Information We Collect: Personal Data is any information about an individual from which that individual can be identified. Your name, address and phone number are examples of Personal Data. We collect Personal Data that you choose to provide to us. For example, we collect Personal Data when you visit fashionanddesign.precollegeprograms.org or another of our websites (“Sites”) and submit a form requesting additional information. We also collect Personal Data when you enroll and participate in the School’s Precollege Programs, answer surveys and participate in our social media communities.
If a parent, school or other third party purchases Precollege Programs on your behalf, such third parties may provide us with Personal Data about you, including your first name, last name and email address. We may also collect Personal Data about you from our business partners and third parties.
Use of Your Personal Data: We may use your Personal Data in the following ways:
- For the purpose you provided Personal Data, for example to enroll you in one of the School’s Precollege Programs or respond to a specific inquiry;
- To allow you access to the Precollege Programs in which you have enrolled and to post content and communicate with others;
- To customize and personalize your learning experience;
- To administer, support, improve and develop our business, which includes, where you have given your consent if required by law, the following:
- To send you information about the School’s PreCollege Programs;
- To send you information about the School's other programs, including its higher education programs;
- To send you information about the Precollege Programs of our other university partners that may be of interest to you;
- To send you information about Kaplan products and services that may be of interest to you;
- To deliver advertising to you through our trusted third party service providers, such as Facebook Custom Audiences or other similar business tools;
- As otherwise described to you at the point of collection.
Mobile Devices, Phone Calls and SMS: If you provide us with a telephone number, you agree that we may contact you by telephone and/or text message utilizing automated technology at such telephone number(s). You understand that this consent is not required to purchase goods or services from us.
Your Ability to Choose: If you do not wish to continue receiving emails from us about the School’s Precollege Programs, you may unsubscribe by clicking on the unsubscribe link in our emails and following directions. If you do not wish to continue receiving SMS messages from us, you may stop messages by replying “STOP” to any message. You may also direct us to stop marketing to you by emailing us at firstname.lastname@example.org.
Disclosure of Your Personal Data: We share your Personal Data in the following limited circumstances:
- Parents/Guardians and Others Known to You: We may share your Personal Data with your parents/guardians. If payment for your Precollege Program was made by another third party, such as a grandparent, school, or sponsor, we may share your Personal Data with that third party as well. We may also share your Personal Data with others who you have specifically designated as authorized to receive information from us.
- The Kaplan Family of Companies: We may share your Personal Data with other companies within the Kaplan family of companies.
- Service Providers: We may share your Personal Data with trusted third parties who are delivering services to us, including those who help deliver Precollege Programs, help us process transactions, such as charging your credit card when you make purchases, and otherwise help us operate our business. These third parties are not authorized by us to use your Personal Data except in connection with providing services to us. We may disclose pseudonymous data (such as IP address of device ID) to third party attribution services who help us recognize you across the multiple devices you may use to interact with us.
- Legal Matters & Safety: We may disclose your Personal Data in response to legal process, to protect our rights, as otherwise required by law, or for the prevention or detection of a crime.
- Sale or Transfer of our Assets: If we sell our company or part of it, or our business enters into a joint venture with another business entity, we may disclose your Personal Data to our new business partners or owners who may then provide you with information about their products and services.
We do not disclose your Personal Data to third parties for their direct marketing purposes.
Disclosure of Other Types of Data: We may disclose anonymous, aggregated or de-identified data to third parties.
Transfer of Data Outside of Your Home Country: Your Personal Data will be held in the United States. Your Personal Data may also be stored, processed and accessed in other countries where Kaplan has facilities or where you are located. You consent to the transfer of your Personal Data outside your country, including to the United States.
Security and Information Retention: We employ security measures to protect your information both online and offline from access by unauthorized persons and against unlawful processing, accidental loss, destruction and damage. The Personal Data we obtain from students allows Kaplan to deliver smarter, more efficient and more effective instruction.
By mail: Kaplan Inc. 750 Third Avenue, 7th Floor, New York, NY 10017
By email: email@example.com
Name of DPO: Rachael Convery
Email address: firstname.lastname@example.org
Postal address: 2nd Floor, Warwick Building, Kensington Village, Avonmore Road, London W14 8HQ, United Kingdom.
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the opportunity to address your concerns before you approach the ICO so please contact us in the first instance.
Our storage and retention of your Personal Data: We will only retain your Personal Data for as long as necessary to fulfil 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 unauthorised 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. Please contact us at email@example.com if you would like more 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 working relationship with us. In some circumstances we may anonymise your Personal Data so that it can no longer be associated with you, in which case we may use such information without further notice to you.
Your rights as a data subject: Under certain circumstances, by law you have the right to:
- 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 and to check that we are lawfully processing it.
- Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have exercised your right to object to processing (see below).
- 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. You also have the right to object where we are processing your Personal Data for direct marketing purposes.
- Request the restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of Personal Data about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your Personal Data to another party.
If you want to review, verify, correct or request erasure of your Personal Data, object to the processing of your Personal Data, or request that we transfer a copy of your Personal Data to another party, please contact us at firstname.lastname@example.org.
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 the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it.
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 for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
Your right to withdraw consent: In circumstances where you may have provided your consent to the collection, processing and transfer of your Personal Data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. You have the right to withdraw consent to marketing by following the opt-out links on any marketing message. To withdraw your consent for another circumstance, please contact us at email@example.com. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law
Rev. December 2019