Effective: November 13, 2018
Last updated: March 19, 2019
Purpose and who we are
EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield
Aperian Global participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. We are committed to subjecting all personal data received from European Union (EU) member countries and Switzerland, respectively, in reliance on each Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Frameworks, and to view our certification, please visit [https://www.privacyshield.gov/welcome].
Aperian Global is responsible for the processing of personal data it receives, under each Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Aperian Global complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.
With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, Aperian Global is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, we 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.
You are responsible for ensuring the accuracy of the Personally Identifiable Information you submit to Aperian Global. Inaccurate information may affect your ability to use the Site, the information you receive when using the Site, and our ability to contact you. For example, your email address should be kept current because that is one of the primary manners in which we communicate with you.
What You Agree to by Using Our Site
What Information We Collect
We gather two types of information about users through the Site:
1) Information relating to your use of our Site. When users come to our Site, we may track, collect and aggregate information indicating, among other things, which pages of our Site were visited, the order in which they were visited, when they were visited, and which hyperlinks were “clicked.” We also collect information from the URLs from which you linked to our Site. Collecting such information may involve logging the IP address, operating system and browser software used by each user of the Site. We may be able to determine from an IP address a user’s Internet Service Provider and the geographic location of his or her point of connectivity.
2) Personally Identifiable Information provided directly by you or via third parties. We collect Personally Identifiable Information that you provide to us when you register for an account, update or change information for your account, purchase products or services, complete a survey, sign-up for email updates, Online Courses, participate in our public forums, send us email messages, in-person conference registration by mail-in form or by telephone, mobile application, and/or participate in Online Courses or other services on our Site.
We may use the Personally Identifiable Information that you provide to respond to your questions, provide you the specific course and/or services you select, send you updates about Online Courses offered by Aperian Global or other Aperian Global events, and send you email messages about Site maintenance or updates.
Account Registration. If you register for an account on our Site, you may be required to provide us with Personally Identifiable Information such as your name and email address.
Updates. Aperian may offer you the ability to receive updates either via email or by posting on portions of the Site only accessible to registered users. In order to subscribe to these services, you may be required to provide us with Personally Identifiable Information such as your name and email address.
Participation in Online Courses. Aperian offers users the opportunity to participate in an Online Course on or through the Site. If you desire to participate in a course, you will be asked to provide us with certain information necessary to conduct such a course. This information may include your name, IP address and email address as well as optional information about your demographics.
If you participate in an online course, we may collect from you certain student-generated content, such as assignments you submit to instructors. We also collect course data, such as student responses to in-video quizzes, standalone quizzes, exams, and surveys. You should not include any Personally Identifiable Information or other information of a personal or sensitive nature, whether relating to you or another person, on assignments, exams, or surveys, except for information required to participate or submit such assignments, exams, or surveys.
Communications with Aperian. We may receive Personally Identifiable Information when you send us an email message or otherwise contact us.
Third Party Sites. We may receive your Personally Identifiable Information when you access or log-in to a third party site, e.g., Facebook, Twitter and/or other social media platforms, from our Sites. This may include the text and/or images of your Personally Identifiable Information available from the third party site.
Surveys. We may receive your Personally Identifiable Information when you provide information in response to a survey operated by us. This may include details about your education history and/or your employment.
Third Party Credit Card Processing. Aperian provides you with the ability to pay for online content and other services using a credit card through a third party payment processing service provider. Please note that our service provider – not Aperian – collects and processes your credit card information.
How We Use the Information
Information relating to your use of our Site. We use information relating to your use of the Site to build higher quality, more useful services by performing statistical analyses of the collective characteristics and behavior of our users, and by measuring demographics and interests regarding specific areas of our Site. We may also use this information to ensure the security of our services and the Site.
Providing the Site and our services. We use Personally Identifiable Information which you provide to us in order to allow you to access and use the Site and in order to provide any information, products or services that you request from us.
Research. We may share anonymized and aggregate course data information about your activity on our Site, and demographic data (such as gender and age categories) from surveys operated by us with third parties, such as our University partners and other business partners so that our University partners and other business partners may use the data for research related to online education.
Disclosure to Aperian Operations and Maintenance Contractors. We use various service providers, vendors and contractors (collectively, “Contractors”) to assist us in providing our products and services to you. Our Contractors may have limited access to your Personally Identifiable Information in the course of providing their products or services to us, so that we in turn can provide our products and services to you. These Contractors may include vendors and suppliers that provide us with technology, services, and/or content related to the operation and maintenance of the Site or the online content. Access to your Personally Identifiable Information by these contractors is limited to the information reasonably necessary for the contractor to perform its limited function for us.
-Digital Advertising Alliance (DAA)’s self-regulatory opt-out page (http://optout.aboutads.info/) and mobile application-based “AppChoices” download page (https://youradchoices.com/appchoices)
In the mobile environment, most mobile operating systems offer device-based opt-out choices that are transmitted to companies providing interest-based advertising. To set an opt-out preference for a mobile device identifier (such as Apple’s IDFA or Android’s GAID), visit the device manufacturer’s current choice instructions pages, or read more about sending signals to limit ad tracking for your operating system here: http://www.networkadvertising.org/mobile-choices.
Please note that these settings must be performed on each device (including each web browser on each device) for which you wish to opt-out, and if you clear your cookies or if you use a different browser or device, you will need to renew your opt-out preferences.
Disclosure to Acquirers. Aperian may disclose and/or transfer your Personally Identifiable Information to an acquirer, assignee or other successor entity in connection with a sale, merger, or reorganization of all or substantially all of the equity, business or assets of Aperian to which your Personally Identifiable Information relates.
Third Party Sites
Retention of Personally Identifiable Information
Confidentiality & Security of Personally Identifiable Information
If you contact us by e-mail, please note that e-mail communications are typically not encrypted and should not be considered secure.
If you no longer wish to receive marketing-related emails from us, you may opt-out by clicking “Unsubscribe” or “Update my Preferences” at the bottom of any marketing email you receive from us.
Updating or Deleting Your Personally Identifiable Information
You have certain rights in relation to your Personally Identifiable Information. You can access your Personally Identifiable Information and confirm that it remains correct and up-to-date or choose whether or not you wish to receive material from us or some of our partners by logging into the Site and visiting your user account page. If you would like further information in relation to your rights or would like to exercise any of them, you may also contact us via email@example.com. If you are EU/EEA data subject you have the right to request that we:
provide access to any Personally Identifiable Information we hold about you;
prevent the processing of your Personally Identifiable Information for direct-marketing purposes;
update any Personally Identifiable Information which is out of date or incorrect;
delete any Personally Identifiable Information which we are holding about you;
restrict the way that we process your Personally Identifiable Information;
provide your Personally Identifiable Information to a third party provider of services; or
provide you with a copy of any Personally Identifiable Information which we hold about you.
We try to answer every email promptly where possible, and provide our response within the time period stated by applicable law. Keep in mind, however, that there will be residual information that will remain within our databases, access logs and other records, which may or may not contain your Personally Identifiable Information.
Please also note that certain Personally Identifiable Information may be exempt from such requests in certain circumstances, which may include if we need to keep processing your Personally Identifiable Information to comply with a legal obligation. In any case, if we deny a request we will provide an explanation for our refusal. When you email us with a request, we may ask that you provide us with information necessary to confirm your identity.
Aperian Global will retain your information for as long as your account is active, as needed to provide you services. Aperian Global will use your information as necessary to comply with legal obligations, resolve disputes, and enforce agreements. Unless requested earlier, as a general rule Aperian Global will delete all personal information within a period of five years after your account has become inactive, however shorter retention periods may apply depending on our services.
Questions, Suggestions and Complaints
If you have any privacy-related questions, suggestions, unresolved problems, or complaints you may contact us via firstname.lastname@example.org or at Aperian Global Inc, Attention: Privacy Department, 555 12th Street, Suite 1670, Oakland, CA 94607, USA. If you reside or are located in the EEA, our Privacy Team may assist with all queries regarding our processing of Personally Identifiable at email@example.com. If you reside or are located in the EEA, you may also make a complaint to our supervisory body for data protection matters (namely the UK Information Commissioner’s Office at firstname.lastname@example.org) or seek a remedy through local courts if you believe that your rights have been breached.
California Privacy Rights
Under California’s “Shine the Light” law (California Civil Code Section § 1798.83), California residents who provide personal information in obtaining products or services for personal, family or household use are entitled to request and obtain from us once a calendar year information about the customer information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year (e.g. requests made in 2018 will receive information regarding 2017 sharing activities). To obtain this information, please send an email message to email@example.com with “Request for California Privacy Information” on the subject line and in the body of your message. We will provide the requested information to you at your e-mail address in response. Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing will be included in our response.
International Privacy Practices
Aperian’s Sites are primarily operated and managed on servers located and operated within the United States. In order to provide our products and services to you, we may send and store your Personally Identifiable Information (also commonly referred to as personal data) outside of the country where you reside or are located, including to the United States. Accordingly, if you reside or are located outside of the United States, your Personally Identifiable Information may be transferred outside of the country where you reside or are located, including to countries that may not or do not provide the same level of protection for your Personally Identifiable Information. We are committed to protecting the privacy and confidentiality of Personally Identifiable Information when it is transferred. If you reside or are located within the EEA and such transfers occur, we take appropriate steps to provide the same level of protection for the processing carried out in any such countries as you would have within the EEA to the extent feasible under applicable law.
No Information from Children Under 13