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(Last Updated: August 2023)
“Personal Information” is information that identifies you as an individual or relates to an identifiable individual, which may include:
- Postal address
- Email address
- Online identifier, such as an Internet Protocol address
- Telephone number
- Educational records
- Work history or other employment information
- Emergency contact details
- Demographic data, including, where relevant, racial and ethnic origin, health and disability information
- Commercial information, such as purchase history
- National and student ID numbers, such as a social security, driver’s license, passport, or tax ID
- Membership in professional or industry associations
- Credit and debit card number
- Bank account details
- Profile picture
- Social media account ID
- Biometric data
- Geolocation data
- Inferences drawn from your Personal Information, such as consumer preferences
Collection of Personal Information
We and our service providers collect Personal Information in a variety of ways, including:
- Through the Services
- We collect Personal Information through the Services, for example, when you visit one of our sites, apply for admission, or maintain an ongoing relationship with Walden as a student.
- From you during your course of study or period of enrollment with us.
- We collect Personal Information from you offline, such as when you complete an application for admission, fill out a form at an education or career fair, apply for a student ID card, participate in a promotion, or contact us by phone.
- From Other Sources
- We receive your Personal Information from other sources, for example:
- our affiliates, partners, and service providers;
- private and publicly available databases;
- application references and/or recommendation writers; and
- other educational institutions.
- If you connect your social media account to your Services account, you will share certain Personal Information from your social media account with us, for example, your name, email address, photo, list of social media contacts, and any other information that may be or you make accessible to us when you connect your social media account to your Services account.
- We receive your Personal Information from other sources, for example:
Use of Personal Information
We and our affiliates, partners, and service providers use Personal Information for legitimate business purposes including:
- Providing the functionality of the Services and fulfilling your requests.
- To provide the Services’ functionality to you, such as arranging access to your registered account and providing you with related assistance.
- To respond to your inquiries and fulfill your requests, when you contact us via one of our online contact forms or otherwise, for example, when you send us questions, suggestions, or complaints.
- To complete your transactions and provide you with related assistance.
- To send administrative information to you, such as changes to our terms, conditions and policies.
- To allow you to send messages to another person if you choose to do so.
- To respond to valid government inquiries.
We will engage in these activities to manage our contractual relationship with you and/or to comply with a legal obligation.
- Providing you with our newsletter and/or other marketing materials and facilitating social sharing
- To send you marketing related emails, with information about our services and other news about us.
- To facilitate social sharing functionality that you choose to use.
We will engage in this activity with your consent or where we have a legitimate interest.
- Analysis of Personal Information for business reporting and providing personalized services.
- To analyze or predict our users’ preferences in order to prepare aggregated trend reports on how our digital content is used, so we can improve our Services.
- To better understand you, so that we can personalize our interactions with you and provide you with information and/or offers tailored to your interests.
- To better understand your preferences so that we can deliver content via our Services that we believe will be relevant and interesting to you.
We will provide personalized services either with your consent or because we have a legitimate interest.
- Allowing you to participate in sweepstakes, contests, or other promotions.
- We may offer you the opportunity to participate in a sweepstakes, contest, or other promotion.
- Some of these promotions have additional rules containing information about how we will use and disclose your Personal Information.
We use this information to manage our contractual relationship with you.
- Aggregating and/or anonymizing Personal Information.
- We may aggregate and/or anonymize Personal Information so that it will no longer be considered Personal Information. We do so to generate other data for our use, which we may use and disclose for any purpose.
- Accomplishing our business purposes.
- For data analysis, for example, to improve the efficiency of our Services;
- For audits, to verify that our internal processes function as intended and are compliant with legal, regulatory or contractual requirements;
- For fraud and security monitoring purposes, for example, to detect and prevent cyberattacks or attempts to commit identity theft;
- For developing new services;
- For enhancing, improving, or modifying our current services;
- For identifying usage trends, for example, understanding which parts of our Services are of most interest to users;
- For determining the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users; and
- For operating and expanding our business activities, for example, understanding which parts of our Services are of most interest to our users so we can focus our energies on meeting our users’ interests.
We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or because we have a legitimate interest.
Walden University does not sell Personal Information collected through the Services to third parties.
Disclosure of Personal Information
We disclose Personal Information:
- To our third party service providers, to facilitate services they provide to us.
- These can include providers of services such as website hosting, data analysis, payment processing, order fulfillment, information technology and related infrastructure provision, customer service, email delivery, auditing, and other services.
- To third parties, to permit them to send you marketing communications, consistent with your choices.
- To third-party sponsors of sweepstakes, contests, and similar promotions.
- By using the Services, you may elect to disclose Personal Information
- On message boards, classroom discussion forums, chat, profile pages, blogs and other services to which you are able to post information and content (including, without limitation, our Social Media Pages). Please note that any information you post or disclose through these services will become public and may be available to other users and the general public.
Other Uses and Disclosures
We also use and disclose your Personal Information as necessary or appropriate, especially when we have a legal obligation or legitimate interest to do so:
- To comply with applicable law.
- This can include laws outside your country of residence.
- To respond to requests from public and government authorities.
- These can include authorities outside your country of residence.
- To cooperate with law enforcement.
- For example, when we respond to law enforcement requests and orders.
- For other legal reasons.
- To enforce our terms and conditions; and
- To protect our rights, privacy, safety or property, and/or that of our affiliates, you or others.
- In connection with a sale or business transaction.
- We have a legitimate interest in disclosing or transferring your Personal Information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings). Such third parties may include, for example, an acquiring entity and its advisors.
“Other Information” is any information that does not reveal or cannot be reasonably be used to reveal your specific identity or does not directly relate to an identifiable individual, and may include:
- Browser and device information
- App and/or Website usage data
- Information collected through cookies, pixel tags, and other technologies
- Demographic information and other information provided by you that does not reveal your specific identity, such as your gender or date of birth
- Information that has been aggregated in a manner such that it no longer reveals your specific identity
- Information that has been deidentified or pseudonymized in a manner such that it no longer reveals your specific identity
If we are required to treat Other Information as Personal Information under applicable law, then we may use and disclose it for the purposes for which we use and disclose Personal Information as detailed in this Policy.
Collection of Other Information
We and our service providers collect Other Information in a variety of ways, including:
- Through your browser or device
- Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version and the name and version of the Services (such as the App) you are using. We use this information to ensure that the Services function properly.
- Through your use of the Apps
- When you download or use the Apps, we and our service providers may track and collect App usage data, such as the date and time the App on your device accesses our servers and what information and files have been downloaded to the App based on your device number.
- Using cookies
- Using pixel tags and other similar technologies
- Pixel tags (also known as web beacons and clear GIFs) may be used to, among other things, track the actions of users of the Services (including email recipients), measure the success of our marketing campaigns, and compile statistics about usage of the Services and response rates.
- Display Advertising. Walden University and its affiliates utilize Display Advertising for remarketing purposes. This involves collecting demographic data (age, gender, and interests) in Google Analytics for site optimization, remarketing, and understanding user behaviors. If you wish to opt out of this, please use the Google Analytics Opt-out Browser Add-on. Walden University and its affiliates use remarketing in conjunction with Google Analytics. Third-party vendors, such as Google, may show relevant advertisements on sites across the Internet. Walden University, its affiliates, and third-party vendors utilize Google Analytics’ first-party cookies and Doubleclick’s third-party cookies together to inform, optimize, and serve ads based on a user’s past visits to this website. In addition, these cookies are used to report ad impressions, other uses of ad services, and interactions with the website.
- Using Adobe Flash technology (including Flash Local Shared Objects (“Flash LSOs”)) and other similar technologies
- We may use Flash LSOs and other technologies to, among other things, collect and store information about your use of the Services. If you do not want Flash LSOs stored on your computer, you can adjust the settings of your Flash player to block Flash LSO storage using the tools contained in the Website Storage Settings Panel. You can also go to the Global Storage Settings Panel and follow the instructions (which may explain, for example, how to delete existing Flash LSOs (referred to as “information”), how to prevent Flash LSOs from being placed on your computer without your being asked, and how to block Flash LSOs that are not being delivered by the operator of the page you are on at the time). Please note that setting the Flash Player to restrict or limit acceptance of Flash LSOs may reduce or impede the functionality of some Flash applications.
- IP Address
- Your IP address is automatically assigned to your computer by your Internet Service Provider. An IP address may be identified and logged automatically in our server log files whenever a user accesses the Services, along with the time of the visit and the page(s) that were visited. Collecting IP addresses is standard practice and is done automatically by many websites, applications and other services. We use IP addresses for purposes such as calculating usage levels, diagnosing server problems and administering the Services. We may also derive your approximate location from your IP address.
- Physical Location
- We may collect the physical location of your device by, for example, using satellite, cell phone tower or WiFi signals. We may use your device’s physical location to provide you with personalized location-based services and content. We may also share your device’s physical location, combined with information about what advertisements you viewed and other information we collect, with our marketing partners to enable them to provide you with more personalized content and to study the effectiveness of advertising campaigns. In some instances, you may be permitted to allow or deny such uses and/or sharing of your device’s location, but if you do, we and/or our marketing partners may not be able to provide you with the applicable personalized services and content.
Uses and Disclosures of Other Information
We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. In some instances, we may combine Other Information with Personal Information. If we do, we will treat the combined information as Personal Information as long as it is combined.
We seek to use reasonable organizational, technical and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contacting Us” section below.
Choices and Access
Your choices regarding our use and disclosure of your Personal Information
We give you choices regarding our use and disclosure of your Personal Information for marketing purposes. You may opt-out from:
- Receiving email marketing from us: If you no longer want to receive marketing-related emails from us on a going-forward basis, you may opt-out by following the instructions contained in each such email or by contacting us at [email protected].
- Receiving other types of marketing communications from us: If you no longer want to receive marketing-related communications from us on a going-forward basis, you may opt-out by contacting us at [email protected].
- Our sharing of your Personal Information with affiliates for their direct marketing purposes: If you would prefer that we discontinue sharing your Personal Information on a going-forward basis with our affiliates for their direct marketing purposes, you may opt-out of this sharing by contacting us at [email protected].
- Our sharing of your Personal Information with unaffiliated third parties for their direct marketing purposes: If you would prefer that we discontinue sharing your Personal Information on a going-forward basis with unaffiliated third parties for their direct marketing purposes, you may opt-out of this sharing by contacting us at [email protected].
We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt-out of receiving marketing-related communications from us, we may still send you important administrative messages, from which you cannot opt-out.
How you can access, change, or delete your Personal Information
If you would like to request to review, correct, update, suppress, restrict or delete Personal Information that you have previously provided to us, or if you would like to request to receive an electronic copy of your Personal Information for purposes of transmitting it to another organization (to the extent this right to data portability is provided to you by applicable law), or if you would like to request information about how your Personal Information has been collected or disclosed, you may contact us using the “Contact Us” information below. We will respond to your request consistent with applicable law.
In your request, please make clear what Personal Information you would like to have changed, whether you would like to have your Personal Information suppressed from our database or otherwise let us know what limitations you would like to put on our use of your Personal Information. For your protection, we will only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity by requesting additional documentation before implementing your request. We will try to comply with your request as soon as reasonably practicable.
Please note that we need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion (e.g., when you make a payment, you may not be able to change or delete the Personal Information provided until after the completion of such transaction).
If you are a resident of California, under 18 and a registered user of the Services, you may ask us to remove content or information that you have posted to the Services by writing to us at the Contact Us address below. Please note that your request does not ensure complete or comprehensive removal of the content or information, as, for example, some of your content may have been reposted by another user.
We retain Personal Information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law.
The criteria used to determine our retention periods include:
- The length of time we have an ongoing relationship with you and provide the Services to you (for example, for as long as you are a student of ours);
- Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
- Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).
Third Party Services
In addition, we are not responsible for the information collection, use, disclosure or security policies or practices of other organizations, such as Facebook, Apple, Google, Microsoft, RIM, or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including with respect to any Personal Information you disclose to other organizations through or in connection with the Apps or our Social Media Pages.
Third Party Advertising
We use third-party advertising companies to serve advertisements regarding goods and services that may be of interest to you when you access and use the Services and other websites or online services.
- From Australia: Your Online Choices
- From Canada: AdChoices
- From Europe: European Interactive Digital Advertising Alliance (EDAA)
- From the U.S.: About Ads and NAI's Opt-out .
If you are in the U.S., you may download the AppChoices to opt out in mobile apps.
Use of Services by Minors
The Services are not directed to individuals under the age of sixteen (16), and we do not knowingly collect Personal Information from individuals under sixteen (16).
Jurisdiction and Cross-Border Transfer
Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services you understand that your information will be transferred to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Information.
If you are located in the European Economic Area (“EEA”)
Some of the non-EEA countries are recognized by the European Commission as providing an adequate level of data protection according to EEA standards. For transfers from the EEA to countries not considered adequate by the European Commission, we have put in place adequate measures, such as standard contractual clauses adopted by the European Commission to protect your Personal Information. You may obtain a copy of these measures by reviewing Data Protection in the EU.
Third Party Payment Service
Additional Information for Individuals in the EEA
If you are located in the EEA, you also may lodge a complaint with a data protection authority for your country or region or where an alleged infringement of applicable data protection law occurs.
Additional Information for Individuals in California
Under the California Consumer Privacy Act (“CCPA”), California residents have the right to not receive discriminatory treatment for the exercise of the privacy rights conferred by the CCPA. California residents also have the right to designate an authorized agent to make a request under the CCPA on the resident’s behalf.
Trademarks, Copyright, and Disclaimers
Walden University and Education for Good are registered trademarks of Walden University, LLC. Elements of the Walden University website are protected by trade dress and other laws. The website and its contents may not be copied or imitated in any way without the express written consent of Walden University, LLC.
© 2023 Walden University, LLC. All rights reserved. The contents of the Walden University website pages, including, but not limited to, text, graphics, and icons, are copyrighted materials owned or controlled by Walden University and contain Walden University’s name, trademarks, service marks, and trade names. Students may download one copy of these materials on any single computer and print a copy of the materials for their use in learning about, evaluating, or acquiring Walden University services or products. No other permission is granted to students to print, copy, reproduce, distribute, transmit, upload, download, store, display in public, alter, or modify these materials.
Link Policy and Disclaimer
Walden University is not responsible for the content of any third-party-linked site that is not owned by Walden University, or of any other links contained in such third-party sites. Walden University provides links for students’ convenience only, and the inclusion of any link to a site not owned by Walden is not an endorsement by Walden of the site or its contents. Walden University assumes no responsibility for any other party’s site hyperlinked to the Walden University website or in which any part of the Walden University website has been hyperlinked.
No permission is granted here for students to use Walden University’s icons, site address, or other means to hyperlink other Internet sites with any page in the Walden University website. Students must obtain prior written permission to hyperlink in any manner to the Walden University website.
Warranty and Other Disclaimers
The materials and information found on the Walden University website are provided “as is,” without warranty of any kind, either express or implied, including without limitation any warranty for information, services, or products provided through or in connection with the Walden University website. Without limiting the foregoing, all implied warranties of merchantability, fitness for a particular purpose, expectation of privacy, or non-infringement are expressly excluded and disclaimed. Some jurisdictions do not allow the exclusion of implied warranties, so the above exclusion may not apply to all students. This disclaimer of liability applies to any damages or injury caused by any failure of performance, error, omission, interruption, deletion, defect, delay in operation or transmission, computer virus, communication line failure, theft or destruction, or unauthorized access to, alteration of, or use of record, whether for breach of contract, tortious behavior, negligence, or under any other cause of action. Students specifically acknowledge that Walden University is not liable for any defamatory, offensive, infringing, or illegal materials or conduct, or that of third parties contained on the Walden University website, and Walden University reserves the right to remove such materials from the Walden University website without liability.
Statement of Ownership
Walden University is a member of Adtalem Global Education Inc. (NYSE: ATGE; member S&P MidCap 400 Index), a leading workforce solutions provider headquartered in the United States. Adtalem’s purpose is to empower students to achieve their goals, find success and make inspiring contributions to our global community. Adtalem Global Education Inc. is the parent organization of American University of the Caribbean School of Medicine, Chamberlain University, Ross University School of Medicine, Ross University School of Veterinary Medicine, and Walden University. For more information, please visit adtalem.com.
Adtalem Global Education – Home Office
500 W. Monroe Street, Suite 28
Chicago, IL 60661
Telephone Number: 312.651.1400