Visor del documento
Nombre Último Cambio
Education Management Corporation (en) - Política de Privacidad y Puerto Seguro 19-mar-2017 | 99,99%
Cambio importante indicado
# Antigua Versión Nueva Versión
0 Safe Harbor Privacy Policy
1 Last Updated: 3/16/2015
2 Education Management Corporation (EDMC) and its U.S. subsidiaries comply with the United States (U.S.) – European Union (E.U.) Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework regarding the collection, use, and retention of personal information transferred from E.U. (plus European Economic Area (EEA) member countries) and Switzerland to the United States. EDMC has certified to the Department of Commerce that it adheres to the Safe Harbor Framework including the Privacy Principles of notice, choice, onward transfer, security, data integrity, access and enforcement. To learn more about the Safe Harbor program, and to view EDMC’s certification, please visit http://www.export.gov/safeharbor . Additional information about Safe Harbor is available at https://www.ftc.gov/tips-advice/business-center/guidance/information-eu-residents-regarding-us-eu-safe-harbor-program.
3 We also comply with U.S. laws, including the Family Educational Rights and Privacy Act (FERPA), where applicable, which provide privacy protections for personal information.
4 Consistent with Safe Harbor, EDMC’s adherence to the Safe Harbor Privacy Principles may be limited:
5 To the extent necessary to meet national security, public interest, or law enforcement requirements; or
6 By statute, government regulation, or case law that create conflicting obligations or explicit authorizations, provided that, in exercising any such authorization, our non-compliance with the Safe Harbor Privacy Principles will be limited to the extent necessary to meet the overriding legitimate interests furthered by such authorization.
7 This policy applies only to personal information EDMC transfers from the E.U. (including the EEA countries) and Switzerland to the United States.
8 PRIVACY PRINCIPLES
9 EDMC’s Safe Harbor Privacy Policy, as set forth below, reflects the following principles:
10 1. NOTICE
11 At EDMC, we notify individuals about the purposes for which we have collected and use personal information about them; choices they have regarding certain uses and disclosures of their personal information; how, in general terms, their personal information is stored and secured; the types of third parties to which we disclose their personal information (such as service providers, government agencies, or educational program partners such as clinical or other training programs); and how to contact us with inquiries or complaints (see below).
12 Notice will be provided in clear and conspicuous language either when individuals are first asked by EDMC to provide personal information, or as soon as practicable thereafter. In any event, notice will be provided before EDMC uses or discloses the information for a purpose other than that for which it was originally collected or discloses information to a non-agent third party except as otherwise permitted by Safe Harbor and this policy. Notice may take a variety of forms including this or other EDMC privacy policies, in academic catalogues, in disclosures on forms that request personal information, orally at the time of collection, or other similar means of notice.
13 EDMC may collect health, education, or financial information from the E.U. and Switzerland in the course of operating our business, which includes, among other things, providing online courses to individuals residing in the E.U. and Switzerland, soliciting enrollment by E.U. and Swiss-based individuals, verifying E.U. and Swiss-based financial and other information, and processing payments from individuals in the E.U. and Switzerland.
14 2. CHOICE
15 “Sensitive information,” for purposes of this Safe Harbor Privacy Policy, includes personal information specifying medical or health conditions, racial or ethnic status, political opinions, religious or philosophical beliefs, trade union membership, or sexual orientation and activity. If we transfer Sensitive Information from the E.U. or Switzerland to the U.S., we require (with some exceptions) the individual to opt-in before their Sensitive Information is disclosed to a non-agent third party or used for a purpose other than the original purpose for which the information was collected or the purpose authorized subsequently by the individual through the exercise of opt-in choice.
16 In other cases, where an opt-in is not provided, we give individuals the opportunity to choose (opt-out) whether their personal information will be disclosed to a non-agent third party or used for a purpose incompatible with the purpose for which it was originally collected or subsequently authorized by the individual. For the purposes of this Safe Harbor Privacy Policy, “agent” means any third party, including our service providers, that collects or uses personal information under the instructions of, and solely for, EDMC or to which EDMC discloses personal information for use on EDMC’s behalf.
17 For example, under FERPA our schools may make certain basic “directory” information about students available to the public. Students, however, can opt-out of having their personal information included in our directories.
18 To opt-out of having your personal information disclosed in student directories you should contact the Registrar’s Office for your school, your Registrar’s Office also can assist you in exercising available choices concerning disclosures of personal information that is part of your educational record. To exercise choice in other contexts you can use the opt-out opportunities in e-mail or other communications that you receive from us or you may contact EDMC at 412-395-7815 or by email at EDMCEUsafeharbor@edmc.edu or in writing to:
19 Education Management Corporation
20 ATTN: CISO
21 3. ONWARD TRANSFER
22 EDMC’s disclosure of personal information to non-agent third parties will comply with the Notice and Choice principles, except in certain instances where we may be required by law to disclose your personal information to certain government authorities or third parties, for example to law enforcement agencies in the countries where we or third parties operating on our behalf may operate. Other examples of instances when EDMC may disclose personal information without notice or choice include when responding to court orders, legal process, or to establish or exercise legal rights or defend against claims.
23 4. SECURITY
24 EDMC takes reasonable precautions to protect personal information from loss, misuse, unauthorized access, disclosure, alteration and destruction.
25 5. DATA INTEGRITY
26 EDMC strives to process personal information only in ways that are compatible with the purposes for which it has been collected or subsequently authorized by an individual. We take reasonable steps to ensure that data is accurate, complete, current, and reliable for its intended use.
27 6. ACCESS
28 We provide students with access to personal information in their educational records in accordance with FERPA. In the case of personal information that is not part of a student’s educational records, it is EDMC’s policy to provide individuals with access to personal information that is maintained in EDMC’s files. We provide a mechanism for individuals to correct, amend, or delete their personal information where it is inaccurate, except in cases permitted under Safe Harbor such as:
29 Where the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy in the case in question;
30 Where the rights of persons other than the individual would be violated; or
31 With respect to individual requests for the correction or deletion of information, in cases where EDMC is otherwise legally required to retain the personal information.
32 Whether the personal information is covered by applicable federal laws or regulations or by our Safe Harbor Privacy Principles, EDMC requires that an individual provide reasonable validation of his or her identity before we provide access to that individual’s file. To access your EDMC file and obtain any of the remedies contained in this section, contact us at 412-395-7815 or by email at EDMCEUsafeharbor@edmc.edu or in writing to: Education Management Corporation
33 210 Sixth Avenue, 33rd Floor
34 Pittsburgh, PA 15222
35 ATTN: CISO
36 7. ENFORCEMENT
37 EDMC monitors and assesses its compliance with our Safe Harbor Privacy Policy. Any questions or concerns regarding the collection, use or disclosure of personal information should be directed to us at 412-395-7815 or by email at EDMCEUsafeharbor@edmc.edu or in writing to: Education Management Corporation
38 210 Sixth Avenue, 33rd Floor
39 Pittsburgh, PA 15222
40 ATTN: CISO
41 EDMC will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information in accordance with the principles contained in this Policy.
42 EDMC has further committed to refer unresolved privacy complaints under the US-EU and US-Swiss Safe Harbor Principles to an independent dispute resolution mechanism, the BBB EU SAFE HARBOR, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by EDMC, please visit the BBB EU SAFE HARBOR WEB SITE for more information and to file a complaint.
43 PUBLIC RECORD AND PUBLICLY AVAILABLE INFORMATION
44 In accordance with the Safe Harbor Privacy Principles, in cases where EDMC discloses publicly available information from the E.U. or Switzerland without combining that information with non-public information, our policies on Notice, Choice and Onward Transfer may not apply.
45 CONTACT US
46 If you have any questions or complaints regarding this policy or our privacy practices, contact us at 412-395-7815 or by email at EDMCEUsafeharbor@edmc.edu or in writing to: Education Management Corporation
47 210 Sixth Avenue, 33rd Floor
48 Pittsburgh, PA 15222
49 ATTN: CISO
50 POLICY CHANGES
51 EDMC reserves the right to change this policy from time to time, consistent with the Safe Harbor Privacy Principles. In the event that EDMC, at some point in the future, EDMC were to choose to withdraw from the Safe Harbor program, personal information transferred pursuant to the Safe Harbor would continue to be subject to Safe Harbor requirements and protections even after our withdrawal. Privacy and Cookies Policy
52 This policy was last updated on December 7, 2016.
53 Education Management Corporation (Education Management Corporation, "we" or "our") is committed to protecting any personal information that we maintain about you. Consistent with our Privacy Principles , we want you to understand what kinds of information we may collect from you, how this information may be used, the steps we take to protect it, choices you have regarding our use and disclosure of personal information about you, and other information about our privacy practices. This Privacy Policy (this "Policy") applies to the online collection of information by our websites, webpages and mobile applications that link to or otherwise adopt this Policy.
54 This privacy policy is divided into sections for the convenience of the reader. If you would like to jump to a particular section, follow the links below:
55 What types of information are collected through this site or mobile application?
56 Does your website use cookies or similar technologies?
57 What choices do I have about online tracking and the placement of cookies on my device?
58 How is my information used?
59 What types of choices do I have about your collection and use of personal information about me?
60 Can I access and request correction of personal information I provide through the website or mobile application?
61 How may personal information collected through this website or mobile application be disclosed?
62 Do you take steps to safeguard information I provide through the site or mobile application?
63 What is "Refer-A-Friend"?
64 Does your site or mobile application contain links to other websites or social media platforms?
65 If I followed a link to your site from another website, whose privacy policy controls?
66 If I am using the site from outside the United States will information collected through the site be transferred to the United States?
67 How do you comply with the Children's Online Privacy Protection Act ("COPPA")?
68 How will changes to this Policy be communicated?
69 Who can I contact with questions regarding this Policy?
70 What types of information are collected through this site or mobile application?
71 We may collect a range of information from you if you visit our site or mobile application depending upon the features you use.
72 We may collect personal information, such as your name, address, telephone number, email address, credit card numbers, Social Security numbers or other identifiers that you may provide in the course of completing a form or transaction on our site or mobile application. Portions of our site may collect additional information from individuals using those features such as accepting resumes from job applicants or collecting application of financial aid information from students and applicants.
73 We may collect information about the browser and/or device that you are using to access our website or mobile application (such as the type of browser or device you are using, browser settings, and the device identification number). Device information may or may not be personally identifiable depending upon whether it is linked to the identity of the user.
74 We may automatically log information, such as a user's IP address, domain name, browser type, date and time of access, and other log file data. This information may be used to analyze trends or administer our websites and mobile applications. We may collect statistical or non-personally-identifiable information about our users, such as which pages are visited, how long a visitor stays on a particular page, the website from which a user came to our site, or similar such information. We also may collect aggregate information such as the total number of unique or return visitors to our site, using our application, or visiting a particular page in a given timeframe. We may use this information to measure the use of our sites and applications and to improve our content. We may use Google Analytics, a third party provider of analytics tools or a similar third party service to analyze information about visits to our website. For information about opting out of Google Analytics please visit: https://tools.google.com/dlpage/gaoptout .
75 Does your website use cookies or similar technologies?
76 Yes, we may utilize "cookies," web beacons and other similar technologies on our website. We may use first and/or third party "browser" or "HTTP" cookies, which are unique text files that may be used for data analysis, and enable our website to tailor information for the visitor. We may use browser cookies for purposes such as to personalize the user's experience on our site, to remember a user when the user registers for products or services, for fraud prevention, or to track visits to our websites. We also may use "web beacons" (also referred to as pixel tags, clear gifs or other terms) or similar technologies to collect information such as how long a visitor remains on a particular page. If you do not want us to deploy browser cookies to your device when you visit our websites, you may set the browser to reject cookies or to notify the user when a web site tries to place cookies in the browser program (see below). Rejecting cookies may affect your ability to use some of features offered by the website. If you use our website without setting your browser to block cookies, you consent to the placement of cookies on your device.
77 Third parties, including our service providers or marketing partners may collect information about a visitor to our site over time and/or across different websites when the visitor uses our website. This information often is aggregate data or individual information that is tied to a browser or device rather than specific identifiers such as the visitor's name and address, but some of this information might be considered to be personally identifiable under some federal or state laws.
78 What choices do I have about online tracking and the placement of cookies on my device?
79 Some Internet browsers have begun to offer what often is referred to as "do not track" mechanisms for browser users to automatically signal privacy preferences to websites that they visit. Internet browsers have only begun to include these features relatively recently and there is not yet a consensus about what steps a website should take when it receives a do-not-track signal from a site visitor's browser or what information collection or use restrictions should be applied when a do-not-track signal is received. As a result, our site(s) do not currently respond to do-not-track-signals. We are continuing to monitor do not track developments and may revisit the issue in the future. In the meantime, you can exercise other choices available to you, including limiting the placement of browser cookies on your device using your browser's cookie control features and other choices described in this Policy.
80 Internet Explorer
81 Safari
82 Safari Mobile (iPhones and iPads)
83 Firefox
84 Chrome
85 You also can opt-out of, or make other choices concerning, the types of third party advertisements that may be targeted to you based on your browser activity by using mechanisms such as the “AdChoices” icon that may appear in advertisements that may appear on some of our sites. You can click on the “AdChoices” icon, where displayed, to exercise the choices available there. Additional information about AdChoices is available at: www.youradchoices.com. Information and opt-out choices for ads placed by Google are available at: www.google.com/settings/ads .
86 How is my information used?
87 We may use the information we collect through our site or mobile application for the following purposes:
88 To respond to requests for information or to facilitate transactions or communications that users of our sites or users of our mobile applications request;
89 To process requests and applications for prospective students;
90 To process registration, financial aid, academic and other interactions with our students;
91 To facilitate the educational experiences and career services offered to our students and alumni;
92 To improve and administer our websites and mobile applications;
93 To carry out our educational mission and facilitate the education of our students;
94 To better understand the needs of the users of our sites and mobile applications and create content that is relevant to the user;
95 For marketing and market research purposes;
96 To generate statistics and de-identified data;
97 To personalize content for the user;
98 To notify the user of any changes with our website or mobile application which may affect the user;
99 To enforce the terms of use for our website or mobile application;
100 For historical, statistical or business planning purposes;
101 To prevent fraud and investigate potential misconduct; or
102 To comply with law and legal process.
103 We do not share, sell or lease personal information about you except as set forth in this Policy.
104 What types of choices do I have about your collection and use of personal information about me?
105 You have a number of choices regarding our collection and use of information through our websites and mobile devices:
106 In cases where you are requested to affirmatively provide information, such as to complete a form, or an application, or a survey on our website, you may decline to do so. Please understand, however, that in some cases certain information is required to complete an application, form or survey, and if you decline to provide the information requested you may not be able to submit the application or request or to use certain functionalities of our websites or mobile applications.
107 If you would like restrict our placement of cookies on your device, please see the FAQ "What Choices Do I Have About the Placement of Cookies on My Device?" above.
108 If you prefer that we no longer contact you about potential educational opportunities at our school, please e-mail us at csprogramadmin@edmc.edu.
109 If you would prefer not to receive e-mail marketing messages from us, please use the opt-out instructions included in the email message to opt-out of additional communications.
110 You may be given additional choices in the context of particular preferences tools or functions that we make available through our website or mobile applications.
111 Can I access and request correction of personal information I provide through the website or mobile application?
112 Yes. If the information that you provide through our website is included in an educational record then we provide access to that information in accordance with the Family Educational Rights and Privacy Act (FERPA), as applicable.
113 In the case of personal information that is not part of a student's educational records, it is our policy, with certain exceptions, to provide individuals with access to personal information that is maintained in EDMC's files. In some cases, the website may allow you to log-in to directly access and/or correct information you have provided. In other cases, such as web forms that you may submit through the site, if you would like to obtain a copy of the information you provided you can contact us at csprogramadmin@edmc.edu . When you update information, we may keep a copy of the prior version for our records.
114 Exceptions to access and correction rights may include:
115 Where the burden or expense of providing access would be disproportionate to the risks to the individual's privacy in the case in question;
116 Where the rights of persons other than the individual would be violated; or
117 With respect to individual requests for the correction or deletion of information, in cases where we are otherwise legally required to retain the personal information.
118 We require that an individual provide reasonable validation of his or her identity before we provide access to personal information from our files. To request access to or correction of information please send an email to csprogramadmin@edmc.edu .
119 You may request that we delete information that you post on our websites, online services, and applications that is accessible to other users of the website, service or application such as comments, social media posts, or blog entries, either by using the functionality (if any) provided by the website, service, or application that you used to post the information or by sending an email to csprogramadmin@edmc.edu specifying the information that you are requesting that we remove and sufficient information about where you posted it so that we can locate it. Please note that a deletion request may not result in complete or comprehensive removal of the content from our website, service, or application to the extent we are permitted or required by law to retain that information. For example, information may not be removed if we need to maintain the information for legal compliance purposes or if you fail to follow the instructions above, such as by failing to provide sufficient information for us to process your request. Similarly, if information that you posted has been stored, republished or reposted by a third party, or you were compensated or consideration for providing the content, that information may not be subject to deletion.
120 How may personal information collected through this website or mobile application be disclosed?
121 We may disclose information with your consent or as otherwise necessary or appropriate to process a transaction that you may request.
122 We may disclose information that we collect through our websites or mobile applications with agents, affiliated businesses, and service providers providing services on our behalf.
123 We may disclose information, as applicable, to the U.S. Department of Education; state or provincial education agencies, to other regulators, or our accrediting organizations.
124 In the event that our company or some of our assets are sold or transferred or used as security or to the extent we engage in business negotiations with our business partners, the information collected on our websites or mobile applications, including this site, may be transferred or shared with third parties as part of that transaction or negotiation.
125 If we receive a request from law enforcement officials or judicial authorities to provide information on individuals, we may provide such information. In matters involving claims of personal or public safety or in litigation where the data is pertinent, we may use or disclose your personal information without a court order.
126 We may use information you submit to investigate security breaches, misconduct, or otherwise cooperate with authorities pursuant to a legal matter.
127 Do you take steps to safeguard information I provide through the site or mobile application?
128 We recognize that you may be concerned about the security of your personal information and we are committed to employing reasonable technology in order to protect the security of our website. Even with such technology, no website is 100% secure. We take reasonable measures that we believe are appropriate to protect your information from loss, misuse, alteration or destruction. We will ask any agents and service providers to whom we may transfer your information take comparable steps to protect that security.
129 If you use this site or mobile application, you are responsible for maintaining the confidentiality of any user ID and password or other access credentials that you may be provided. You should notify us immediately if any user ID and password or other access credentials we may issue you are compromised.
130 What is "Refer-A-Friend"?
131 We may offer you opportunities to request that we send content from our websites or otherwise reach out to friends or family members that you believe may be interested in learning more about our programs. If you choose to make such a referral, which is voluntary, we may ask you for your name and contact information as well as contact information for the individual or individuals that you refer, such as their name, email address and/or phone number. When we contact your friend, we may identify you as the party that made the referral. This feature is only to be used to refer individuals with whom you have an existing relationship that you think would be interested in being contacted by us by phone or by email.
132 Does your site contain links to other websites or social media platforms?
133 Yes, our website may include links to other websites or links that facilitate your ability to post content to social media platforms. This Policy only applies to those of our websites that link to this Policy. Please be aware that sites we link to may collect information about you and operate according to their own privacy practices which may differ from this Policy. Similarly, if you post content to social media platforms, such as Facebook or Twitter, whether you do so manually or using a widget offered on our site, please remember that your social media postings will be made available in accordance with the social media site where you are posting the information and that you may be limited in your ability to control information once you have made it available to third parties by posting it. Remember to consult the privacy policy of any websites you may visit regarding their privacy practices.
134 If I followed a link to your site from another website, whose privacy policy controls?
135 The privacy policy posted on the website you were visiting, if any, would apply to any information collection that occurred on that site. Our privacy policy applies to your activity on our site.
136 If I am using the site from outside the United States will information collected through the site be transferred to the United States?
137 This site is designed primarily for users from the United States. By using this site, users from other countries consent to the transfer of any personal or other information collected to the United States and housed on servers in the United States and your information will be subject to use and disclosure in accordance with this Policy and applicable United States federal, state, and local law.
138 How do you comply with Children's Online Privacy Protection Act ("COPPA")?
139 COPPA regulates the collection of personal information online from children under the age of 13. This site is not intended or designed to attract users under the age of 13 or to collect personal information from such users. We do not collect personally identifiable data from any person we know to be under the age of 13 and those under 13 should not submit any personal information through this site. If we learn that we have inadvertently collected personal information from a child under the age of 13 we will remove the information from our files.
140 How will changes to this Policy be communicated?
141 If we make any material changes to this privacy policy we will change the "last updated" date so that you can quickly determine whether there were material changes since the last time you reviewed the policy.
142 Who can I contact with questions regarding this Policy?
143 If you have questions concerning our privacy practices, contact us at:
144 Privacy Administrator
145 210 Sixth Avenue
146 Pittsburgh, PA 15222
147 Fax: 1.412.995.7295
148 Email: csprogramadmin@edmc.edu