Effective Date: December 9, 2021
Last Revised: December 9, 2021
This Privacy Notice for California Residents (this “California Privacy Notice”) is provided by Summit College (who we refer to, together with our affiliates, “us,” “we,” or “our,” depending on the context). It applies to information we collect through the sites that link to this California Privacy Notice (referred to collectively as the “Site”), as well as through any other contact you have with Summit College in connection with the educational programs offered (referred to generally as a “Program” or the “Programs”).
This California Privacy Notice applies only to California residents (who are referred to as “you” or as “consumers” in this California Privacy Notice), and it supplements the information contained in our general Privacy Notice.
This California Privacy Notice has been adopted to address the requirements of the California Consumer Privacy Act of 2019, referred to as the CCPA, and any terms defined in the CCPA will have the same meaning when used in this California Privacy Notice.
We may use your Personal Information to provide you with marketing and promotional information about our products and services. These promotions may be made by mail, email, telephone, instant messaging application, or text (SMS) message, or other methods that may become relevant or available. All promotional materials that are sent by use using electronic means will include a simple means for you to stop receiving further communications. For example, we may provide you with an “unsubscribe” link, or an email address to which you can send an opt-out request. In addition, if we need your consent for direct marketing communications under applicable law, and if you provide your consent, you will be able to change your mind at any time.
Please note that despite your email preferences, we may need to contact you regarding your enrollment at Summit College, as required by law, or regarding legal matters. However, we will not send you marketing communications if you have opted out of receiving them.
You can manage your consent preferences with respect to direct marketing activities by contacting us at firstname.lastname@example.org.
We collect personal information as defined in the CCPA, which generally means any information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device. Please note that personal information does not include the following:
The table below describes the categories of personal information we collect, the categories of sources of that information, and our business or commercial purpose for collecting the information, all with respect to the last 12 months.
|Category of Personal Information||Do We Collect Information in This Category (Yes or No)?||If Yes, What Type of Information In This Category Do We Collect?||If Yes, Where Do We Obtain This Information?||If Yes, What is Our Business Purpose or Commercial Purpose For Collecting It?|
|Identifiers||Yes||Real name, postal address, online identifier, IP address, email address, Social Security number, driver’s license number, student ID||Directly from the consumer and from lead generation services||We collect this information as necessary for us to do business with you (for example, as necessary to verify your identity). We also collect this information so that we can operate our business and provide services to you and to others, as described below.|
|Personal information categories listed in the California Consumer Records statute (Cal. Civ. Code §1798.80(e))||Yes||Name, Social Security number, address, telephone number, driver’s license number, education, employment, employment history, financial aid status, estimated household income, financial information, medical information, or health insurance information, languages/first language||Directly from the consumer and from third party marketing demographic data providers||We collect this information as necessary for us to do business with you (for example, as necessary to verify your identity). We also collect this information so that we can operate our business and provide services to you and to others, as described below.|
|Protected classification characteristics under California or federal law||Yes||Age (40 years or older), marital status, gender, veteran or military status, citizenship, race||Directly from the consumer and from third party marketing demographic data providers||We collect this information so that we can operate our business and provide services to you and to others, as described below.|
|Geolocation data||Yes||Geo-location data||Directly from the consumer’s browser, and (subject to device settings) through communications from the device’s mobile provider||We collect this information so that we can operate our business and provide services to you and to others, as described below.|
|Professional or employment-related information||Yes||Employer and employment status||Directly from the consumer|
|Non-public education information (per the Family Educational Rights and Privacy Act, 20 U.S.C. §1232g, 34 C.F.R. Part 99)||Yes||Education level, degrees held, prior schools attended, reason for study, prior qualifications and assessments, risk factors (academic, financial, personal, technical), transcripts, and applicant/application information||Directly from the consumer|
|Inferences drawn from other personal information||Yes||Responsiveness to outreach efforts, interest in Programs||Directly from the consumer, from lead generation services, and from third party demographic data providers|
Where we say above that we collect information so that we can operate our business and provide services to you and to others, we mean that we use the information for one or more of the following purposes:
In addition to the business and commercial purposes of collection of personal information described above, we may use any of the personal information we collect for the following purposes:
We will not use the personal information we have collected for any materially different, unrelated, or incompatible purposes not disclosed in this California Privacy Notice without providing you notice and, if required by the CCPA, the opportunity to consent to such use.
Disclosures of Personal Information for a Business Purpose
With respect to the personal information we have collected, in the past 12 months we have shared information in the following categories (which are listed by reference to the categories identified above) with third parties, in each case for a business or commercial purpose:
The categories of third party with whom we share this information (other than our contracted service providers as described below) are our Partner School, your employer (if your employer is paying for your enrollment in a Program), our business partners, and our corporate affiliates.
In addition to the above, we also share personal information in the categories identified above with our service providers, such as companies who handle our data management and/or email distribution, parties who provide us with data enrichment services, our website and infrastructure hosting providers and our managed information technology support service provider, and also to third parties to whom you authorize us to disclose your personal information in connection with our services.
In addition, you should be aware that we may share information with third parties in the following circumstances:
Sales of Personal Information
In the preceding 12 months, we have not sold personal information to third parties.
The CCPA provides California residents with specific rights regarding their personal information. If you are a California resident, this section describes your CCPA rights, and explains how to exercise them.
Rights to Access Certain Information
You have the right to ask up to provide you with information about our collection and use of your personal information over the past 12 months. You may request the following information:
Rights to Request Deletion of Certain Information
You have the right to ask us to delete any of your personal information that we collected from you and have retained. However, there are certain exceptions to our obligation to delete the information, which we describe below.
We may deny your deletion request if we or our service providers need to keep the information to:
How to Submit a Verifiable Consumer Request and Exercise Your Rights
To exercise any of the rights described above, you must submit a verifiable consumer request to us by either:
Only you, or a person registered with the California Secretary of State that you expressly authorize to act on your behalf, can make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within any 12-month period. The verifiable consumer request must:
– Provide sufficient information that allows us to reasonably verify that you are the person about whom we requested personal information, or are an authorized representative of that person, which may include (by way of example, but not limited to) verification of your current address, Student ID, date of birth, email address, or telephone number; and
– Describe your request with sufficient detail that enables us to understand, evaluate, and respond to it.
We cannot respond to your request or provide you with information if we cannot identify you or confirm your authority to make the request.
We will only use any personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
How and When We Will Respond to Verifiable Consumer Requests
We will confirm receipt of a verifiable consumer request within 10 days, and with that confirmation, we will include a description of our verification process and will provide an expected response timeframe. Generally, we will respond to each verifiable consumer request within 45 days of receipt. If we require more time, subject to the limitations imposed by the CCPA, we will inform you of the reason and extension period in writing.
We will deliver our written response by mail or electronically using the contact information you have provided.
Any disclosure we provide in response will only cover the 12-month period preceding our receipt of the request. If we cannot comply with your request, we will explain why. If you request that we provide you with a copy of your data, we will select a format in which to provide your personal information that is readily usable, and should allow you to transmit the information from one entity to another without undue difficulty.
We do not generally charge a fee to process or respond to requests, unless the request is excessive, repetitive, or manifestly unfounded. If we determine that a fee is warranted by the circumstances, we will tell you why, and will provide you with a cost estimate before completing your request.
We will not discriminate against you for exercising any of your CCPA rights. This means that unless we are permitted to do so by the CCPA, we will not:
In addition to the CCPA, California’s “Shine the Light” law permits California residents to request certain details about our disclosure of their personal information to third parties for those third parties’ own direct marketing purposes. If are a California resident, and you would like to make such a request, please contact us at . Please note that there are legal limits on how often you can make such a request, and we are only obligated to respond to one information request per customer per year.
Because of changes in Internet technology and practices, this California Privacy Notice may change from time to time. We will post any changes we make to this California Privacy Notice on this page, and any changes will be effective once the new notice is posted. It is your responsibility to check this for updates. You can determine when this California Privacy Notice was last updated by referring to the “Last Modified” legend at the top. By using the Site after we post any changes to this California Privacy Notice, you agree to accept those changes, whether you have reviewed them or not.
If you have any questions or comments about this California Privacy Notice, please do not hesitate to contact us as provided below: