OUR COMMITMENT TO YOUR PRIVACY
We at the United States Career Campus LLC are committed to
providing you with information about what data is being collected about you,
how it will be used, and to whom we disclose it.
United States Career Campus LLC takes
the privacy of personal data seriously. Our policy (“Privacy Policy”) explains
how we collect, use, and disclose data, and your choices and rights with
respect to your data.
United States Career Campus LLC., is
committed to protecting the privacy of those who visit our websites. As part of
our normal operations, we collect different kinds of information about our
website visitors. We have, however, structured our websites so that people have
the option to visit without identifying themselves or revealing any personal
information.
The following are things you can do
while visiting our website if you prefer NOT to have information about your
visit collected.
Disable cookies within your browser
before visiting our website.
Choose not to submit information via
web forms located within our website.
Choose to register for public
seminars via telephone or email as opposed to our website.
Choose not to “opt-in” to receiving
informational emails.
This privacy policy and statement of
cookie use (the “Privacy Policy”) discloses our privacy practices and expresses
our commitment to keeping you informed of the information we collect and how it
is used. We ask that you take time to read it carefully. We may update this
Privacy Policy from time to time to reflect new uses, rules, regulations, or
technologies that impact your privacy.
We recommend that users review our
Privacy Policy on a routine basis to view any changes. This Privacy Policy will
be continuously assessed against new technologies, business practices and data
protection regulations.
Personal data, or personal
information, means any information about an individual from which that person
can be identified, either directly or indirectly. The data we collect about you
depends on the services you use, how you use them, and the information you
provide to us.
The following describes the
information we collect and how that information is used to provide our visitors
with the optimal online experience.
Data you provide directly to us.
You may provide data to us when you
use our services, such as when you register for an account, participate in one
of our programs, or communicate with us.
This data may include:
Identity Data – which includes first name, last
name, username or similar identifier, and title.
Contact Data – which includes business address,
corporate or personal email address and telephone numbers.
Marketing and Profile Data – which includes your interests and
preferences in receiving marketing from us and selecting third parties, your
communication preferences and survey responses.
Customer Service and Inquiry Data - such as information you provide us
when you contact customer support or ask us a question about our services and
products.
User-Generated Content - such as information you provide to
our instructors and coaches in connection with your participation in our
business Services.
Data collected automatically when you use the services.
When you use our services, we may
automatically collect certain data using a variety of tools, including server
logs, cookies, and other technologies.
This data may include:
Device and Network Data – which includes internet protocol
(IP) address, browser type and version, time zone setting and location, browser
plug-in types and versions, operating system and platform and other technology
on the devices you use to access our website.
Usage Data - includes information about how you
use our services, such as which services you use, content accessed within the services,
date and time of use, amount of time spent on the Services, navigation within
the Services, and entering and exiting URLs.
Data from other sources.
We may also collect data about you
from other sources, such as information you post publicly on social media
platforms.
De-Identified Data - We may also aggregate or
de-identify personal data such that it does not directly or indirectly reveal
your identity (“De-Identified Data”). For example, we may aggregate information
about use of our websites to calculate the percentage of users accessing
specific website features. We may use and disclose such De-Identified Data for
any purposes. However, if we combine or connect De-Identified Data with your
personal data so that it can directly or indirectly identify you, we treat the
combined data in accordance with this Privacy Notice. We do not collect any special
categories of personal data about you – also considered sensitive data. Special
categories of personal data include, but are not limited to, details about your
race or ethnicity, religious or philosophical beliefs, sexual orientation, or
political opinions. Nor do we collect any information about criminal
convictions and offences.
What we do with your data
How we use your data depends on your
relationship with us and the services that you use:
Data collected from Learners under an
enterprise (employer) account.
We process data collected from
individuals in their capacity as learners associated with enterprise accounts
in accordance with the relevant customer’s instructions and in fulfillment of
the contractual relationship with such customer. This data may include the
learner’s identity data, contact data, device and network data, and usage data.
Consistent with our contractual commitments, we use this data to provide the services
to learners, support, and troubleshooting, to analyze and improve the services,
to secure our services, and for legal and compliance purposes, or as otherwise
requested by the customer.
Data collected from learners with a direct relationship with
United States Career Campus LLC
We process data collected from
individuals in their capacity as learners who have a direct relationship with
us pursuant to our contractual relationship. This data may include the
learner’s identity data, contact data, device and network data, usage data, and
customer service and inquiry data. We may use this data to provide the services,
support and troubleshoot the services, to analyze and improve the services, to
market our other services to you, to communicate with you about the services
(such as updates or notices about changes to our terms or policies), to secure
the services, and for legal and compliance purposes, or for other purposes for
which we seek your consent.
Data collected from website visitors and others.
We process data collected from
individuals outside of their capacity as learners (such as visitors to our
website) for a variety of purposes. This data may include any of the data collection
methods listed above. We may use this data to provide the services, support and
troubleshoot the services, to analyze and improve the services, to provide you
with information about our other services, to communicate with you about the services
(such as updates or notices about changes to our terms or policies), to market
and advertise our services, to personalize the services, to secure the services,
and for legal and compliance purposes, or for other purposes for which we seek
your consent.
Disclosure of your data
We disclose your data in the following ways:
Within the United States Career
Campus LLC family of companies - We disclose your data within the United States Career
Campus LLC family of companies under common ownership and/or control to provide
and enhance the services and to operate our business.
With your employer - If you are a learner using a United
States Career Campus LLC business services account provided by your employer,
information about your activity on United States Career Campus LLC is
accessible to, and may be disclosed to, your employer. Please note that this
does not apply to information we collect from individuals who have established
an independent relationship with us.
With our service providers - United States Career Campus LLC
may share your personal data with vendors and other partners that provide
services on our behalf. We require all service providers to respect the
security of your personal data and to treat it in accordance with the law. We
do not allow our third-party service providers to use your personal data for
their own purposes and only permit them to process your personal data for
specified purposes and in accordance with our instructions.
Online advertising partners - We work with third-party online
advertising partners that, where permitted by law and consistent with any
consent or opt out elections you have made, collect information both on our services
and on third-party platforms to help tailor and serve you advertisements
online. These partners may use cookies, pixel tags and similar technologies on
many online services, including ours, to collect information to serve you more
relevant ads. You can learn more about how we and our partners use cookies (also
known as internet cookies or web cookies) and similar technologies, and about
your rights and choices with respect to cookies, by reviewing our Cookie Policy.
Business transfers - We may also share your data with
third parties to whom we may choose to sell, transfer, or merge all or parts of
our business or our assets. Alternatively, we may seek to acquire other
businesses or merge with them. If a change happens to our business, then the
new owners may use your personal data in the same way as set out in this
Privacy Notice.
Legal, compliance, security, and
safety - We may also
disclose your personal data 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.
United States Career Campus LLC is a
global company - Please
note that United States Career Campus LLC is a global company and serves
customers and individuals around the world. As such, when we disclose data as
described above, we may transfer data to other jurisdictions that may have data
protection laws that differ from those in your home country. When we transfer,
store, or process your data, we take reasonable steps to protect your personal
data in accordance with this privacy notice and applicable laws.
Standard Contractual Clauses (SCCs) - For instance, we may implement
Standard Contractual Clauses (SCCs) to govern the transfer of your data, or
other means recognized by applicable laws in compliance with the General Data
Protection Regulation (GDPR) and other applicable laws and regulations.
Data Privacy Framework (DPF) - Also, United States Career Campus
LLC complies with the EU-US Data Privacy Framework (EU-US DPF), the UK
Extension to the EU-US DPF, and the Swiss-US Data Privacy Framework (Swiss-US
DPF) as set forth by the US Department of Commerce, and the South African
Protection of Personal Information (POPI) Act.
Data Privacy Framework (DPF)
United States Career Campus LLC
adheres to the Data Privacy Framework (DPF) Principles with regard to the
processing of personal data received from the European Union in reliance on the
EU-US DPF; and from the United Kingdom (and Gibraltar) in reliance on the UK
Extension to the EU-US DPF; and from Switzerland in reliance on the Swiss-US
DPF, and the South African Protection of Personal
Information (POPI) Act.
If there is any conflict between the
terms in this privacy policy and the Data Privacy Framework (DPF) Principles,
the Principles shall govern. To learn more about the Data Privacy Framework
(DPF) program, please visit https://www.dataprivacyframework.gov/.
Contact information - In compliance with the Data
Privacy Framework (DPF), United States Career Campus LLC commits to resolve Data
Privacy Framework (DPF) Principles-related complaints about our collection and
use of your personal information. EU, UK, Swiss and the South African
Protection of Personal Information (POPI) Act. individuals with inquiries or
complaints regarding our handling of personal data received in reliance on the
DPF should first contact United States Career Campus LLC at
info@uscareercampus.com
Data protection authorities - In compliance with the Data
Privacy Framework (DPF), United States Career Campus LLC commits to cooperate
and comply respectively with the advice of the panel established by the EU data
protection authorities (DPAs) and the UK Information Commissioner’s Office
(ICO) and the Swiss Federal Data Protection and Information Commissioner
(FDPIC) and the South African Protection of Personal Information (POPI) Act with
regard to unresolved complaints concerning our handling of personal data
received in reliance on the Data Privacy Framework (DPF).
Arbitration - Please note that as part of the Data
Privacy Framework (DPF) individuals may invoke binding arbitration by
delivering proper notice to United States Career Campus LLC and following the
procedures and subject to the conditions of the Data Privacy Framework (DPF).
You can find more information on this from the International
Centre for Dispute Resolution.
Onward transfers - When United States Career Campus
LLC uses third-party vendors in the provision of its services, it remains
liable under the Data Privacy Framework (DPF) to its customers for onward
transfers of personal data to such vendors.
US jurisdiction - United States Career Campus LLC is
subject to the investigatory and enforcement power of the US Federal Trade
Commission (FTC).
Using artificial intelligence (AI)
United States Career Campus LLC
leverages AI technologies to improve our products and services, providing a
better experience for our learners. The use of AI, and similar emerging
technologies, must be done in accordance with our code of conduct and AI-related
policies and procedures – in compliance with applicable law and regulations.
Our policies and procedures ensure that any use of AI is done in an ethical and
responsible manner. Generally, and with the exception of a very limited set of
circumstances, personal data is not used or processed using AI.
PURPOSE SPECIFICATION
United States Career Campus LLC
collects and uses personal data for specific purposes and does not use the data
in ways that are incompatible with those purposes.
We will only use your personal data
for the purposes stated in this privacy notice, for other purposes we have
specifically disclosed to you, or for which we seek your consent.
Our services are not intended for
children, and we do not knowingly collect data relating to children. If you
become aware that a child has provided us with information, please contact us
immediately at info@uscareercampus.com so we can delete such information from
our system.
The laws in some jurisdictions
require us to tell you about the legal bases we rely on to use or disclose your
“personal data” as such term is defined under applicable law. To the extent
that those laws apply, our legal grounds are as follows:
To honor our contractual commitments - Much of our processing of personal
data is to meet our contractual obligations to our customers, or to take steps
at customers’ requests in anticipation of entering a contract with them. For
example, we handle personal data on this basis to provide learners with the services.
Legitimate interests - In many cases, we handle personal
data on the ground that it furthers our legitimate interests in ways that are
not overridden by the interests or fundamental rights and freedoms of the
affected individuals, such as to provide customer support and troubleshooting
and to protect and secure our Services.
Consent - Where required by law, and in some
other cases, we handle personal data on the basis of your implied or express
consent, such as when we seek your consent to engage in direct marketing where
legally required.
Legal compliance - We need to use and disclose
personal data in certain ways to comply with our legal obligations.
Vital interest - To protect the vital interests of
the individual or others.
DATA MINIMIZATION
We collect and retain the personal
data we deem necessary for the purposes for which it was collected and for the
length of time required for our legitimate business and legal purposes.
We will only retain your personal
data for as long as necessary to fulfill the purposes we collected it for,
including for the purposes of satisfying any legal, accounting, or reporting
requirements. To determine the appropriate retention period for personal data,
we consider the amount, nature, and sensitivity of the personal data, the
potential risk of harm from unauthorized use or disclosure of your personal
data, the purposes for which we process your personal data and whether we can
achieve those purposes through other means, and the applicable legal
requirements.
In some circumstances you can ask us
to delete your data – see, “Individual rights” (below) for further
information.
We take reasonable steps to ensure that personal data is accurate and up
to date.
Where United States Career Campus LLC acts as a controller of data,
United States Career Campus LLC takes reasonable steps to ensure that personal
data is accurate and up to date. We have implemented technical and
organizational measures to ensure the information we collect remains accurate.
Users have the right to update or correct their personal data, and United
States Career Campus LLC provides mechanisms to enable users to do so – see,
“Individual rights” (below) for further information. It is important that the
personal data we hold about you is accurate and current. Please keep us
informed if your personal data changes during your relationship with us.
SECURITY
United States Career Campus LLC takes
appropriate measures to protect personal data from unauthorized access, use,
disclosure, alteration, and destruction.
United States Career Campus LLC takes
a variety of measures to protect personal data from unauthorized access, use,
disclosure, alteration, and destruction, including encryption, access controls,
and monitoring. United States Career Campus LLC conducts regular security
assessments and maintains an incident response and notification plan in the
event of a data breach.
However, please note that no
transmission of data across the internet can be guaranteed to be secure.
In addition, we limit access to your
personal data to those employees, agents, contractors and other third parties
who have a business need to know. They will only process your personal data on
our instructions, and they are subject to a duty of confidentiality.
Our website, products, and services
may include links to third-party websites, plug-ins, and applications. Clicking
on those links or enabling those connections may allow third parties to collect
or share data about you. We do not control these third-party websites and are
not responsible for their privacy and security practices or statements. When
you leave our environment, we encourage you to read the privacy policy of every
website you visit.
INDIVIDUAL RIGHTS AND CHOICES
This section explains your rights and
choices with respect to your data where United States Career Campus LLC acts as
a data controller, e.g., for learners with whom we have a direct relationship
and website visitors. If you are a learner using a United States Career Campus
LLC business services account, please contact your employer to exercise your
rights under applicable law. We cooperate with our enterprise account customers
to respond to individual requests in accordance with our contractual
obligations.
Exercising your rights and choices.
United States Career Campus LLC
provides mechanisms to enable users to exercise their rights under applicable
law with respect to their data and to make requests concerning their personal
data. If you wish to make any of the requests set out below, please send us an
email at info@uscareercampus.com and
specify from the below list the type of request you are making.
Access - Request access to your personal
data (commonly known as a “data subject access request”). This enables you to
receive a copy of the personal data we hold about you.
Correction - Request correction of the personal
data that we hold about you. This enables you to request correction of any
incomplete or inaccurate data, though we may need to verify the accuracy of the
new data you provide to us.
Deletion - Request erasure of your personal
data. This enables you to ask us to delete or remove personal data. You also
have the right to ask us to delete or remove your personal data where you have
successfully exercised your right to object to processing (see below), where we
may have processed your information unlawfully or where we are required to
erase your personal data to comply with local law. Note, however, that we may
not always be able to comply with your request of erasure for specific legal reasons
which will be notified to you, if applicable, at the time of your request.
Objection - Object to processing of your personal
data where we are relying on a legitimate interest (or those of a third party)
and there is something about your particular situation which makes you want to
object to processing on this ground as you feel it impacts on your fundamental
rights and freedoms. You may also object where we are processing your personal
data for direct marketing purposes. In some cases, we may demonstrate that we
have compelling legitimate grounds to process your information which overrides
your rights and freedoms.
Restriction - Request restriction of processing
of your personal data. This enables you to ask us to suspend the processing of
your personal data in the following scenarios: (a) if you want us to establish
the data’s accuracy; (b) where our use of the data is unlawful but you do not
want us to erase it; (c) where you need us to hold the data even if we no
longer require it as you need it to establish, exercise or defend legal claims;
or (d) you have objected to our use of your data but we need to verify whether
we have overriding legitimate grounds to use it.
Transfer - Request transfer of your personal
data to you or to a third party. To the extent required by law, we will provide
to you, or a third party you have chosen, your personal data in a structured,
commonly used, machine-readable format. Note that this right only applies to
automated information which you initially provided consent for us to use or
where we used the information to draw up a contract with you.
Please note that these rights are not
absolute and are subject to certain exceptions. If we cannot act on your
request, we will explain the reason(s) why. For example, a request might impact
the rights of another person or another company. Depending on applicable law,
you may have the right to appeal our decision to deny your request; if you
would like to exercise this right, please email us at info@uscareercampus.com
No Fee Usually Required
You will not have to pay a fee to
access your personal data (or to exercise any of the other rights). However, we
may charge a reasonable fee if your request is clearly unfounded, repetitive or
excessive. Alternatively, we may refuse to comply with your request in these
circumstances.
What We May Need from You
We may need to request specific
information from you to help us confirm your identity and ensure your right to
access your personal data (or to exercise any of your other rights), which may
include verification of your contact information and about the services you
use. This is a security measure to ensure that personal data is not disclosed
to any person who has no right to receive it. We may also contact you to ask
you for further information in relation to your request to speed up our
response.
Time Limit to Respond
We try to respond to all verified
requests within one month of our receiving them. Occasionally it may take us
longer than a month if your request is particularly complex or you have made a
number of requests.
Data Protection Officer
We will appoint a data protection
officer (“DPO”) who will be responsible for overseeing questions in relation to
this privacy notice. If you have any questions about this privacy notice, you
will have to contact our DPO at info@uscareercampus.com. You may also contact
us by telephone at 1 (978) 667 0078 with any general questions about our
websites.
Complaints
If you have any concerns or
complaints about our data processing activities, we urge you to first try to
resolve your issue directly with us by contacting our Data Protection Officer
via info@uscareercampus.com or the
contact information provided above. However, you also may have the right to
make a complaint to the data protection supervisory authority in the country
where you are based.
Marketing Opt Out
You can ask us or third parties to
stop sending you marketing messages at any time by checking or unchecking
relevant boxes to adjust your marketing preferences or by following the
“Unsubscribe” links on any marketing message sent to you.
Where you opt out of receiving these
marketing messages, this will not apply to personal data provided to us because
of a product/service purchase, warranty registration, product/service
experience or other transactions.
Sale/Targeted Advertising Opt Out
Rights
Under the laws in certain US states,
you also have the right to opt out of our processing or disclosure of your
information for online targeted advertising purposes. Note that certain US
states also allow you to opt out of the "sale" of your information to
third parties in exchange for valuable consideration (monetary or otherwise).
While we do not sell your personal data in exchange for money, we may use
online advertising and related analytics tools that result in the disclosure of
your information to our third-party partners and that are subject to this opt
out right. You can opt out of these activities.
ACCOUNTABILITY
United States Career Campus LLC is
responsible for implementing processes to comply with the data privacy
principles discussed in this privacy notice.
United States Career Campus LLC’s
role and responsibilities.
United States Career Campus LLC is
responsible for complying with data protection laws and regulations and is
designating a DPO to oversee compliance. United States Career Campus LLC has
implemented policies and procedures to ensure compliance with data protection
laws and regulations, including regular audits and employee training. United
States Career Campus LLC also conducts due diligence on its vendors and
partners to ensure that they comply with applicable data protection laws and
regulations.
Your use of United States Career
Campus LLC business services is administered by your employer pursuant to a
business-to-business (“B2B”) contract between United States Career Campus LLC
and your employer. United States Career Campus LLC is the processor of, and
responsible for, processing personal data in connection with the performance of
its contractual duties and the provisions of the United States Career Campus
LLC business services to its corporate clients (“B2B” relationship). The
agreement between United States Career Campus LLC and its business customer,
your employer, takes precedence when in conflict with this privacy notice. It
follows that your employer may have access to your personal data processed by a
United States Career Campus LLC Business Service and that your employer may
have its own privacy policy applicable to your use of one or more United States
Career Campus LLC business services. Your employer – as the controller of your
personal data – administers your use of the applicable United States Career
Campus LLC business services. Accordingly, please contact your employer with
any privacy questions related to your use of United States Career Campus LLC business
services or about your employer’s privacy policy governing the same.
United States Career Campus LLC is
the controller of, and responsible for, the contact information we collect in
connection with the provisions of direct-to-consumer services (“B2C”), and also
our marketing initiatives and employment opportunities that often originate
with our website located at www.uscareercampus.com
ACCEPTANCE OF PRIVACY POLICY
By using our websites, you signify
your assent to our privacy policy. If you do not agree with this privacy policy,
please do not use our website. Your continued use of our website following
posting of changes to these terms will mean you accept those changes.
CONTACTING US
Please contact us if you:
have any comments or concerns about
this privacy policy,
wish to confirm that United States
Career Campus LLC is processing your personal data, or
wish to have access to the personal
data United States Career Campus LLC may have about you, the practices of this
site, or your interactions with this site.
United States Career Campus LLC,
Info@uscareercampus.com
1 (978) 667 0078
NOTIFICATION OF CHANGES
We reserve the right to update or
modify this policy at any time, for any reason, without notice to you, other
than the posting of the amended Privacy Policy at this Site. We may e-mail
periodic reminders of our policies and will e-mail United States Career Campus
LLC members of material changes thereto, but you should check our Site
frequently to see the current Privacy Policy that is in effect and any changes
that may have been made to it.
Last updated: May 16, 2024