course discussion boards or our social media pages. We may also collect your social media profile information. We might also collect the information you submit to us, such as through live chat or text messaging services.
We collect job application information. If you apply for a job through our Services, we collect the information you include in your application. For example, this may include the name and address of your employer(s) and your employment history.
We collect demographic information. We may collect your age, gender, race or ethnicity.
We collect Audio/Visual Information. For example, when you visit certain facilities, we may capture or collect photographs and record audio and video at the facility (including through the use of CCTV cameras and other technologies). We may also record audio during service or other calls.
We collect device and location information. We collect the type and make of device you use to access our Services. We may also collect information about the browser you are using. We might look at what site you came from or what site you visit when you leave us. We may collect information across the devices you use to access our Services. If you use our mobile app, we might look at how often you use the app and where you downloaded it. This might include your device identification number, IP address, or mobile operating system. We may also collect location information,, when you access our apps or our websites, or when your WiFi or Bluetooth-enabled device connects to, or is detected by, the wireless networks at our facilities.
We collect information from you passively. We use tracking technologies like browser cookies and web beacons to collect information passively about you. This includes when you use our Services or when you otherwise interact with our websites, apps, ads, or our emails that we or our vendors send to you. We may collect information from your devices when your device connect to or is detected by our WiFi services. This information may include your location, MAC address, signal strength, date/time stamp, wireless access point location (which can be associated with a physical location), device manufacturer and operating system, and your use of the WiFi, such as which websites you visit.
We may record your interactions with our sites, including page and app interaction information and other electronic communications and content from your use of the Services (such as content entry, mouse movements, screen captures, what areas of the websites you visit and for how long, what search terms or other data you enter, and what products or content or links you view and click on), and methods used to browse away from the page. We may also embed technologies (which may include, for example, web beacons, tags, and pixels) in the emails and other communications we or our vendors send to you to help us understand how you interact with those messages, such as whether and when you opened a message or clicked on any content within the message. We may engage or otherwise permit other parties to also collect information through the Services in these ways.We collect information from third parties. We may receive information about you from other sources. This might include our business partners, our education partners, and organizations that administer college-level exams, manage records related to education, disciplinary records, or provide scholarships, grants, and other financial aid. It might also include other academic institutions. It also includes friends who use our referral features. We may also get information about you from social media sites.
We combine information we obtain from different sources. We may combine information that we collect offline with information we collect online. We may also combine information you submit or that we track across multiple devices. We may also combine information we collect from you with information we get about you from others.
2. WE USE INFORMATION IN A VARIETY OF WAYS
We use your information to communicate with you. This includes determining your eligibility for our services, maintaining or servicing your account, providing customer service, processing or fulfilling orders and transactions, verifying your information, processing payments, providing financial aid processing, providing advertising or marketing services, providing analytic services, collections activity, responding to your questions or inquiries or notifying you if you won a promotion. We will also use your information to send you information about your account or about our relationship. We may send push notifications to you from our mobile application, SMS text messaging services, or other similar services that you have opted into.
We use your information to identify and authenticate. We use your information to verify when you access your account.
We use information to provide you with our Services. This includes determining your eligibility for our services and providing educational services. It also includes fulfilling your requests.
We use your information to understand your interests and develop and improve our Services. We may use your information to improve and develop our platform, products and Services. This may include improving student retention and user experience. We may also use your information to customize your experience with us. For example, we may use your information to determine your interest in our Services or to better understand what other products and services interest you.
We use your information for marketing purposes. We may provide you with information about our Services or new products and services or other ads. We might use your information to serve you with ads. These might be third-party offers or products we think you might find interesting. We may also have our business partners serve you with advertisements for our Services. We may use your personal information to send these communications.
We use information for security purposes. This may include detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity. It may also include debugging to identify and repair errors that may impair our existing intended functionality, undertaking activities to verify, maintain, improve, upgrade or enhance the quality or safety of a service, device or system that we own, manufacture, manufacture for, or control. We may also use information to protect our family of companies, students, prospective students, applicants, website visitors, alumni, employees and others. It may also include protecting our Services.
We use your information for employee management purposes. This may include applicant and candidate evaluations or interviews. It may also include maintaining your employee file for work authorization, payment and salary records, and employee development such as reviews or disciplinary actions.
We use your information to support our mission, objectives and goals. We may conduct internal research for technological development and demonstration, conduct and analyze results of surveys, focus groups, interviews, employer feedback and other assessment measures.
We use information as otherwise permitted or required by law or as we may notify you. This includes using your information for our legitimate business needs.
3. WE SHARE INFORMATION WITH SERVICE PROVIDERS AND THIRD PARTIES
We share your information within the Perdoceo Education Corporation family of companies. This includes our network of schools and the Career Education Scholarship Fund.
We share your information with service providers who perform services on our behalf. For example, this may include payment processors or companies that provide identity verification services. It may also include companies that fulfill transcript requests or send communications on our behalf. We may also share your information with others that provide educational services on our behalf.
We share information with our business partners. For example, this may include third parties that provide educational products and services related to our business. It may also include social media sites or a third-party that co-sponsors a promotion.
We share information with those who help pay for your education. We may share your information with authorized family members or employers who help pay your tuition. We may also share information with banks or other lenders that provide education loans to you. For more information about how we treat education records and financial information, please visit here.
We share information with third parties for marketing purposes. This may include third parties that serve ads on our behalf. This may also include third parties in whose products or services we believe you may be interested. These third parties may also share your information with others. These third parties may use your information for their own marketing purposes or the marketing purposes of others. This may include the delivery of interest-based advertising.
Your information may be publicly accessible while using our Services. Information you submit in chat rooms or other features can be seen by others who use those features. This may include information about you, such as the courses you are enrolled in or your contact information. Online Live Chat or classroom sessions may be recorded for use by enrolled students. Students who participate with their web camera engaged or utilize a profile image are consenting to have their video or image recorded.
We will share your information with any successor to all or part of our business. For example, if all or part of our business is sold, we may share your personal information with the new owner. This may include as part of an asset sale, corporate reorganization, or other change of control. We may also share your personal information with others as they conduct diligence.
We share information with regulating agencies and government entities. We may share your information with the organizations that analyze our education practices and provide our qualifications to operate as an educational institution. We may also share information with government agencies if we believe we are required to do so in order to comply with the law or as part of our business operations. For more information about how we treat education records and financial information, please visit here.
We will share information to comply with the law or to protect ourselves or others. This includes responding to a court order or lawfully issued subpoena. It could also include sharing information if a government agency or investigatory body requests it. We might share information when we are investigating potential fraud or for disciplinary purposes. We may also share information if you are the winner of a sweepstakes or other contest with anyone who requests a winner’s list.
We will share information for other reasons we may describe to you.
4. YOU HAVE CERTAIN CHOICES ABOUT HOW WE USE YOUR INFORMATION
You can opt-out of receiving certain of our communications. To stop receiving our promotional emails or text messages, follow the unsubscribe instructions in any promotional communication you receive from us. Note that even if you opt-out of our promotional communications, you may still receive transactional and emergency notification communications from us.
If you would like to opt-out of marketing e-mails, you may also click “UNSUBSCRIBE” on any marketing e-mail. You may also contact PRIVACY MATTERS.
If you would like to opt-out of text messages you may also respond to any text with the keyword “STOP” or “UNSUBSCRIBE”. You may also contact PRIVACY MATTERS .
If you would like to be added to our Do Not Call list, please call us and request to be added to the Do Not Call list or contact PRIVACY MATTERS. We will accept your Do Not Call request by any reasonable method of communication such as e-mail, fax, text message, or mail.
Note that even if you opt-out of our promotional communications, you may still receive mandatory and emergency notification communications from us.
You can control the tools on your mobile devices. For example, you can turn off the GPS locator or push notifications on your mobile phone.
5. YOUR CALIFORNIA PRIVACY RIGHTS
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 shared personal information with third parties for their direct marketing purposes. To make a request, please send us an email at firstname.lastname@example.org or write to us at the address listed below. Indicate in your email or letter that you are a California resident making a “California Shine the Light” inquiry.
The California Consumer Privacy Act (CCPA) of 2018 provides consumers residing in California with rights relating to the access, deletion, and sharing of personal information for California residents. Please see Appendix A – California Specific Privacy Notice below for all required information, including your rights under the CCPA and how to submit a request.
6. 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 email at email@example.com or write to us at the address listed below. Indicate in your email or letter that you are a Nevada resident making a “Nevada Internet Privacy” inquiry.
7. OUR SERVICES AND CHILDREN
8. WE USE SECURITY MEASURES
The Internet is not 100% secure. We cannot promise that our Services or the use of the Services will be completely safe. We encourage you to use caution when using the Internet. We use reasonable means to safeguard personal information under our control. User IDs and passwords are needed to access certain areas of our Services. It is your responsibility to protect your username and password(s).
9. STORAGE OF INFORMATION
10. WE MAY LINK TO THIRD PARTY SITES
Our Services may contain links to other third-party sites that are not governed by this Policy. If you click on a link to a third-party site, you will be taken to a site we do not control. We are not responsible for third-party sites or their privacy practices. We suggest that you read the privacy policies of those sites carefully.
11. HOW TO CONTACT US
If you have any questions about our privacy practices contact us at firstname.lastname@example.org or by telephone at 888-983-3498. You may also write to us at the following address:
Trident University International
Attn: Privacy Matters
5757 Plaza Drive; Suite 100
Cypress, CA 90630
Appendix A – California Specific Privacy Notice
1. YOUR RIGHTS UNDER THE CCPA
Except as otherwise provided by applicable California law, note that for purposes of these requests under this Section 1 of this Notice, personal information does not include information about job applicants, employees and other of our personnel; information about employees and other representatives of third-party entities we may interact with; or information we have collected as a service provider. 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.
Your Right to Request Information about Personal Information Collected. You have the right to request the following about personal information we collected about you over the past 12 months:
- The categories of your personal information we collected.
- The categories of sources from which we collected the personal information.
- Our business or commercial purpose for collecting or selling the personal information.
- The categories of third parties with whom we shared the personal information.
- The specific pieces of personal information we have collected about you.
Your Right to Request Disclosure of Personal Information We Sold or Disclosed for a Business Purpose. You have the right to request that we disclose:
- The categories of your personal information that we sold and the categories of third parties to whom we sold the personal information.
- The categories of your personal information that we disclosed for a business purpose.
Your Right to Request Deletion of Certain Personal Information We Collected. You have the right to request that we delete your personal information that we maintain about you, subject to certain exceptions.
You have the right to opt-out of sales, within the meaning of the CCPA, of certain information subject to the CCPA. You are not required to have an account with us to exercise your right to opt-out of the sale of your personal information to third parties. Please submit your request to email@example.com. If you do not have an account, please include your name, address and email address. You may also submit this request online by visiting the following site: DO NOT SELL MY PERSONAL INFORMATION.
We do not sell the personal information of consumers we actually know are less than 16 years of age.
Your Right to Nondiscrimination. We do not discriminate if you choose to opt-out or exercise any of your rights under the CCPA. This includes, but is not limited to (i) charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties, (ii) providing a different level or quality of goods or services, or (iii) suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services. 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. You will be given the opportunity to provide prior opt-in consent (which you may revoke at any time).
2. CATEGORIES OF PERSONAL INFORMATION
We have collected the following categories (as enumerated in the CCPA) of personal information from consumers within the last twelve (12) months:
(Yes or NO)
|A. Identifiers.||A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.||YES|
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment data, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.||YES|
|C. Protected classification characteristics under California or federal law.||Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).||YES|
|D. Commercial information.||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||YES|
|E. Biometric information.||Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.||NO|
|F. Internet or other similar network activity.||Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.||YES|
|G. Geolocation data.||Physical location or movements.||YES|
|H. Audio or Visual data.||Audio, electronic, visual, or similar information.||YES|
|I. Professional or employment-related information.||Current or past job history or performance evaluations.||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)).||Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.||YES|
|K. Inferences drawn from other personal information.||Profile reflecting a person’s preferences, characteristics, household characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||YES|
3. CATEGORIES OF SOURCES
We obtain the categories of personal information listed above in Section 2 of this Notice from the following categories of sources:
- Direct interactions. We collect personal information when you request information about our products and services or sign up for an event. We might also collect information when, for example, you sign up to receive communications from us. You may give us your information by filling in forms or by corresponding with us by email, phone, fax, mail or in-person. This includes, but is not limited to, personal data you provide when you:
- Purchase our products or services or request information;
- Discuss your interest in and/or your eligibility for our services with our staff, including but not limited to, personnel in Admissions, Academics, Financial Aid, Registrar’s Office, Student Advising, Faculty, Career Services or Student Accounts.
- Apply for financial aid, scholarships, grants or other types of financial aid (e.g., military tuition assistance, employer tuition assistance, etc.).
- Create or register for a user account on our website, virtual campus, student portal, mobile application or job/hiring information site;
- Subscribe to our publications such as newsletters, alumni communications, career services information, investor updates or webinars;
- Request marketing be sent to you such as by email, mail, phone, live chat or text messaging;
- Interact with our website such as through our application center, FA calculator, live chat, or providing your contact information;
- Interact with our social media pages, commenting on or liking posts;
- Enter a competition, sweepstakes, or promotion;
- Complete a survey or other assessment tool.
- Provide information in-person at industry events, school events or other venues, or by phone, fax, online chat, text message, or email; or
- Provide information or apply for a position on our job information website.
- Automated technologies or interactions. As you interact with our website or mobile application, we may automatically collect data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We may also receive technical information about you if you visit other websites employing our cookies. Please see About Our Ads for further details.
- Vendors we engage to provide services on our behalf.
- Other parties or publicly available sources. We may receive personal information about you from various other parties and public sources.
We may combine information that we have collected offline with information we collected online. Or we may combine information we get from another party with information we already have.
4. USE OF YOUR PERSONAL INFORMATION
5. DISCLOSURE AND SALE OF PERSONAL INFORMATION
|Category of Personal Information||In the preceding twelve (12) months, we have disclosed the following categories of personal information to third parties for a business or commercial purpose:||In the preceding twelve (12) months, we have “sold” the following categories of personal information|
|A. Identifiers.||YES||NO (We do not sell information to third parties as defined under the CCPA).|
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||YES||NO (We do not sell information to third parties as defined under the CCPA).|
|C. Protected classification characteristics under California or federal law.||YES||NO (We do not sell information to third parties as defined under the CCPA).|
|D. Commercial information.||YES||NO (We do not sell information to third parties as defined under the CCPA).|
|E. Biometric information.||NO||NO (We do not sell information to third parties as defined under the CCPA).|
|F. Internet or other similar network activity.||YES||NO (We do not sell information to third parties as defined under the CCPA).|
|G. Geolocation data.||YES||YES|
|H. Audio or Visual data.||YES||NO (We do not sell information to third parties as defined under the CCPA).|
|I. Professional or employment-related information.||YES||NO (We do not sell information to third parties as defined under the CCPA).|
|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||NO (We do not sell information to third parties as defined under the CCPA).|
|K. Inferences drawn from other personal information.||YES||NO (We do not sell information to third parties as defined under the CCPA).|
6. CATEGORIES OF THIRD PARTIES
- We may disclose the categories of personal information in Section 3 of this Notice for a business or commercial purpose to the following categories of third parties:
- 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 organizations products and/or 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 platform, products, and services, improve student retention, our internal inquiry model system, and overall user experience.
- Organization we contract with for employee benefit purposes.
- Background check providers for job candidates and/or students.
7. SUBMITTING A REQUEST
To exercise your access, disclosure, and deletion rights, as a California resident, you must submit a verifiable consumer request to us. We have outlined the procedure below.
- You may submit your request online at: Privacy Data Request. This is the most efficient way to make your request. You may also contact us via our toll-free number 888-983-3498 or at firstname.lastname@example.org.
- You will be asked to provide certain personal information that we will review against our records to validate your identity. We require this personal information to prevent identity theft or fraud. In some cases we may need to contact you for additional information or clarification to comply with your request. 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 to verify your identity or the requestor’s authority to make the request, or as permitted by law.
8. HOW TO CONTACT US
If you have any questions about our CCPA privacy practices, contact us at email@example.com or toll-free at 888-983-3498. You may also write to us at the following address:
Trident University International
Attn: Privacy Matters
5757 Plaza Drive; Suite 100
Cypress, CA 90630