PRIVACY

OVERVIEW
Everything we do is focused on improving student success and educational outcomes. Students have the right to benefit from their data and enhance their likelihood to complete their academic and learning journey. As FERPA-compliant stewards of institutional information, we prioritize student privacy.

We only collect data critical to improving educational outcomes upon request at partner institutions. We do not sell data to third parties. We work to protect data through industry best practices, including encryption and de-identification.

With specific security or privacy questions, please email privacy@civitaslearning.com.

PRIVACY POLICY

Effective: August 3, 2017

OUR COMMITMENT TO PRIVACY
Your privacy is important to us. In this Privacy Policy, we describe how we collect, use, and disclose information that we obtain about visitors to our website, www.civitaslearning.com (“the Site”), information received from our customers, and the choices you can make about the way your information is collected and used. It also describes your choices regarding use, access and correction of your personal information.

By visiting the Site you agree that your personal information will be handled as described in this Policy. Your use of our Site and any dispute over privacy, is subject to this Policy.

INFORMATION WE COLLECT ABOUT YOU
We may collect information about you directly from you as well as automatically through your use of our Site or Services. In addition we may receive information from educational institutions where you currently are or previously have been enrolled as a student. This helps us to update, expand and analyze our records, identify new customers, and provide products and services that may be of interest to you.  If you provide us personal information about others, or if others give us your information, we will only use that information for the specific reason for which it was provided to us.

Information We Collect Directly From You
The type of information we collect from you depends on your interaction with our Applications and our Services.  Most of our Applications require users have registered accounts for access. You may register for an Application directly or you may be registered by your educational institution. Registration information may include your email address, name, and business title if appropriate. If you contact us, we collect your name, email address, phone number, and any information that you choose to provide to us.

If you are a student user or a student advisor, we may also collect from you information about your or your advisees’ degree and career goals, course plans, and any other information you submit to the Application, such as your comments or notes on your goals.

Information that We Collect About You from Your Educational Institution
We may also collect information about you from your educational institution.  This may include information from your educational institution’s student information system or learning management systems.  These databases typically include personal information such as a student’s name, date of birth, student ID, home address, etc…

Information We Collect Automatically
We automatically collect the following information about your use of our Applications through cookies and other technologies: your browser type and operating system; your IP address; how you use the Applications or Services; login and logout time stamps, and the length of time you use our Applications or Services.  We may combine this information with other information that we have collected about you, including, where applicable, your name, and other personal information. Please see the section “Cookies and Other Tracking Mechanisms” below for more information.

We may share your information with third parties who provide services on our behalf to help with our business activities. These companies are authorized to use your personal information only as necessary to provide these services to us.

ACCESS TO YOUR DATA
Upon request, Civitas Learning, Inc. will provide you with information about whether we hold any of your personal information and acknowledge that you have the right to access your personal information. You may access, correct, or request deletion of our personal information by contacting us at privacy@civitaslearning.com. We will respond to your request within a reasonable timeframe.

Civitas Learning, Inc. has no direct relationship with the individuals whose personal data it processes. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct his query to Civitas Learning, Inc.’s client (the data controller). If requested to remove data we will respond within a reasonable timeframe.

Civitas Learning, Inc. will retain your personal information and the data we process on behalf of our Clients for as long as needed to provide services to our Client. Civitas Learning, Inc.  will retain and use this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Civitas Learning, Inc. collects information under the direction of its Clients, and has no direct relationship with the individuals whose personal data it processes. If you are a customer of one of our Clients and would no longer like to be contacted by one of our Clients that use our service, please contact the Client that you interact with directly. We may transfer personal information to companies that help us provide our service. Transfers to subsequent third parties are covered by the service agreements with our Clients.

THE WAY WE USE INFORMATION
We primarily use the information that you provide to us to respond to your requests. We also may use your information, including personal information, for the following purposes:

  • To respond to your inquiries and for other customer service purposes;
  • To personalize your experiences while using our Site and Services;
  • For marketing and promotional purposes. For example, we may use your information, such as your email address, to send you news and newsletters or to otherwise contact you about products or information we think may interest you;
  • To better understand how users access and use our Site both on an aggregated and individualized basis, in order to improve our Site and Services, and for other research and analytical purposes; and
  • As permitted or required by law.

Advertising
We partner with a third party to manage our advertising on other sites. Our third party partner may use cookies or similar technologies in order to provide you advertising based upon your browsing activities and interests. If you wish to opt out of interest-based advertising click here (http://preferences-mgr.truste.com/) [or if located in the European Union click here (http://www.youronlinechoices.eu/)]. Please note you will continue to receive generic ads.

Email Preferences
You may sign-up to receive newsletters and other communications from us.  If you would like to discontinue receiving this information, you may update your email preferences by using the “Unsubscribe” link found in emails we send to you or by contacting us at privacy@company.com.

Tracking and Use of Cookies
We and our third-party service providers use cookies and similar technologies to analyze trends to track information about your use of our Site or Services and gather demographic information about our user base as a whole. We may combine this information with other personal information we collect from you (and our third party service providers may do so on our behalf). You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our website or service.

Cookies: Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Site and Services, to deliver relevant local resources, remember browser preferences, and improve our visitors’ experiences on the site. There are two types of cookies: session and persistent cookies.

  • Session Cookies: Session cookies exist only during an online session. They disappear from your computer when you close your browser or turn off your computer. We use session cookies to allow our systems to uniquely identify you during a session or while you are logged into the Site. This allows us to process your online transactions and requests and verify your identity, after you have logged in, as you move through our Site.
  • Persistent Cookies: Persistent cookies remain on your computer after you have closed your browser or turned off your computer. We use persistent cookies to track aggregate and statistical information about user activity.

Disabling Cookies: Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Site who disable cookies will be able to browse certain areas of the Site, such as the cart feature, which holds your order, but some features may not function.

Third Party Analytics
We use automated devices and applications to evaluate usage of our Site. We use these tools to help us improve our performance and user experiences. These entities may use cookies and other tracking technologies to perform their services. We do not share your personal information with these third parties.

Do-Not-Track Signals
Currently, our systems do not recognize browser “do-not-track” requests. You may, however, disable certain tracking as discussed above (e.g., by disabling cookies).

SECURITY OF MY PERSONAL INFORMATION
We have implemented commercially reasonable precautions to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our best efforts, no data security measures can guarantee 100% security.

Legal Notice
In certain situations, Civitas Learning Inc. may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

We may also disclose your personal information as required by law, such as to comply with a subpoena or other legal process, when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.

INTERNATIONAL TRANSFERS
We store personal information about website visitors and subscribers within the European Economic Area (the “EEA”), the United States and other countries and territories. To facilitate our operations, we may transfer and access such personal information from the United States.

If you are visiting our websites from the EEA or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your personal information to the United States and other jurisdictions in which we operate. By providing your personal information, you consent to any transfer and processing in accordance with this Policy

EU-U.S. PRIVACY SHIELD
Civitas Learning, Inc. participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework.  Civitas Learning, Inc. is committed to subjecting all personal data received from European Union (EU) member countries, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles.  To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List. https://www.privacyshield.gov/list

Civitas Learning, Inc. is responsible for the processing of personal data it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf.  Civitas Learning, Inc.  complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions.

With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Civitas Learning, Inc.  is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission.  In certain situations, Civitas Learning, Inc.  may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

Under certain conditions, more fully described on the Privacy Shield website [https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint], you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.

HOW TO CONTACT US
Should you have other questions or concerns about these privacy policies, please call us at your convenience:

Civitas Learning
100 Congress Ave. Suite 300
Austin, TX 78701

+1-512-625-7175

privacy@civitaslearning.com

CHANGES TO THIS POLICY
This Policy is current as of the Effective Date set forth above. We may change this Policy from time to time, so please be sure to check back periodically. We will post any changes to this Policy on our Site. If we make any changes to this Policy that materially affect our practices with regard to the personal information we have previously collected from you, we will endeavor to provide you with notice in advance of such change by highlighting the change on our Site.