PRIVACY POLICY

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Last Updated: January 1, 2020

This Privacy Policy is incorporated by reference into the Boot Camp Terms of Use (the “Boot Camp Terms). The terms “Boot Camp,” “we,” and “us” mean Trilogy Education Services, Inc. (“TES”) and its affiliates and subsidiaries. Capitalized terms not otherwise defined herein shall have the meaning ascribed to them in the Boot Camp Terms.

The Privacy Policy explains how Boot Camp may: collect, use, and disclose personal information about you that we obtain through the Boot Camp Service (as defined in the Boot Camp Terms). By using the Boot Camp website (the “Site”) and the Boot Camp Service, you are authorizing us to collect, use and disclose data related to you and the provision of the Boot Camp Service, as well as education records – as defined in the Family Educational Rights and Privacy Act (FERPA) – in accordance with this privacy policy.

AGREEMENT AND YOUR EXPRESS CONSENT

By using this Site and/or the Boot Camp Service, you accept and hereby expressly consent to our collection, use, and disclosure of your personal information and education records in accordance with the terms of this Privacy Policy. In addition, you expressly consent to the receipt of electronic messages from the Boot Camp, including emails and text messages and including promotional emails and text messages. This Consent is effective immediately and remains valid indefinitely. This Consent shall not be voided upon your graduation or withdrawal from the Boot Camp or in the event your educational institution no longer does business with us. You acknowledge that neither your enrollment in a Course nor your use of this Site and/or the Boot Camp Services enrolls you as a part-time or full-time student at University.

This Privacy Policy may change from time to time, so please check back periodically to check the most recent modification date to ensure that you are aware of any changes. If we make any material changes to the collection, use or disclosure of education records, we will notify you by means of a notice on this Site prior to the change becoming effective and you will be required to log in and consent to the changes in order to continue to use the Site. Your continued use of the Site or the Boot Camp Service after any changes signifies your express consent to any such changes. If you do not agree to such changes, you must immediately stop using the Site and the Boot Camp Service.

THE INFORMATION Boot Camp COLLECTS FROM YOU

We collect personal information (such as your name, email, login and password details, registrations and applications, postal address and telephone number) when you:

• create an account;
• register or apply for a Course, either directly or by using a third-party website;
• participate in our surveys, promotions and competitions;
• sign up for a newsletter;
• post information to the Boot Camp Service that includes personal information; and
• communicate with us, for example to submit queries regarding the Site or the Boot Camp Service.

We also collect information, such as IP address, location data, and usage statistics, by using cookies, server logs, and other similar technology as you use the Boot Camp Service. See below for more information on our use of cookies on this Site.

Registration. To create an account, you must provide your name, email address, phone number, postal address, and date of birth. You may also provide other optional information, such as race, gender, previous salary information, current industry of employment.

Using the Boot Camp Service.  If you post personal information in a comment or to a chat room, blog or other public area of the Site, we may collect the information you post.   Posted information is also available for viewing and disclosure by other users of the Site, and we have no control over such use. We discourage posting sensitive or personal information in comments as they are viewable by the public.

From Third Parties. We may use third parties to perform certain tasks for us, such as facilitating your purchase of a Course. Such third parties will provide us with personal information, such as your name, address, and email address, you provide to them so that we have your information for Course rosters.

Customer Support. We may collect personal information through your communications with our customer-support, marketing, admissions, student support, career services and sales teams.  This information will be used to send you information you have requested from us and to send you promotional email messages.  You may unsubscribe from promotional emails by clicking “unsubscribe” on the emails you receive from us. 

Making Payments. When you make payments to pay for a Course, you must provide personal information to our third-party service providers, including first and last name, email address, phone number, mailing address and credit card information.

Promotions and Competitions.  If you choose to participate in a promotion or competition, we may collect, use and disclose information as described in the promotion or competition.  

Surveys.  In most cases, information from surveys will be used on an aggregated, de-identified, or anonymous basis to help us improve the Boot Camp Service.  In certain limited cases, we may disclose information collected by a survey to instructors, teaching assistants, or career coaches in order to provide educational or career support such as tutoring or career counseling. 

It is always your choice whether or not to provide us with such information.  If you do provide information to the Site, you are giving your express consent to the collection, use, retention and disclosure of the information as described in this Privacy Policy.  If you choose not to provide the requested information you may not be able to access the Boot Camp Service or certain features of this Site. You may access or change your information as described below.

Cookies, Automatic Data Collection, and Related Technologies.

The Boot Camp Service collects and stores information that is generated automatically as you use it, including your preferences and usage statistics. When you visit the Boot Camp Service, we and our third-party service providers receive and record information on our server logs, including your IP address, the type of internet browser or device you use any website you have come to the Site from and your operating system. The Site also uses cookies and similar technology. Cookies are small text files that include a unique reference code placed in a visitors’ device to store their preferences and sometimes track information. A number of cookies we use last only for the duration of your web session and expire when you close your browser. Other cookies are used to remember you when you return to our Site and will last for longer.

We use cookies for the following reasons:

Strictly necessary cookies: These cookies are essential in order to enable you to move around the Site and use its features, such as accessing the secure areas of the Site. They also enable us to deliver services you have asked for.

• Examples of strictly necessary cookies set by us are cookies that keep you logged in during your visit on the Site and that enable you to navigate between pages during a browser session so that you can use the Site most efficiently.

Performance cookies: These cookies collect statistical information on how visitors use our Site so that we can make improvements to the Site, how it works and our services.

• Examples of performance cookies set by us are cookies that track website traffic and help us collect data about what users are doing on our Site so that we can improve our website and enhance your overall experience.

Functionality cookies: These cookies allow the Site to remember choices you make such as your user name when you login to your account or the language or region you are in. They may also be used to help you watch a video or comment on a blog and are intended to improve your online experience.

• Examples of functionality cookies set by us are cookies that may serve a different version of the Site to you as compared to other users to determine which version works better, cookies that prevent you from seeing different homepages or other split tests in the future, and bookmarking cookies that help us retrieve and display information you stored on our Site for your next visit.

Targeting Cookies: Targeting Cookies help ensure that the ads you see are relevant to you and your interests. Targeting Cookies may also be placed on your device by our third-party partners that remember you have visited the Site in order to provide you with ads more relevant to you. For more information about targeting cookies, and about how to turn this feature off please visit www.youronlinechoices.com.

• Examples of targeting cookies set by us are cookies that tell us where you came from so that we can evaluate marketing and advertising campaigns, cookies that help us determine where you are located so that we can serve you advertisements that are relevant to you based on your location and cookies that help us group you into interest groups with other users so that we can show you advertisements that are relevant to you while you’re on our Site and on other websites.

Some of the cookies on our Site are set by us (first party cookies) and some are set by third parties who are delivering services on our behalf.

Most computer and some mobile web browsers automatically accept cookies but, if you prefer, you can use your browser to notify you each time a cookie is set or to block and delete cookies from your browser. However, please note that if you do that, the Boot Camp Service may not work properly and you may not be able to take full advantage of the Site or our services. You can learn more about cookies by visiting www.allaboutcookies.org which includes additional useful information on cookies and how to block cookies using different types of browser.

In addition to cookies we use the following similar technologies on the Site:

• Pixel Gifs/web beacons – these are small image files that may be placed by us or third parties in respect of your use of the Site or within the body of our newsletters so we or third parties can understand which parts of the Site are visited or whether particular content is of interest.

HOW WE USE YOUR INFORMATION 

We use your information for the following purposes:

• To identify you and your account;
• To provide and improve our services;
• To communicate with you; and 
• For our marketing purposes; 

You can opt out of promotional or marketing emails by clicking on “unsubscribe” at the bottom of the emails you receive from us.  You can stop text messages by texting “STOP” to text messages you receive from us.  

INFORMATION SHARING AND DISCLOSURE

We may disclose your personal information and education records to (i) business partners (including providers of technology platforms) involved in the fulfillment of the program so that they can assist us in delivering the Boot Camp Service and other services we provide to you, (ii) potential employers so that they may make a determination as to whether to hire you, and (iii) our educational partners so that they can track your progress, work with us to assist you in the event that you are dissatisfied or need assistance, and provide you with a Certificate upon completion. These third parties are contractually obligated to maintain the confidentiality of your personal information consistent with the terms of this policy and to comply with the applicable data protection laws.

Displaying to Other Users. If you post content to the Boot Camp Service it may be displayed on the Boot Camp Service. Other users of the Boot Camp Service may be able to view and use information you post, such as information contained in comments posted in a chat room or on a blog post. We do not have responsibility or liability for information you post. You should exercise caution when using public forums and not disclose your personal information.

Disclosure to Advertisers and Marketers. We disclose your personal information and education records to advertisers whose content we publish or display, or with third party ad servers to serve you advertisements.

Disclosure in Response to Valid Legal Process. We will disclose your information in response to valid legal process, for example, in response to a court order, a subpoena or other legal request for information, and/or to comply with applicable legal and regulatory reporting requirements.  We also may disclose your information in response to a law enforcement agency’s request or other request for information from U.S. or other government entities, or where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, or to verify or enforce compliance with the policies governing our products and/or services and with applicable laws, or as otherwise required or permitted by law or consistent with legal requirements.  In addition, we may transfer your information to an entity or individual that acquires, buys, or merges with us, or our other business units. 

We may also disclose your personal information or education records with your permission, for example, with potential employers.

Merger, Sale, or Other Asset Transfers and Investors. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, your information which we have collected may be used, sold or transferred to third parties such as venture capital or private equity groups, investment banks, or successor companies as part of such a transaction as permitted by law and/or contract. We cannot control how such entities may use or disclose such information.

PAYMENTS  

Payments made on the Site are made through our third-party payment vendor. If you enroll through the Site, you will be providing payment and/or or credit card information, including your name, billing address and other payment information, directly to our payment vendor which operates a secure server to process payments details, encrypting your credit/debit card information and authorize payment. If you enroll over the phone, our agents will enter your information into our payment vendor’s terminal and a copy of such information will be stored in on our servers. We collect and store payment information in order to verify payment and resolve payment disputes. Payment information is subject to each of our payment vendors’ own privacy policy and terms and conditions.

LINKS TO OTHER SITES

SECURITY OF YOUR INFORMATION

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration and disclosure. All information you provide to us is stored on secure servers. All information provided and transactions conducted on our Site, including payment transactions, will be encrypted using SSL technology.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Site, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Site like message boards. The information you share in public areas may be viewed by any user of the Site.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Site. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site.

CHILDREN’S PRIVACY

We do not knowingly collect information from children under 16 and we do not want it. We will take steps to delete it if we learn we have collected it.

We do not knowingly collect, maintain, or use personal information from children under 16 years of age, and no part of the Boot Camp Service is directed to children under the age of 16. If you learn that your child has provided us with personal information without your consent, you may alert us using the contact information below. If we learn that we have collected any personal information from children under 16, we will promptly take steps to delete such information and terminate the child’s account.

GOVERNING LAW/INTERNATIONAL USERS

By choosing to visit the Boot Camp Service or otherwise provide information to us, you agree that any dispute over privacy or the terms contained in this Privacy Policy will be governed by the law of the state of New York and the adjudication of any disputes arising in connection with Boot Camp or the Boot Camp Service will be in accordance with the Boot Camp Terms.

The Site and the Boot Camp Service are based in the U.S.   Any data provided to the Site or the Boot Camp Service will be processed and stored in the U.S. where our servers are located.   By using the Site or the Boot Camp Service, you expressly consent to the collection, retention, use, disclosure and transfer, including international transfer of your personal information to the U.S. in accordance with this Privacy Policy, regardless of your physical location. 

ACCESS, CORRECT OR UPDATE YOUR INFORMATION; QUESTIONS; COMPLAINTS OR POSE A QUESTION OR SUGGESTION

If you would like to obtain a copy of the education records held about you by us, update, amend or correct any information that you have provided to us through your use of the Boot Camp Service or otherwise, or if you have any questions or suggestions for improving this Privacy Policy, please contact us using the information below.   If you have a question or complaint regarding your personal information or education records, or if you wish to exercise any rights to your information under FERPA, please contact us using the information provided below. In the event of a conflict between this Privacy Policy and any law that applies to you, we will follow the applicable law.

NOTICE FOR CALIFORNIA CONSUMERS

Categories of Personal Information that We Collect
As required by the California Consumer Privacy Act (“CCPA”), below are the categories of personal information about California consumers that the Boot Camp collects and discloses for a business purpose. We do not sell personal information.  

We collect and disclose for a business purpose the following categories of personal information:

• Contact Information and Identifiers, including real name, alias, postal address, unique personal identifier, online identifier, IP address, email address, phone number, account name, or other similar identifiers.
• Customer Records, including paper and electronic customer records containing personal information, such as name, signature, address, telephone number, education, employment, employment history, financial information relevant to your payments, or medical information relevant to your participation in the Boot Camp.
• Usage Data, including internet or other electronic network activity information, such as browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement.
• Employment History, including professional or employment-related information.
• Education Information, including information about education history or background.
• Protected Classifications, including characteristics of protected classifications under California or federal law such as race, color, sex, age, religion, national origin, disability, and citizenship status.

Categories of Sources of Personal Information
The categories of sources of personal information we collect are described in the section The Information Boot Camp Collects from You above.

Purposes for Collecting Personal Information
We collect the personal information identified above to communicate with you, for advertising and marketing purposes, to provide and improve our services, and other purposes set forth in How We Use Your Information above.

Categories of Third Parties with Which Personal Information is Shared
We share personal information identified above with the following categories of third parties:

• Our educational partners,
• Third-party providers that serve business, professional or technical support functions,
• Potential employers (as directed by you), or
• Third parties for legal matters or safety purposes. 

California Consumer Rights
California law gives California consumers the right to make the following requests:

• The right to opt-out of sale of your personal information.  Boot Camp does not sell personal information.
• The right to request a copy of the personal information that we have collected about you in the prior 12 months.  
• The right to request deletion of the personal information that we have collected from you, subject to certain exemptions (for example, where the information is used by us to detect security incidents, debugging or to comply with a legal obligation).
• The right to request more details about the personal information we collect and how and why we use and share it, including the categories of personal information we have collected about you, the categories of sources for personal information we collect, the business or commercial purposes for collecting personal information, and the categories of third parties with which we share personal information.

You can submit a copy, deletion, or right-to-know request online by filling out Boot Camp’s Data Request Form or by contacting us at 1-888-213-3391.

The CCPA prohibits discrimination against California consumers for exercising their rights under the CCPA and imposes requirements on any financial incentives offered to California consumers related to their personal information, unless the different prices, rates, or quality of goods or services are reasonably related to the value of the consumer’s data.

TERMS OF USE

Please also review our Terms of Use section establishing the use, disclaimers and limitations of liability governing the use of our website at http://bootcamps.vanderbilt.edu/.

CONTACT INFORMATION

Boot Camp           
105 East 34th Street #225
New York, New York 10016
bootcamp@trilogyed.com