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Privacy Policy

(Last updated: March 1, 2024)

Walden University (“Walden”, “we”, or “us”) is a pioneer in high-quality distance education for working professionals.. Walden aims to raise the standard of nursing and healthcare education and advance healthcare outcomes in communities across the United States and around the world. Walden is a subsidiary group company of Adtalem Global Education, Inc.

This Privacy Policy describes how we collect, use, maintain, process, and disclose your personal information and the choices you can make about how we collect, use, process, and disclose your personal information (As used throughout this policy, the terms “collect, use, maintain, process, and disclose” as related to your personal information shall be collectively referred to as “collect”.)  Walden does not sell personal information.  This Privacy Policy applies to personal information collected through this website and other services we offer, and anywhere else the Policy is posted (collectively, our “Services”). If you reside or are in the European Economic Area (“EEA”) or the United Kingdom (“UK”), Walden is the data controller of all personal information collected via the Services.

If you are a student at Walden, your educational information that is part of your educational record is maintained in accordance with the U.S. Federal Family Educational Rights and Privacy Act (“FERPA”), state laws, and Walden’s policies. Where certain state or local privacy laws are preempted by FERPA, Walden must abide by FERPA.

 

Personal Information We Collect

We collect personal information to provide and improve the Services we offer and to communicate with you about our Service offerings. We collect personal information in the following ways:

  • Information you provide to us: We collect personal information you provide to us as part of the Services, such as when you create an account with us, request informational materials, submit an application, enroll in our programs or courses, apply for financial aid, participate in a promotion or survey, use career services, set up profiles for online educational or administrative tools, utilize our online or offline resources, [attend a conference, event or other in-person function, or otherwise interact with us either online or offline. Examples of the type of information you may provide to us are:

 

    • Personal identifying information, such as your name, mailing address, email and phone number, social security number, date of birth, passport details, sex, national origin, medical condition, educational and employment history, photo, fingerprint information, financial information, health insurance information, and other similar type of personal identifiers;
    • Commercial Information such as account information, course login credentials, or other similar information;
    • Biometric information, which is defined as any information based on an individual's biometric identifiers used to identify an individual, such as retina or iris scans, fingerprints, voiceprints, scans of hand or face geometry, or 0ther unique biological patterns or characteristics used to identify an individual.
    • Testimonials provided for marketing materials;
    • Demographic information that identifies a group of people with a common characteristic who are legally protected from discrimination or retaliation based on that characteristic, job application or career preferences, interests, veteran or military status, and information provided on your applications for admission;
    • Payment information
    • Course and webinar enrollment information
    • Information that you provide in course discussion boards, community forums, in directories, on social media, or in response to promotions and surveys, such as photos, comments, and reviews;
    • Audio recordings in connection with coursework and testimonials;
    • Geolocation data, internet protocol addresses, and
    •  Professional and educational related information.

 

  • Information collected automatically: We automatically collect and store certain types of information about your use of the Services, such as information collected using cookies, pixels, and other tracking technologies. Examples of the type of information we may collect automatically includes:
    • Course access dates/times and course completion data;
    • IP address of the device you are using;
    • Device ID;
    • Location of your device;
    • Browser type;
    • Internet service provider;
    • Audio recordings when you make customer service calls for quality and training purposes;
    • Video recordings from CCTV security monitoring; and
    • Content interaction information, such as files or content viewed, time spent viewing content, and download information.
  • Information from other sources: We may receive information from other sources, such as education partners that administer exams and courses, provide scholarships or financial services, or manage educational records, service providers, testing centers, social media, third-party platforms and forums, and business partners. Examples of the type of information we may receive from other sources are:
    • Personal information, such as your name, personal and professional mailing address, email and phone number, and professional and educational history;
    • Educational performance, professional history, information contained in letters of reference, and student loan or grant information related to your attendance at Walden;
    • Profile information, comments, and similar information provided to or on social networks and other forums; and
    • Interests, demographic data, and internet browsing behavior.

Some of the information we collect may, when combined with other information, be personal information that could be used to identify you. Such information is treated as personal information.

You are responsible for ensuring the accuracy of personal information you provide to us. Inaccurate information may affect your ability to use the Services, the information you receive when using the Services, and our ability to contact you.

Where we need to collect personal information by law, or under the terms of a contract we have with you or in order to provide you with information you have requested, and you do not provide this information when requested, we may be prevented from complying with our legal obligations or we may not be able to perform all or part of the contract we are entering into with you or provide you with the information requested. For example, we require (a) certain information under law to process a financial aid application, (b) certain information in order to enroll you in a course, (c) your contact details in order to send you any information you have requested.

Special categories of data

When you make an application for admission to one of our courses of programs, our application form asks you about your racial/ethnic origin. You are not required to give us this information but if you choose to do so we only use it for equal opportunities monitoring and share it with the Department of Education for this purpose. Our legal basis for processing this data is your explicit consent.

All applicants deemed academically eligible by the Walden Admission Committee must initiate drug, background and fingerprint screenings and either clear all screenings within 120 days of the session start date or sign a self-attestation and disclosure indicating their ability to clear all screenings within 120 days of the session start date before the applicant is granted acceptance. Through these checks, we may potentially process health data, criminal convictions and offences data, and your biometric fingerprint information from a third-party background check provider. We will ask you whether we can do this. We only use this data for the purposes of conducting a fraud and security check and clearing your application to the Walden pre-licensure program. We retain this data while you are active in the program and for six years after you leave the program.

In addition, once your application to one of our courses or programs has been accepted, we collect details of any medical conditions you may have, your health insurance information and we may be able to infer information about your racial or ethnic origin from your nationality or from your passport. We only use this information for assisting students with any conditions you may tell us about so that we can arrange any additional support or make any necessary arrangements for you (this is for our legitimate interests in ensuring we provide equal opportunities for all applicants and for carrying out obligations in the field of social protection law.

How We Use the Personal Information Collected

We collect, maintain, use, store, and process the personal information we collect to provide and improve the Services, to support our business functions, as well as to personalize, provide, measure, and improve our advertising and marketing. We may use personal information to form a view on what we believe may be of interest to you. This is how we decide which content, product and service offerings may be relevant for you and direct you to particular areas of this website that we think will be most relevant for you.

Some examples of how we use personal information include:

  • To provide you with information, products, or services that you request from us such as details about our programs, enrollment, ongoing education, financial aid, student services, and career services (necessary for the performance of our contract with you or otherwise in our legitimate interests to provide you with the relevant information, products, or services);
  • To administer applications, enrollment, registration, financial services, housing, and alumni programs (necessary in order for us to enter into and for the performance of our contract with you and otherwise in our legitimate interests to administer such products or services);
  • To assess your eligibility for admission to Walden (necessary for us to enter into a contract with you);
  • To analyze student performance (our legitimate interests in understanding more about student performance to operate our business and improve our Services);
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection (necessary for the performance of our contract with you);
  • To process payment or facilitate delivery of services requested (necessary for the performance of our contract with you);
  • To provide you with support and respond to your inquiries, such as to investigate and address your concerns, and monitor and improve our responses (our legitimate interests in providing you with support, responding to your inquiries, and developing and improving our service);
  • To provide, personalize, measure, and improve our website experience and to deliver content and product and service offerings based on your advertising customization preferences (our legitimate interests in operating our website and keeping it updated and relevant);
  • To send you information about our products, services, and promotions (either your consent (where applicable law requires us to obtain your consent for marketing to you) or for our legitimate interests in promoting our products and services and growing our business);
  • To administer promotional activities, such as surveys, sweepstakes, contests, and referrals (either your consent where we request this or our legitimate interests in running such activities to promote our business);
  • To help maintain and improve the safety, security, and integrity of our campuses, facilities, website(s), and applications (our legitimate interests in maintaining network and physical security);
  • For testing, research, analysis, and product development, such as to develop and improve our websites, products and services, databases and other technology assets, and offerings (our legitimate interests in developing our business and product lines);
  • To support our general business operations (our legitimate interests in running and operating our business in a proper manner); and
  • As described to you when collecting your personal information to fulfill any other purpose for which you provide it.

Disclosing Personal Information

We may disclose your personal information to other businesses or entities where it is required for the performance of our contract with you, where it is required by law, or where we have another legitimate interest in doing so, as follows:

  • To our parent organization, only for use in the manner described in this Privacy Policy;
  • To service providers that perform services on our behalf, such as credit card payment processors, event planners and coordinators, data management and storage providers, marketers and advertisers, analytics and research companies, background check providers, and professional advisors. The above excludes text messaging originator opt-in data and consent; this information will not be shared with any third parties.
  • To clinical affiliates and residency programs;
  • To law enforcement agencies, regulators, and courts in response to a court order, subpoena, regulatory requirements, or similar legal process, to report any activities we reasonably believe to be unlawful, or as otherwise required by law;
  • To combat fraud or criminal activity, and to protect our rights, users, and business partners, or as part of legal proceedings affecting Walden;
  • To another entity in connection with a merger, transfer of data assets, reorganization, divestiture, financing, dissolution, or similar corporate event involving all or part of our business; and
  • Otherwise at your request or with your consent.

Cookies and Similar Technologies

We, as well as third parties that provide content or other functionality for our Services, may use cookies, pixel tags, web beacons, local storage, and other technologies to automatically collect information through the Services. These tracking technologies are small data files downloaded to or stored on your computer, tablet, mobile phone or other internet-enabled device that enable us to record certain pieces of information whenever you visit or interact with our email communications, website, applications, and tools. These technologies allow us to understand who has interacted with us and help us to operate our Services more efficiently, personalize your experience on our website, improve our content and offerings, engage in analytics and measurement, and show you advertisements in which you may be interested.

  • Cookies. Our site uses cookies that fall into the following categories: Strictly Necessary, Functionality, Performance, Third-Party, and Marketing and Advertising. For more information on cookies, please read our Online Cookie Policy
  • Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded on the website that collects information about users’ engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page.
  • Interest-based advertising. We permit third parties to use technologies on our website to collect information about your device and your use of our Services to advertise products and services to you that are tailored to your perceived interests, as well as to provide advertising-related services such as reporting, attribution, analytics, and market research. Such third parties may act on our behalf, and we may grant them the right to use your information for their own purposes. Typically, the information used for interest-based advertising is collected through cookies and other tracking technologies which recognize the device you are using and collect information about it and your use of our website and other websites and applications over time, including click stream information, browser type, time and date you visited the Services, AdID, precise geolocation and other information. For example, one such third party vendor, Google, shows our ads and uses cookies to serve ads based on a user’s prior visits to this website. We also use data analytics to serve ads based on a user’s prior visits to this website. Click here for more information about Google Ads
  • Analytics. We also use Google Analytics and Google Analytics Demographics and Interest Reporting to collect information regarding visitor behavior and visitor demographics for some of our Services and to develop content. Click here for more information about Google Analytics
  • Social Media. This website may include social media features, such as Facebook, LinkedIn, Twitter, Instagram, YouTube, or other widgets. These social media companies may recognize you and collect information about your visit to our website, and they may set a cookie or employ other tracking technologies. Your interactions with those features are governed by the privacy policies of those companies.

Your Choices in Relation to Tracking and Online Advertising

  • Users can visit Google Ad for more information about its settings.
  • Users can visit Google Analytics for information on how to opt-out of Google Analytics.
  • To opt-out of third-party interest-based advertising from advertisers and third parties that participate in certain self-regulatory programs, please visiting the Network Advertising Initiative and the Digital Advertising Alliance. Alternatively, you may opt-out of this advertising if you are located in the European Union by visiting Your Online Choices. Opt-outs are generally device and browser specific, meaning that you will need to opt-out on each device and browser you use. Please note, even if you opt-out of interest-based advertising, you will continue to receive generic ads.
  • Users can manager their cookie preferences by utilizing the online cookie preference center: Cookies Settings
  • For California users, please see our California Notice at Collection and Privacy Notice

Security

To help protect the privacy and security of your personal information we use reasonable security measures, including administrative, technical, and physical measures. These measures help protect against loss, misuse or unauthorized access, disclosure, alteration, or destruction of your personal information. Additionally, we train our colleagues about the importance of confidentiality and maintaining the privacy and security of your personal information.

While we do our best to protect your personal information, please be aware that no security measures are perfect or impenetrable. If you know or have reason to believe that your personal information has been lost, stolen, misappropriated, or otherwise compromised, please see the Contact Us section below for information about how to contact us.

International Transfer of Personal information

Personal information may be collected, used, disclosed, stored, and processed in a jurisdiction other than where you reside or are located, including in the United States where we are based and in other countries including Canada and the United Kingdom where the parties listed above are based for the purposes outlined above. These jurisdictions may have data protection laws that differ from your home jurisdiction. For individuals located in the EEA and UK, we are committed to protecting the privacy and confidentiality of your personal information when it is transferred and have put in place standard contractual clauses as appropriate safeguards to protect your personal information where this is required. If you require further information about this, you can contact us on the contact details listed at the end of this Privacy Policy.

Retention

We keep personal information for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting or reporting requirements and our legitimate interests in maintaining such personal information in our records. In doing this we will have regard to the amount, nature, and sensitivity of the personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and applicable legal requirements.

Third-Party Websites

Any links to third-party websites on our site are provided solely as a convenience to you. We do not endorse or make any representations about these websites or any products, materials, or services. Any personal information you provide on these third-party websites is subject to the privacy practices and policies of those sites. We do not accept any responsibility or liability for the privacy practices or content of any websites or services that are not operated by or for us.

EEA and UK Data Subject Privacy Rights

If you are an individual located in the EEA or UK, you have the following rights:

The right to request access to your personal information,

  • The right to edit, correct, and update your personal information,
  • The right to request erasure of your personal information,
  • The right to restrict processing of your personal information,
  • The right to object to the processing of your personal information,
  • The right to data portability, and/or
  • The right to withdraw your consent, to the extent that we have collected your personal information based on your affirmative informed consent.

We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances and as identified above:

  • Where it is necessary for our legitimate interests. This can include processing your personal information for the purposes of providing and enhancing the provision of our Services, as well as advertising our products, credentials, designations, services, and information to you.
  • Where we need to perform the contract, we have entered or are about to enter with you.
  • Where we need to comply with legal obligations, resolve disputes, and enforce our contractual agreements.
  • Where we have your express opt-in consent.

If you wish to contact us in connection with the exercise of your rights listed above, contact us at privacy@adtalem.com. Unless we notify you at the time of your request, we will not charge any fee in connection with the exercise of your rights. You also have the right to complain to or seek advice from a supervisory authority for data protection issues and/or bring a claim against us in any court of competent jurisdiction.

Notice for Nevada Residents

If you are a Nevada resident, you can opt out of sales of certain covered information that a website operator has collected or will collect about the resident. You can opt-out by clicking Do Not Sell My Personal Information and managing your preferences in the Cookies Settings

Notice for US Residents in Certain Other States

Residents of other US states including Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Montana, Oregon, Tennessee, Texas, Utah, and Virginia provide now or in the future have or will have the following rights:

  • The right to request access to your personal information,
  • The right to edit, correct, and update your personal information,
  • The right to request erasure of your personal information,
  • The right to restrict processing of your personal information,
  • The right to object to the processing of your personal information,
  • The right to data portability, and/or
  • The right to withdraw your consent, to the extent that we have collected your personal information based on your affirmative informed consent.

If you wish to contact us in connection with the exercise of your rights listed above, contact us at privacy@adtalem.com. Unless we notify you at the time of your request, we will not charge any fee in connection with the exercise of your rights. You also have the right to complain to or seek advice from a supervisory authority for data protection issues and/or bring a claim against us in any court of competent jurisdiction.

Parents/Guardians

Our Services are not directed to children under the age of 16 and we do not knowingly collect any personal information from children under the age of 16. Any personal data records that may be tied to an applicable individual who cannot provide parental consent will have their record deleted promptly as enforced by the Children’s Online Privacy Protection Act of 1998 (15 U.S.C. §§ 6501–6506). Certain data privacy laws may require an individual who is under 16 to provide parental consent. If this applies to you, please defer from utilizing our services until parental consent has been provided. If we become aware that we have unknowingly collected personal information from a child under the age of 16, and do not have parent or guardian consent on file, we will endeavor to delete such personal information from our records. If you believe we are incorrectly processing the personal information of a child under the age of 16, we recommend you contact us as provided in the final section of this policy.

Changes to this Privacy Policy

This Privacy Policy may be updated periodically. If we make material changes, we will attempt to let you know via email or other communication. We encourage you to periodically review this page for the latest information on our privacy practices. If you continue to use the Services, you agree to this Privacy Policy and any updates we make to it. We will not, however, use your personal information in a manner that is materially different than what we disclosed to you at the time the personal information was collected without your consent.

Contact Us

If you have any questions or concerns about this Privacy Policy, contact us at:


Adtalem Global Education
500 W. Monroe Street
28th Floor
Chicago, IL 60661
Email Us: privacy@adtalem.com

Notice for California Residents

(Last Updated: March 1, 2024)

This Walden California Privacy Notice (“California Privacy Notice”) should be read in conjunction with the main Walden Privacy Policy. This California Privacy Notice applies to information collected on this website and anywhere the policy is posted (collectively, our “Services”). We have adopted this California Privacy Notice pursuant to the California Consumer Privacy Act of 2018 (“CCPA”) and it applies only to residents of the State of California (“you”).

Scope

Some personal information we collect from you may not be covered by this California Privacy Notice because certain personal information collection and processing activities are exempt from the CCPA. Therefore, this California Privacy Notice and the California privacy rights set out below may not apply to you or to all your personal information.

Notice at Collection

We may collect the following categories of personal information about you:

  • Identifiers, such as, name, postal address(es), email address, phone numbers, date of birth, social security number, passport details, driver’s license number, online identifier, and IP address;
  • California Customer Records, such as name, postal address, phone numbers, driver’s license number, social security number, passport number, education information, employment information, employment history, bank account number, financial information, medical information, and health insurance information;
  • Characteristics of Protected Classifications Under California or Federal Law, such as, race, sex, age, national or ethnic origin, citizenship status, marital status, sexual orientation, veteran or military status, medical condition;
  • Commercial Information, such as, products or services purchased, other purchasing or consuming tendencies;
  • Biometric Information, such as fingerprint information.
  • Internet or Other Electronic Network Activity, such as, browsing history, search history, website, or advertisement interaction;
  • Geolocation Data, such as, IP address, physical location;
  • Audio, Video and Other Electronic Data, such as, audio, visual, or electronic information, including photos, call recordings, and CCTV footage;
  • Professional or Employment-related Information, such as, current, or past job history;
  • Education Information, such as education records directly related to students maintained by us or a third-party acting on our behalf, such as, grades, transcripts, class lists, student schedules, student identification codes, and disciplinary records. This also includes student directory information, including information such as a student’s name, address, telephone listing, date and place of birth, major field of study, participation in officially recognized activities and sports, weight and height of members of athletic teams, dates of attendance, degrees and awards received, and the most recent previous educational agency or institution attended by the student; and
  • Inferences drawn from online activities and the other data listed in this section, such as, a profile reflecting preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
  • Other Personal Information, such as the results of a drug and alcohol screen and criminal convictions and offences data.

We may use your personal information for the following purposes:

  • To provide you with information, products, or services that you request from us such as details about our programs, enrollment, ongoing education, financial aid, student services and career services;
  • To administer applications, enrollment, registration, financial services, housing, and alumni programs;
  • To assess your eligibility for admission to Walden;
  • To analyze student performance;
  • To fulfill any other purpose for which you provide it;
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us;
  • To process payment or facilitate delivery of services requested;
  • To provide you with support and respond to your inquiries, such as to investigate and address your concerns, and monitor and improve our responses;
  • To provide, personalize, measure, and improve our website experience and to deliver content and product and service offerings based on your advertising customization preferences;
  • To conduct background checks in connection with admission to clinical rotation programs;
  • To send you information about our products, services, and promotions
  • To administer promotional activities, such as surveys, sweepstakes, contests, and referrals. The above excludes text messaging originator opt-in data and consent; this information will not be shared with any third parties;
  • To help maintain and improve the safety, security, and integrity of our campuses, facilities, website(s), and applications;
  • For testing, research, analysis, and product development, such as to develop and improve our websites, products and services, databases and other technology assets, and offerings;
  • To support our general business operations
  • As described to you when collecting your personal information or to fulfill any other purpose for which you provide it.

 

You can opt-out by clicking Do Not Sell My Personal Information and managing your preferences in the Cookies Settings

Collection, Use and Sharing of Personal Information

This table sets out the categories of personal information that we have collected from you, the sources from which we have obtained it, the purpose for which we collect it and the categories of third parties and other entities with whom we have shared it. It sets out our relevant practices over the last 12 months. Our collection, use and disclosure of personal information depends on your relationship with us and your interaction with the Services. 

(Last Updated: March 1, 2024)

This Walden California Privacy Notice (“California Privacy Notice”) should be read in conjunction with the main Walden Privacy Policy. This California Privacy Notice applies to information collected on this website and anywhere the policy is posted (collectively, our “Services”). We have adopted this California Privacy Notice pursuant to the California Consumer Privacy Act of 2018 (“CCPA”) and it applies only to residents of the State of California (“you”).

Scope

Some personal information we collect from you may not be covered by this California Privacy Notice because certain personal information collection and processing activities are exempt from the CCPA. Therefore, this California Privacy Notice and the California privacy rights set out below may not apply to you or to all your personal information.

Notice at Collection

We may collect the following categories of personal information about you:

  • Identifiers, such as, name, postal address(es), email address, phone numbers, date of birth, social security number, passport details, driver’s license number, online identifier, and IP address;
  • California Customer Records, such as name, postal address, phone numbers, driver’s license number, social security number, passport number, education information, employment information, employment history, bank account number, financial information, medical information, and health insurance information;
  • Characteristics of Protected Classifications Under California or Federal Law, such as, race, sex, age, national or ethnic origin, citizenship status, marital status, sexual orientation, veteran or military status, medical condition;
  • Commercial Information, such as, products or services purchased, other purchasing or consuming tendencies;
  • Biometric Information, such as fingerprint information.
  • Internet or Other Electronic Network Activity, such as, browsing history, search history, website, or advertisement interaction;
  • Geolocation Data, such as, IP address, physical location;
  • Audio, Video and Other Electronic Data, such as, audio, visual, or electronic information, including photos, call recordings, and CCTV footage;
  • Professional or Employment-related Information, such as, current, or past job history;
  • Education Information, such as education records directly related to students maintained by us or a third-party acting on our behalf, such as, grades, transcripts, class lists, student schedules, student identification codes, and disciplinary records. This also includes student directory information, including information such as a student’s name, address, telephone listing, date and place of birth, major field of study, participation in officially recognized activities and sports, weight and height of members of athletic teams, dates of attendance, degrees and awards received, and the most recent previous educational agency or institution attended by the student; and
  • Inferences drawn from online activities and the other data listed in this section, such as, a profile reflecting preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
  • Other Personal Information, such as the results of a drug and alcohol screen and criminal convictions and offences data.

We may use your personal information for the following purposes:

  • To provide you with information, products, or services that you request from us such as details about our programs, enrollment, ongoing education, financial aid, student services and career services;
  • To administer applications, enrollment, registration, financial services, housing, and alumni programs;
  • To assess your eligibility for admission to Walden;
  • To analyze student performance;
  • To fulfill any other purpose for which you provide it;
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us;
  • To process payment or facilitate delivery of services requested;
  • To provide you with support and respond to your inquiries, such as to investigate and address your concerns, and monitor and improve our responses;
  • To provide, personalize, measure, and improve our website experience and to deliver content and product and service offerings based on your advertising customization preferences;
  • To conduct background checks in connection with admission to clinical rotation programs;
  • To send you information about our products, services, and promotions
  • To administer promotional activities, such as surveys, sweepstakes, contests, and referrals. The above excludes text messaging originator opt-in data and consent; this information will not be shared with any third parties;
  • To help maintain and improve the safety, security, and integrity of our campuses, facilities, website(s), and applications;
  • For testing, research, analysis, and product development, such as to develop and improve our websites, products and services, databases and other technology assets, and offerings;
  • To support our general business operations
  • As described to you when collecting your personal information or to fulfill any other purpose for which you provide it.

 

You can opt-out by clicking Do Not Sell My Personal Information and managing your preferences in the Cookies Settings

Collection, Use and Sharing of Personal Information

This table sets out the categories of personal information that we have collected from you, the sources from which we have obtained it, the purpose for which we collect it and the categories of third parties and other entities with whom we have shared it. It sets out our relevant practices over the last 12 months. Our collection, use and disclosure of personal information depends on your relationship with us and your interaction with the Services. 

Category of Personal Information Categories of Sources Business or Commercial Purpose   Categories of Third Parties and Other Entities with Whom We May Share

Identifiers, such as, name, postal address, email address, phone numbers, online identifiers, or IP address.

  • Directly from you
  • Automatically, such as via cookies and other tracking technologies
  • Our business partners and affiliates
  • Third parties
  • Your browser or device
  • Social media and third-party platforms
  • To fulfill your requests for products or services
  • To fulfill any other purpose for which you provide it.
  • To protect our rights and meet our legal obligations.
  • To provide you with support and respond to your inquiries.
  • To provide, personalize, measure, and improve our website experience.
  • To customize content
  • For our marketing and advertising purposes
  • For testing, research, analysis, and product development
  • To support our general business operations
  • Other uses about which we notify you.
  • To administer promotional activities, such as surveys, sweepstakes, contests, and referrals
  • To assess your eligibility for admission to certain institutions and programs
  • For customer service and customer support purposes
  • To analyze student performance
  • Our parent organization
  • Our service providers and business partners
  • Third parties
  • As may be permitted or required by law, such as with law enforcement and third parties pursuant to legal request or legal proceedings.
  • In connection with the sale or restricting of all our part of our business
  • At your request or with your consent

California Customer Records, such as name, address, or phone numbers

  • Directly from you
  • Our business partners and affiliates
  • Third parties
  • To fulfill your requests for products or services
  • To fulfill any other purpose for which you provide it.
  • To protect our rights and meet our legal obligations.
  • To provide you with support and respond to your inquiries.
  • To support our general business operations
  • Other uses about which we notify you.
  • To assess your eligibility for admission to certain institutions and programs
  • For customer service and customer support purposes
  • Our parent organization
  • Our service providers and business partners
  • Third parties
  • As may be permitted or required by law, such as with law enforcement and third parties pursuant to legal request or legal proceedings.
  • In connection with the sale or restricting of all our part of our business
  • At your request or with your consent

Characteristics of Protected Classifications Under California or Federal Law, such as race, sex, gender, sexual orientation, marital status, military, or veteran status, nationality, or ethnicity

  • Directly from you
  • Our business partners and affiliates
  • To protect our rights and meet our legal obligations.
  • To support our general business operations
  • To conduct background checks in connection with admission to clinical rotation programs
  • Other uses about which we notify you
  • Our parent organization
  • Our service providers and business partners
  • Law enforcement and third parties pursuant to legal request or legal proceedings, as may be permitted or required by law.
  • As may be permitted or required by law, such as with law enforcement and third parties pursuant to legal request or legal proceedings.
  • In connection with the sale or restricting of all our part of our business
  • At your request or with your consent 

Commercial Information, such as, products or services purchased and other purchasing or consuming tendencies.

  • Directly from you
  • Automatically, such as via cookies and other tracking technologies
  • Our business partners and affiliates
  • Our business partners and affiliates
  • Third parties
  • To fulfill your requests for products or services
  • To provide you with support and respond to your inquiries.
  • To provide, personalize, measure, and improve our website experience.
  • To customize content
  • For our marketing and advertising purposes
  • For testing, research, analysis, and product development
  • To support our general business operations
  • For customer service and customer support purposes
  • To analyze student performance
  • Other uses about which we notify you
  • Our affiliates
  • Our service providers and business partners
  • As may be permitted or required by law, such as with law enforcement and third parties pursuant to legal request or legal proceedings.
  • In connection with the sale or restricting of all our part of our business
  • At your request or with your consent 

Biometric Information, such as fingerprint information.

  • Directly from you
  • Our business partners and affiliates
  • To protect our rights and meet our legal obligations.
  • To conduct background checks in connection with admission to clinical rotation programs
  • Other uses about which we notify you.
  • Our parent organization
  • Our service providers and business partners
  • Third parties
  • As may be permitted or required by law, such as with law enforcement and third parties pursuant to legal request or legal proceedings.
  • In connection with the sale or restricting of all our part of our business
  • At your request or with your consent 

Internet or Other Electronic Network Activity, such as, browsing history, search history, or website or advertisement interaction.

  • Directly from you
  • Automatically, such as via cookies and other tracking technologies
  • Our business partners and affiliates
  • Your browser or device
  • Social media and third-party platforms
  • To provide, personalize, measure, and improve our website experience.
  • To customize content
  • For our marketing and advertising purposes
  • For testing, research, analysis, and product development
  • To support our general business operations
  • Other uses about which we notify you
  • Our parent organization
  • Our service providers and business partners
  • Third parties
  • As may be permitted or required by law, such as with law enforcement and third parties pursuant to legal request or legal proceedings.
  • In connection with the sale or restricting of all our part of our business
  • At your request or with your consent 

Geolocation Data, such as, IP address or physical location.

  • Automatically, such as via cookies and other tracking technologies
  • Your browser or device
  • To provide, personalize, measure, and improve our website experience.
  • To customize content
  • For our marketing and advertising purposes
  • For testing, research, analysis, and product development
  • To support our general business operations
  • Other uses about which we notify you
  • Our affiliates
  • Our service providers and business partners
  • Law enforcement and third parties pursuant to legal request or legal proceedings, as may be permitted or required by law.
  • As may be permitted or required by law, such as with law enforcement and third parties pursuant to legal request or legal proceedings.
  • In connection with the sale or restricting of all our part of our business
  • At your request or with your consent 

Audio, Video and Other Electronic Data, such as, photos, call recordings, or CCTV footage.

  • Directly from you
  • Our business partners and affiliates
  • To fulfill your requests for products or services
  • As security measures for our offices and campuses
  • To protect our rights and meet our legal obligations.
  • To provide you with support and respond to your inquiries.
  • For our marketing and advertising purposes
  • For customer service and customer support purposes
  • To support our general business operations
  • Other uses about which we notify you
  • Our parent organization
  • Our service providers and business partners
  • Law enforcement and third parties pursuant to legal request or legal proceedings, as may be permitted or required by law.
  • As may be permitted or required by law, such as with law enforcement and third parties pursuant to legal request or legal proceedings.
  • In connection with the sale or restricting of all our part of our business
  • At your request or with your consent 

Professional and employment-related information, such as business contact details, job title or employer;

  • Directly from you
  • Our business partners and affiliates
  • To fulfill your requests for products or services
  • To fulfill any other purpose for which you provide it.
  • For testing, research, analysis, and product development
  • To support our general business operations
  • Other uses about which we notify you
  • Our parent organization
  • Our service providers and business partners
  • As may be permitted or required by law, such as with law enforcement and third parties pursuant to legal request or legal proceedings.
  • In connection with the sale or restricting of all our part of our business
  • At your request or with your consent

Education information, meaning education records directly related to students maintained by us or a party acting on our behalf, such as grades, transcripts, class lists, student schedules, student identification codes, and student disciplinary records.

This also includes student directory information, including information such as a student’s name, address, telephone listing, date and place of birth, major field of study, participation in officially recognized activities and sports, weight and height of members of athletic teams, dates of attendance, degrees and awards received, and the most recent previous educational agency or institution attended by the student.

  • Directly from you
  • Third parties such as the U.S. Government and other educational institutions 
  • School officials
  • Other educational institutions
  • Third parties as may be permitted or required by law, including FERPA, such as with law enforcement and third parties pursuant to legal request or legal proceedings.
  • Third parties at your request or with your consent

Inferences drawn from this information, such as, a profile reflecting preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

  • Directly from you
  • Automatically, such as via cookies and other tracking technologies
  • Our business partners and affiliates
  • Third parties
  • Your browser or device
  • Social media and third-party platforms
  • To provide, personalize, measure, and improve our website experience.
  • To customize content
  • For our marketing and advertising purposes
  • For testing, research, analysis, and product development
  • To support our general business operations
  • Other uses about which we notify you.
  • To analyze student performance
  • Our parent organization
  • Our service providers and business partners
  • Third parties
  • As may be permitted or required by law, such as with law enforcement and third parties pursuant to legal request or legal proceedings.
  • In connection with the sale or restricting of all our part of our business
  • At your request or with your consent

Other Personal Information, such as the results of a drug and alcohol screen and criminal convictions and offences data.

  • Directly from you
  • Third parties
  • To conduct background checks in connection with admission to clinical rotation programs
  • Our service providers and business partners
  • Third parties at your request or with your consent

How We Share Personal Information

In the last twelve months, we have disclosed each of the categories of personal information listed above for business purposes, as set out above.

Sales of Personal Information

We disclose the following categories of personal information with third-party cookie and other ad-tech providers, who may further disclose your information throughout the digital advertising ecosystem. Such disclosures may be considered a sale for purposes of the CCPA.

  • Identifiers
  • California Customer Records
  • Internet or other electronic activity information
  • Geolocation data
  • Inferences drawn from personal information such as preferences, characteristics, and behaviors.

California Privacy Rights

To the extent provided for by law and subject to applicable exemptions, you have the following rights in relation to the personal information about you that we have collected:

  • Right to Know: You have the right to request the following information relating to our collection and use of your personal information over the past 12 months:
  • Categories of personal information we have collected about you;
  • Categories of sources of the personal information we collected about you;
  • Business and/or commercial purposes for collecting or, if applicable, selling that personal information;
  • Categories of third parties with whom we have disclosed or sold that personal information;
  • Specific pieces of personal information we have collected about you;
  • Categories of personal information that we have disclosed or sold with a third party for a business purpose; and
  • Categories of third parties to whom the residents’ personal information was sold.
  • Right to Deletion: You have the right to request that we delete your personal information. Subject to certain exceptions, we will endeavor to delete your personal information and direct any service provider to delete your personal information.
  • Right to Opt-Out: You have the right to direct us not to sell your personal information to third parties. If you are under the age of 16, you have the right to opt in, or to have a parent or guardian opt in on your behalf, to such sales.
  • Right to Non-Discrimination: You have the right not to receive discriminatory treatment for exercising any of the rights described above.

To Exercise Your Right to Know or Right to Deletion

California residents can submit requests to know and/or for deletion by emailing us at privacy@adtalem.com or calling us at 1-866-653-5656. California residents may make up to two requests to know within a 12-month period.

Verification: We will need to verify your identity before processing your request. To verify your identity, we will generally either require you to login to your account or we must be able to match certain information you provide us to the information we maintain about you. Certain requests may require us to obtain additional personal information from you. In certain circumstances, we may decline a request to exercise the right to know and/or right to deletion, particularly where we are unable to verify your identity or locate your information in our systems, or as permitted by law.

To Exercise Your Right to Opt-Out 

You can opt-out by clicking Do Not Sell My Personal Information and managing your preferences in Cookies Settings

Minors Under Age 16

We do not “sell” the personal information of consumers we know to be under 16 years of age. 

Parents/Guardians

Our Services are not directed to children under the age of 16 and we do not knowingly collect any personal information from children under the age of 16. Any personal data records that may be tied to an applicable individual who cannot provide parental consent will have their record deleted promptly as enforced by the Children’s Online Privacy Protection Act of 1998 (15 U.S.C. §§ 6501–6506). Certain data privacy laws may require an individual who is under 16 to provide parental consent. If this applies to you, please defer from utilizing our services until parental consent has been provided. If we become aware that we have unknowingly collected personal information from a child under the age of 16, and do not have parent or guardian consent on file, we will endeavor to delete such personal information from our records. If you believe we are incorrectly processing the personal information of a child under the age of 16, we recommend you contact us as provided in the final section of this policy.

Requests Submitted by Authorized Agents

In certain circumstances, you are permitted to use an authorized agent, as that term is defined by the CCPA (“Authorized Agent”), to submit requests on your behalf where you provide sufficient evidence that the requestor is an authorized agent with written permission to act on your behalf and you successfully verify your own identity with us. An Authorized Agent can make a request on a California resident’s behalf by:

  1. For requests to know and delete: (1) providing a valid power of attorney under the laws of California; or (2) providing sufficient evidence to show that the California resident has (i) provided the Authorized Agent signed permission to act on their behalf, (ii) verified their own identity directly with us, and (iii) directly confirmed with us that they have provided the Authorized Agent permission to submit the request on their behalf.
  2. For requests to opt- out: submitting a signed permission demonstrating that the Authorized Agent has been authorized by the California resident to act on their behalf.

Notice of Financial Incentives

From time to time, we may run sweepstakes, contests, or other offers and promotions (collectively, “Programs”) that may be deemed “financial incentives” in relation to our collection of personal information under the CCPA. Please refer to the terms and conditions of each Program for additional information about the Program, including how eligible consumers can opt-in or opt-out of the Program at any time. To enter a Program, you may be required to provide us or a service provider acting on our behalf with certain personal information, such as identifiers including your name and contact information (“Rewards Data”). If you submit your entry in accordance with the applicable Program’s rules, you may be entered into the Program and will get a chance to win a prize or receive another benefit from us. The value of Rewards Data is related to [the value of your information and the costs associated with offering the Program.

California “Shine the Light”

In addition to the rights described above, California’s “Shine the Light” law permits California residents to request certain information regarding our disclosure, if any, of certain categories of personal information to third parties for their direct marketing purposes during the immediately preceding calendar year. To make such a request, please send an email to privacy@adtalem.com. This request may be made no more than once per calendar year.

Do Not Track

Some web browsers may transmit “do-not-track” signals to websites with which the user communicates. We honor and respond to “do-no-track” signals.

Changes to this Privacy Notice

This California Privacy Notice may be updated periodically. If we make material changes, we will attempt to let you know via email or other communication. We encourage you to periodically review this page for the latest information on our privacy practices. If you continue to use the Services, you agree to this California Privacy Notice and any updates we make to it. We will not, however, use your personal information in a manner that is materially different than what we disclosed to you at the time the personal information was collected without your consent.

How to Contact Us

If you have any questions or concerns about this California Privacy Notice, contact us at:

Adtalem Global Education
500 W. Monroe Street
28th Floor
Chicago, IL 60661
Email Us: privacy@adtalem.com

How We Share Personal Information

In the last twelve months, we have disclosed each of the categories of personal information listed above for business purposes, as set out above.

Sales of Personal Information

We disclose the following categories of personal information with third-party cookie and other ad-tech providers, who may further disclose your information throughout the digital advertising ecosystem. Such disclosures may be considered a sale for purposes of the CCPA.

  • Identifiers
  • California Customer Records
  • Internet or other electronic activity information
  • Geolocation data
  • Inferences drawn from personal information such as preferences, characteristics, and behaviors.

California Privacy Rights

To the extent provided for by law and subject to applicable exemptions, you have the following rights in relation to the personal information about you that we have collected:

  • Right to Know: You have the right to request the following information relating to our collection and use of your personal information over the past 12 months:
  • Categories of personal information we have collected about you;
  • Categories of sources of the personal information we collected about you;
  • Business and/or commercial purposes for collecting or, if applicable, selling that personal information;
  • Categories of third parties with whom we have disclosed or sold that personal information;
  • Specific pieces of personal information we have collected about you;
  • Categories of personal information that we have disclosed or sold with a third party for a business purpose; and
  • Categories of third parties to whom the residents’ personal information was sold.
  • Right to Deletion: You have the right to request that we delete your personal information. Subject to certain exceptions, we will endeavor to delete your personal information and direct any service provider to delete your personal information.
  • Right to Opt-Out: You have the right to direct us not to sell your personal information to third parties. If you are under the age of 16, you have the right to opt in, or to have a parent or guardian opt in on your behalf, to such sales.
  • Right to Non-Discrimination: You have the right not to receive discriminatory treatment for exercising any of the rights described above.

To Exercise Your Right to Know or Right to Deletion

California residents can submit requests to know and/or for deletion by emailing us at privacy@adtalem.com or calling us at 1-866-653-5656. California residents may make up to two requests to know within a 12-month period.

Verification: We will need to verify your identity before processing your request. To verify your identity, we will generally either require you to login to your account or we must be able to match certain information you provide us to the information we maintain about you. Certain requests may require us to obtain additional personal information from you. In certain circumstances, we may decline a request to exercise the right to know and/or right to deletion, particularly where we are unable to verify your identity or locate your information in our systems, or as permitted by law.

To Exercise Your Right to Opt-Out 

You can opt-out by clicking Do Not Sell My Personal Information and managing your preferences in Cookies Settings

Minors Under Age 16

We do not “sell” the personal information of consumers we know to be under 16 years of age. 

Parents/Guardians

Our Services are not directed to children under the age of 16 and we do not knowingly collect any personal information from children under the age of 16. Any personal data records that may be tied to an applicable individual who cannot provide parental consent will have their record deleted promptly as enforced by the Children’s Online Privacy Protection Act of 1998 (15 U.S.C. §§ 6501–6506). Certain data privacy laws may require an individual who is under 16 to provide parental consent. If this applies to you, please defer from utilizing our services until parental consent has been provided. If we become aware that we have unknowingly collected personal information from a child under the age of 16, and do not have parent or guardian consent on file, we will endeavor to delete such personal information from our records. If you believe we are incorrectly processing the personal information of a child under the age of 16, we recommend you contact us as provided in the final section of this policy.

Requests Submitted by Authorized Agents

In certain circumstances, you are permitted to use an authorized agent, as that term is defined by the CCPA (“Authorized Agent”), to submit requests on your behalf where you provide sufficient evidence that the requestor is an authorized agent with written permission to act on your behalf and you successfully verify your own identity with us. An Authorized Agent can make a request on a California resident’s behalf by:

  1. For requests to know and delete: (1) providing a valid power of attorney under the laws of California; or (2) providing sufficient evidence to show that the California resident has (i) provided the Authorized Agent signed permission to act on their behalf, (ii) verified their own identity directly with us, and (iii) directly confirmed with us that they have provided the Authorized Agent permission to submit the request on their behalf.
  2. For requests to opt- out: submitting a signed permission demonstrating that the Authorized Agent has been authorized by the California resident to act on their behalf.

Notice of Financial Incentives

From time to time, we may run sweepstakes, contests, or other offers and promotions (collectively, “Programs”) that may be deemed “financial incentives” in relation to our collection of personal information under the CCPA. Please refer to the terms and conditions of each Program for additional information about the Program, including how eligible consumers can opt-in or opt-out of the Program at any time. To enter a Program, you may be required to provide us or a service provider acting on our behalf with certain personal information, such as identifiers including your name and contact information (“Rewards Data”). If you submit your entry in accordance with the applicable Program’s rules, you may be entered into the Program and will get a chance to win a prize or receive another benefit from us. The value of Rewards Data is related to [the value of your information and the costs associated with offering the Program.

California “Shine the Light”

In addition to the rights described above, California’s “Shine the Light” law permits California residents to request certain information regarding our disclosure, if any, of certain categories of personal information to third parties for their direct marketing purposes during the immediately preceding calendar year. To make such a request, please send an email to privacy@adtalem.com. This request may be made no more than once per calendar year.

Do Not Track

Some web browsers may transmit “do-not-track” signals to websites with which the user communicates. We honor and respond to “do-no-track” signals.

Changes to this Privacy Notice

This California Privacy Notice may be updated periodically. If we make material changes, we will attempt to let you know via email or other communication. We encourage you to periodically review this page for the latest information on our privacy practices. If you continue to use the Services, you agree to this California Privacy Notice and any updates we make to it. We will not, however, use your personal information in a manner that is materially different than what we disclosed to you at the time the personal information was collected without your consent.

How to Contact Us

If you have any questions or concerns about this California Privacy Notice, contact us at:

Adtalem Global Education
500 W. Monroe Street
28th Floor
Chicago, IL 60661
Email Us: privacy@adtalem.com