Last Revised: July 2020
Social Media Privacy
Kaplan Edupac will not require you to:
- Disclose a username or password for accessing personal social media;
- Access personal social media in the presence of Kaplan Edupac’s employees or representatives, or
- Divulge any personal social media information.
Personal Information You Provide. We may collect and store personal information that can identify you, such as your name, postal address, email address (“Personal Information“), when voluntarily submitted by our visitors. We may collect and store any personal information you provide to us that may be contained in any video, comment or another submission you upload or post to the Site. Personal Information might also include title, telephone number; your likeness; and, if you transact business with us, financial information such as your payment method (valid credit card number, type, expiration date or other financial information). If sensitive information is collected, we will take appropriate efforts to comply with industry standards for the protection and proper disposal of all sensitive data, both online and offline. We also may request information about your interests and activities, your gender and date of birth, and other demographic information.
When you provide personal information to us, the information may be sent to servers located in the United States and other countries around the world.
Personal Information From Other Sources. We may also periodically obtain personal information about you from other Kaplan Edupac businesses, business partners, contractors, and other third parties. Examples of information that we may receive include: updated delivery and address information, purchase history, and additional demographic information.
Data Protection Principles. We will comply with data protection law, which says that the personal information we hold about you must be:
Used lawfully, fairly and in a transparent way;
Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes;
Relevant to the purposes we have told you about and limited only to those purposes;
Accurate and kept up to data;
Kept only as long as necessary for the purposes we have told you about; and
Collection. We use various technologies to collect information from your computer and about your use of the Site.
Information collected automatically. We automatically collect information from your browser when you interact with our Site. This information includes, but is not limited to, your IP address, your browser type and language, access times, the content of any undeleted cookies that your browser previously accepted from us (see “Cookies” below), and the referring website address.
A cookie is a string of information that is sent by a website and stored on your hard drive or temporarily in your computer’s memory. Cookies are small files and won’t pose any significant disk-space concerns. You can disable our cookies using the cookie-menu on your Web browser, but doing so may materially affect the functionality of this Site and the information you can access through it. To learn more about cookies and browser functionality, search for “cookies” in the help function of your browser.
Other Technologies. Like many websites, we may use standard Internet technology, such as web beacons, site tags, clear GIFs, and other similar technologies, to collect and maintain information about your web-surfing activity when you are visiting this Site, other Kaplan sites, as well as other non-Kaplan sites. We also may include web beacons or pixels tags in connection with some Site pages and HTML-formatted email messages to, among other things, compile aggregate statistics about Site usage and response rates. A Pixel Tag is an electronic image. Often a single pixel that is ordinarily not visible to Site visitors and may be associated with cookies on the visitors’ hard drive. Pixel tags allow us to count users who have visited certain pages of the Site, to deliver branded services, and to help determine the effectiveness of promotional or advertising campaigns.
Do Not Track Practices. Some web browsers may transmit “do-not-track” signals to the websites with which the user communicates. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them. Because there currently is no industry standard concerning what, if anything, websites should do when they receive such signals, Kaplan currently does not take action in response to these signals. If and when a final standard is established and accepted, we will reassess how to respond to these signals.
How We Use the Information We Collect. We will only use your personal information when the law allows. Most commonly, we will use your personal information in the following circumstances:
- Where we need to perform a contract we have entered into with you;
- Where we need to comply with a legal obligation;
- Where it is necessary for our legitimate interests (or those of a third party) and your interest and fundamental rights do not override those interests;
- Where we need to protect you viral interests (or someone else’s interest);
- Where it is needed in the public interest or for official purposes;
- Generally, we do not rely on consent as a legal basis for processing your personal information other than about sending direct marketing communications to you via email. You have the right to withdraw consent to marketing at any time by contacting us.
We may use information that we collect about you to:
- Deliver the products and services that you have requested;
- Manage your account and provide you with customer support;
- Perform research and analysis about your use of, or interest in, our products, services, or content, or products, services or content offered by others;
- Communicate with you by email, postal mail, telephone and mobile devices about products or services that may be of interest to you either from us, other Kaplan companies or other third parties;
- Develop and display content and advertising tailored to your interests on our Site and other sites; verify your eligibility and deliver prizes in connection with contests and sweepstakes;
- Enforce our terms and conditions; and
- Manage our business and perform functions as otherwise described to you at the time of collection.
Financial information. We may use financial information or payment method to process payment for any purchases, subscriptions or sales made on our Site, to protect against or identify possible fraudulent transactions, and otherwise as needed to manage our business.
If we enter into a contract with you relating to study or accommodation, we may collect additional personal information relating to you including:
- Bank account details;
- Billing address;
- Credit card or other payment information to process your payments.
This information, together with the personal information provided to us above at application stage, will be used by us to perform the contract we have entered into with you.
We will also collect further personal information relating to your visa application and immigration status as we have a legal obligation to use this information.
During your studies, we will collect information about your academic experience and progression. This information is to fulfill our contract with you, but it is also in our legitimate interests to use this personal information to monitor the provision of our service to you.
We may also collect personal information about your health to make appropriate arrangements and reasonable adjustments for you regarding your welfare, attendance or accommodation. We use this information to perform our contract with you, but it also may be in your vital interests for us to do so.
We may also collect personal information about you if you are named as an emergency contact for an individual. We use this information as it is in the vital interests of such individual.
If you use an agent to arrange your application and study with us, we may collect the categories of personal information described above from your agent.
Marketing: Where you have explicitly consented to do so, we may use your personal information to inform you of special offers and new or existing services that we believe may be of interest to you or to send surveys or questionnaires so that we can learn more about your needs and interests.
Failure to Provide Personal Information. Where we need personal information by law, or under the terms of a contract with you and failure to provide that information when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.
Sharing with Third Parties. We do not share your personal information with others except as indicated below or when we inform you and give you an opportunity to opt out of having your personal information shared. We may share personal information with:
- Authorized Service Providers: We may share your personal information with our authorized service providers that perform certain services on our behalf. These services may include fulfilling orders, processing credit card payments, delivering packages, providing customer service and marketing assistance, performing business and sales analysis, supporting our website functionality, and supporting contests, sweepstakes, surveys and other features offered through our website. These service providers may be supplied with or have access to your personal information solely to provide these services to us or on our behalf. Kaplan is the data controller and will remain accountable for your personal information.
- Business Partners: When you make purchases, reservations or engage in promotions offered through our Site or our services, we may share personal information with the businesses with which we partner to offer you those products, services, promotions, contests, and sweepstakes. When you elect to engage in a particular merchant’s offer or program, you authorize us to provide your email address and other information to that merchant.
- Agents: These service providers may be supplied with or have access to your personal information solely to provide these services to us or on our behalf. Kaplan is the data controller and will remain accountable for your personal information.
- Parents and guardians: If you are under 18, we may share your personal information with your parents or guardians to perform our contract, comply with our legal obligations and if it is in you vital interests.
- Other Kaplan Businesses: We may share your personal information we collect with the Kaplan companies as part of our regular reporting activities on company performance, in the context of a business reorganization or group restructuring exercise or for system maintenance support and hosting of data. Sharing contact information with our Kaplan companies enables us to provide you with information about a variety of products and services that might interest you. If you prefer not to receive information from these providers, you can notify us at any time by emailing firstname.lastname@example.org or by completing the CCPA Data Privacy form.
- Regulators: We may need to share your personal information if required by a regulator or to otherwise comply with the law.
- Other Situations:
- We may disclose your information in response to a subpoena or similar investigative demand, a court order, or a request for cooperation from law enforcement or other government agency; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law. In such cases, we may raise or waive any legal objection or right available to us, in our sole discretion. When we believe disclosure is appropriate with efforts to investigate, prevent, report or take other action regarding illegal activity, suspected fraud or other wrongdoing; to protect and defend the rights, property or safety of Kaplan, it’s users, employees, or others; to comply with applicable law or cooperate with law enforcement; or to enforce our website terms and conditions or other agreements or policies.
- In connection with a substantial corporate transaction, such as the possible sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy. We may also need to share your personal information to permit us to pursue available remedies or limit damages we may sustain.
Security of Personal Information.
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. Also, we limit access to your personal information to those employees, service providers, business partners, agents and other third parties who have a legitimate need to know. They will only process your personal information on our instructions or as otherwise agreed and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
Storage and Retention of your Personal Information.
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your information changes during your working relationship with us.
In some circumstances, we may anonymize your 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 information (commonly known as a “data subject access request”). This request enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
Request correction of the persona information that we hold about you. This request enables you to have any incomplete or inaccurate information we hold about you corrected.
Request to be forgotten. This request enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).
Object to the processing of your personal information 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 information for direct marketing purposes.
Request the restriction of processing your personal information. This request enables you to ask us to suspend the processing of personal information about you, for example, if you want us to establish its accuracy or the reason for processing it.
Request the Data Portability of your personal information to another party.
No fee usually required.
You will not have to pay a fee to access your personal information (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.
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 information is not disclosed to any person who has no right to receive it.
Your right to withdraw consent.
How to Contact Us.
Transfer of your Personal Information to Other Countries.
As we are an international business with employees, entities and service providers all over the world, we may need to transfer the personal information you provide to us to other countries, which may be outside the European Economic Area (EEA).
Aggregated and Non-Personal Information. We may share aggregated and non-personal information we collect under any of the above circumstances. We may also share it with third parties and other Kaplan companies to develop and deliver targeted advertising on our websites and websites of third parties. We may combine non-personal information we collect with additional non-personal information collected from other sources. We also may share aggregated information with third parties, including advisors, advertisers, and investors, to conduct the general business analysis.
Your Ability to Choose.
You can let us know, at no cost, that you do not wish us to share your information with third parties for marketing purposes or to notify you about our products and services and special offers by sending us a written request by email to email@example.com, including the word “unsubscribe” in the subject line.
Links to Third-Party Websites.
We may provide areas on our Site where you can post information about yourself and others and communicate with others; upload content (e.g., pictures, videos, audio files, etc.); and post comments or reviews of content found on the Site. Also, such postings may appear on other websites or when searches are executed on the subject of your posting. Also, whenever you voluntarily disclose personal information on publicly-viewable web pages, that information will be publicly available and can be collected and used by others. For example, if you post your email address, you may receive unsolicited messages. We cannot control who reads your posting or what other users may do with the information you voluntarily post, so we encourage you to exercise discretion and caution concerning your personal information. Once you have posted information, you may not be able to edit or delete such information.
Our website is a general audience site, and we do not knowingly collect personal information from children under the age of 13. Should we learn that a child under 13 has provided us with personal information, we will delete that information from our database.
No Rights of Third Parties.