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What We Collect and Why
As an educational institution and employer, The College maintains records for our past, present and prospective students and employees. The College also has business relationships with external parties and, as such, maintains records for the individuals we work with through those collaborations. Information, including personal information, is collected by The College in a variety of ways at different points in an individual’s interaction with the institution for many different purposes. The following sections describe in more detail the types of information we hold, and how we may collect and use that information.
Types of Information We Hold
The College collects various types of information. Categories and examples of which include:
- Your contact information (e.g. name, personal or work mailing address, email address, phone number, employer and job title) and other types of personal information, including sensitive personal information, used to process requests and applications relating to admission, employment, or other College programs and services (e.g. birth date, age, gender, sex, state or federal ID numbers, race, marital status, military status, educational history, employment history, professional certifications)
- Records of your communications with the College (e.g. your IP address, login/logout dates, email open dates, email clicks, web traffic, contact preferences, student contact history, chat communications and information from feedback surveys)
- Technical information about your visit to or use of our Sites, (e.g. site analytics, browser information, referring URL’s, pages accessed, time and date accessed, operating system used, tracking data, session count, user count, and device type)
- Marketing information such as prospective student and partner leads, current interests, and preferences (contact preferences, settings, etc.)
- Records pertaining to your time at The College and your continuing affiliations with us (e.g. records of student work submitted through our learning management system and other academic records, records of participation in academic organizations, disciplinary records, employment records and alumni and donor records)
The above list is not exhaustive and the exact information we collect, store and process about you will depend on your relationship with us. Not all types of information are collected on all individuals.
How We Collect Your Information
We generally collect information two ways, (1) when you voluntarily provide it to us, and (2) automatically when you visit or use our Sites.
You voluntarily provide information to us when you choose to use the webforms, electronic applications, chat functions and other online communication tools available through our Sites, and when you choose to disclose information through your interactions with our student advisors, admission counselors and other authorized College representatives conducting college business.
Automatic Collection through Cookies and Similar Technologies
As you navigate through and interact with the Site, we may use automatic data collection technologies (cookies, web beacons, tags…) to collect certain information.
Cookies are small text files that are placed on your computer by websites to track your individual movements on that website over time.
Types of cookies used by The College on our Sites may include:
- Essential cookies — These are used to authenticate you, prevent fraud and provide you with the services that you have requested.
- Functional cookies — These are used to remember you and recall your settings or preferences (such as language) when you return to our website. These cookies are not used to track you when you visit other websites.
- Performance cookies — These are used to measure the performance of our website and online services. We use the information gathered from these cookies to improve our sites, as well as the products and services we offer.
- Analytics cookies – These are used to help us better understand the effectiveness of our marketing and content delivery to make sure content is relevant to you and your interests.
Cookies used by our Sites may be session-based or persistent. Session-based cookies last only for the duration of a user’s session, while a persistent cookie remains on the user’s hard drive. A persistent cookie can help us recognize you when you return to our website and recall your settings or preferences.
Using our Preference Center, you can opt out of or change your preferences for most third-party cookies and tags on our Sites, except those that are “necessary” to the proper functioning of our Sites or features available to you on our Sites. In addition, you may block or disable cookies for the device and browser you are using through your browser settings; however, if you do so, certain features on our Sites may not be available or function properly.
To the extent permitted by applicable law, we may use, process, transfer, and store information about individuals in an anonymous (or pseudonymous) and aggregated manner. We may combine personal information with other information collected online and offline, including information from third party sources. We may also use information in other ways with consent. By using our Sites and services, you agree that we are licensed to collect, use, share and store anonymized (or pseudonymized) aggregated data collected through our Sites and services for benchmarking, analytics, research, reporting, and other business purposes.
How We Use the Information We Collect
Broadly speaking, your personal information will be used by us for the purpose of contacting you regarding information that you have requested, in conjunction with aggregated information and cookies, and/or for improving our education and other services, our marketing, and our Sites. We may store your information for the purpose of communicating with you about the educational programs and services offered by The College and send you updates if and when they become available. We also use the information we collect for the purposes of administering our educational programs and conducting other university business, to provide services to our students, collaborators, and employees. Occasionally, we may also use the information we collect to notify you about important changes to our Sites or services, new services, educational programs and related offers we think you will find valuable.
Some more specific examples of how we may use your information include:
- Providing services to our students such as evaluating applications for admission, completing course registrations, enrolling you in academic groups or other programs, collecting tuition payments, facilitating your requests for support, and to deliver our online educational programs.
- Providing services to our alumni such as mailing alumni news, information, invitations and surveys, sending donation and engagement solicitations, reviewing web traffic and click-throughs on email to provide engagement statistics.
- Marketing uses such as targeted advertising via social media and other digital channels, audience classification and creation, sharing social content, tracking leads for analytics and communications purposes, conducting market research, surveys, and similar inquiries to help us understand trends and needs of our users, and offering newsletters, articles, event invitations and other information that we believe may interest you.
- Preventing, investigating, or providing notice of fraud, unlawful or criminal activity, or unauthorized access to or use of personal information, our website or data systems, investigating or resolving inquiries initiated by current or prospective students, to meet our legal obligations, to serve the public interest or public health, and for other lawful purposes. This includes but is not limited to identifying you or your wireless device to prevent fraud.
Legitimate Interests for Processing Personal Information
Most of The College’s collection and processing of personal information will fall under one or more of the following categories, depending on your relationship (past and present) with The College:
- Processing is necessary for the purposes of The College’s legitimate business interests, such as providing, improving and customizing our educational offerings, administering our operations, maintaining relationships with and fostering connections among college community members, exploring ways to develop and grow our operations, enhancing protection against fraud and security risks, offering attendance at events and other engagement opportunities, understanding how our online platforms are used, etc.
- Processing is necessary for the performance of a contract to which you are party or in order to carry out your requests of us.
- Processing is necessary for compliance with a legal obligation to which The College is subject.
- You have given your consent to the processing of your personal information for one or more specific purposes.
How We Share Information with Third Parties
The College does not sell personal information to outside parties for their commercial use. However, we may share information with third-parties, including our service providers, collaborators and affiliates, as follows:
- To third parties, such as contractors, service providers, consultants and other agents (“Service Providers”) that provide assistance to our business and the operation and maintenance of the Sites. Service Providers with whom we share such information generally are bound by confidentiality obligations, and, unless we tell you differently, our Service Providers do not have any right to use the information we share with them beyond the scope and duration of what is necessary to assist us;
- To affiliated legal entities and among college operational units and departments for purposes and uses that are consistent with this policy.
- To a buyer or other successor of The College or any of our affiliates in the event of an acquisition, merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of The College’s or any of our affiliates’ equity or assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceedings, in which Personal Information relating to users of the Site which is held by The College is among the assets transferred;
- For any other purpose disclosed by us when you provide the information; and
- For any purpose with your consent. For example, we may share your information with third parties to whom you explicitly ask us to send your information. If you ask us to release information that we have about your Account, we will do so if it is reasonable and not unduly burdensome.
- To respond to legal requirements, including complying with any court order, law or legal process and responding to any government or regulatory request, including responding to law enforcement or other government officials in response to a verified request relating to a criminal investigation or alleged illegal activity;
- To enforce or apply our policies and agreements;
- To detect, prevent or otherwise address fraud, security, trust and safety or technical issues;
- To respond to user support requests; or
- to protect the rights, property, health or safety of The College, our users, any third parties or the public in general.
How We Protect Your Personal Information
The College implements commercially reasonable technical and organizational security controls to protect your personal data against theft, loss or misuse. Your data will be stored in a secure operating environment that is not accessible without authorization. The College applies mitigation measures following periodic risk assessments to ensure an adequate level of protection of your personal data.
Please note for business continuity and disaster recovery purposes, The College may store data in a location outside the jurisdiction(s) in which we normally operate. In such scenarios, we will implement all commercially reasonable measures to protect your personal data against theft, loss or misuse.
The College has put in place appropriate physical, technical, and administrative procedures to safeguard and secure the information from loss, misuse, unauthorized access, disclosure, alteration or destruction. The College cannot guarantee the security of information on or transmitted via the internet.
Children’s Online Privacy Protection
Our Sites are not intended for children under 13 years of age, and we do not knowingly collect personal information from children under 13. No one under age 13 may provide any information to the Sites, including, for example, a name, telephone number or email address. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. Further, your Account may be terminated without warning if we believe that you are under 13 years of age. If you believe we might have any information from or about a child under 13 years of age, please contact us at this link: https://theamericancollege.edu/contact.
Data Retention & Privacy Requests
As an educational institution, The College has certain legal obligations to maintain some data. We also believe in maintaining a lifelong relationship with our College community members. As such, unless we are otherwise required by applicable law, or your request that we do so, we typically will maintain a record for you.
Opt-out and Preferences
The College offers students and alumni several ways to manage their communication preferences for emails and texts. There are opt-out links within each of our email correspondence and you can also login to The College’ Learning HUB to update your individual contact preferences in your profile.
Data Privacy Requests
If opt-out and preferences do not satisfy your concerns, please direct additional privacy related inquiries to:
- Online Requests: https://theamericancollege.edu/contact
- By mail at: Registrar’s Office; The American College of Financial Services, 630 Allendale Road, Suite 400, King of Prussia, PA, 19406
Last Updated: August 18, 2023