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GLOBAL ALUMNI US PRIVACY NOTICE

This policy is effective as of October 14, 2020

 

 

INTRODUCTION

 

Global Alumni (“we”, “our”, and “us”) takes your privacy and the security of your information very seriously, and we encourage you to read this privacy notice (“Notice”) carefully to understand how we collect and handle information that you share with us.  This Notice describes the type of information we collect from you and the steps we take to protect that information.  “Personal Information” as used in this Notice means information that can be used to identify you, directly or indirectly, alone or together with other information.

 

 

SCOPE

 

Global Alumni is an EdTech company dedicated to assisting the world’s best universities to expand their programs and improve the quality of continuing and executive education with cutting-edge technologies and a state-of-the-art platform.

 

This Notice outlines how we collect and use information in the following two distinct contexts:

 

  1. Our Site: We collect certain information through use of our websites located at globalalumni.org and www.pablorivas.es (“Site”).

 

  1. Our Services: We collect certain information as a service provider to, and on behalf of, certain continuing and executive education colleges and universities (“Services”).

 

This Notice applies only to information we collect through our Site and Services. Our Site and Services may contain links to third party sites that are not owned or controlled by Global Alumni, such as links to websites operated by colleges and universities that we work with. Please be aware that we are not responsible for the privacy practices of such other sites. We encourage you to be aware when you leave our Site and Services and to read the privacy notices of each and every website that collects your Personal Information.

 

 

INFORMATION WE COLLECT

 

Site

Like most websites, when you visit our Site, certain information, which may include Personal Information, is automatically collected from you or your device, including the following:

 

  • Personal Information: We may collect your contact information, such as your name, email address, and phone number.

 

  • Analytics Information: We use certain analytics partners in connection with our Site as further described below in the “Third Party Ad Partners, Cookies, Analytics And Other Tracking Mechanisms” section below.
  • Website Visit Information: As is true with most websites, we also collect certain types of non-personal information whenever you visit our website.  By “Site Visit Information” we mean information that does not directly identify you personally, such as device information, unique identifiers, and browser information.
  • Aggregate Information: Aggregate Information is information that does not identify you in any way.  Aggregate Information may be collected when you visit our Site, independent of any information you voluntarily enter.  Additionally, we may use one or more processes to de-identify information that contains Personal Information, such that only Aggregate Information remains.  We may collect, use, store, and transfer Aggregate Information without restriction.

 

 

Services

 

We collect information, including Personal Information, in connection with the Services that we perform for certain continuing and executive education colleges and universities.  We are a “processor” in this context, and collect this information solely as a service provider to, and on behalf of, those colleges and universities, and not for our own purposes.  We collect information about students, prospective students, faculty, and staff, and any other third parties as directed by the colleges and universities that we provide our Services to.  We may collect information directly from you, through our platform, our registration forms, websites that we operate on behalf of colleges and universities, and from colleges and universities that engage our Services. This information may include:

  • Contact Information: Such as first and last name; email address; telephone number; and physical mailing address.
  • Demographic and Education Information: Such as gender; employment information including professional experience, area/department and job function, seniority, job title, years of professional experience, company, company size, industry, and if your company is sponsoring
  • Payment Information: We partner with Paypal, Flywire, and Amazon Pay to process credit and debit card transactions in connection with our Services.  Your full credit or debit card numbers are never shared with us, and at no point in any transaction do we have access to that information.  You should consult Paypal’s, Flywire’s, and Amazon Pay’s privacy Policies and terms of use to learn more about how they process credit and debit card transactions for us by visiting:
  • Academic information: Such as education level, academic institution, and degree(s) obtained.
  • Other: We may record conversations that you have with our sales and customer service teams for training and quality improvement purposes.
  • Analytics Information: We use certain analytics partners in connection with websites we use in connection with our Services, as further described below in the “Cookies and Other Tracking Mechanisms” section below.
  • Website Visit Information: IP Address
  • Aggregate Information: Aggregate Information is information that does not identify you in any way. Aggregate Information may be collected when you use our Services, independent of any information you voluntarily enter.  Additionally, we may use one or more processes to de-identify information that contains Personal Information, such that only Aggregate Information remains.  We may collect, use, store, and transfer Aggregate Information without restriction.

 

 

HOW WE USE AND SHARE YOUR INFORMATION

 

We will only use your Personal information for the purposes for which we have collected it, or the purposes set forth in this Notice, unless you consent otherwise. We will not disclose your Personal Information to third parties other than as described in this Notice, unless you give us consent to do so. We do not sell or lease your information to third-parties.

 

Site

We use your information, including Personal Information, collected through our Site to help us operate our website, operate our business, perform internal analyses, perform internal audits, and provide other services, including advertisements, ad serving, and technical support.  We also use this information to suggest products and promotions to you, develop new products or initiatives, better understand how our Site is used, and to send you updates about our company, our events, and our initiatives.

 

We may share your information, including Personal Information, with our service providers to assist us with operating our website, selling our products and services, our advertising, and our technical support.

 

Services

We use information, including Personal Information, collected through our Services to market and sell continuing and executive education programs on behalf of continuing and executive education colleges and universities that engage our Services.  We also assist continuing and executive education colleges and universities with administration and delivery of their programs, including student enrolment and course delivery.  This may also include ensuring that students and prospective students are not on the specifically designated nationals (SDN) list or from a sanctioned region.

 

By providing your contact information, including your email address and telephone number, you understand that we may use such information to contact you about continuing and executive education programs, including SMS text and through WhatsApp messaging.  We may also use your Personal Information to facilitate your enrollment and participation in continuing and executive education programs.

 

We share information, including Personal Information, we collect on behalf of continuing and executive education colleges and universities with the applicable college or university in which you are a student, are a prospective student, or otherwise have expressed interest in.  We do not share information with colleges or universities other than the specific college or university of which you are a student, are a prospective student, or otherwise have expressed interest in.  We do not share your information with any other third parties except as specified in this Notice.

 

Legal and Law Enforcement Requests

We may disclose, at our sole discretion, your information, including Personal Information, as required by law, or to comply with a governmental or legally binding request—such as a subpoena, warrant, or similar legally enforceable request for information.

 

Other Uses and Disclosures

We may also share and disclose your information, including Personal Information: (i) to investigate a possible crime, such as fraud or identity theft; (ii) in connection with the sale, purchase, merger, reorganization, liquidation or dissolution of Global Alumni; (iii) when we believe it is necessary to protect the rights, property, or safety of Global Alumni or other persons; or (iv) as otherwise required or permitted by law, including any contractual obligations of Global Alumni.

 

 

THIRD PARTY AD PARTNERS, COOKIES, ANALYTICS, AND OTHER TRACKING MECHANISMS

 

Cookies

Like most websites, our Site and other websites we use to perform our Services use Cookies, which are small files that are stored on your computer (or other device) by your web browser. A cookie allows our Site to recognize whether you have visited the Site before and may store user preferences and information. If you are concerned about having cookies on your computer, you can set your browser to refuse all cookies or to indicate when a cookie is being set, allowing you to decide whether to accept it. You can also delete cookies from your computer. However, if you choose to block or delete cookies, certain features of the Services may not operate correctly.  For more information about the cookies that we use, please visit our cookie policy.

 

Like many other websites, our Site does not respond to “do not track” browser headers.

 

Analytics

We partner with certain analytics providers such as to provide insight into our Site and other websites we use to perform our Services, and to improve the relevance of advertisements you receive.  Our analytics partners, and links to their terms, are listed below.

 

 

Analytics Partners and Third Party Cookies:

 

 

 

MESSAGING TERMS AND CONDITIONS

 

When you agree to be contacted by us through text message, WhatsApp message, social media or other electronic messages, we may use such messaging means to communicate with you unless you opt-out or revoke your consent. By checking the applicable box, and submitting your phone number or similar messaging contact information, you explicitly agree that we may communicate with you as outlined above.

 

You may opt-out or revoke consent to receive text message or WhatsApp messages at any time. To revoke consent to receive text message or WhatsApp communication from us, you must reply “STOP” to any message generated by us. To revoke consent to receive other communications please send an email to the following address optout@globalalumni.org.

 

 

SECURITY

 

We use commercially reasonable physical, electronic, and procedural safeguards to protect your information against loss or unauthorized access, use, modification, or deletion. However, no security program is 100% secure, and thus we cannot guarantee the absolute security of your Personal or Other Information.

 

 

DATA RETENTION

 

We retain information for as long as reasonably necessary to operate our Site, to deliver our Services to you, to fulfill the purposes described in this Notice, or as required by law. We reserve the right to retain any information as required under applicable law.

 

YOUR CHOICES AND ACCESS TO INFORMATION

 

Site

With respect to Personal Information collected through out Site, you may access, amend, and/or request deletion of certain Personal Information to the extent permitted under applicable law. To make such requests and/or inquire about such rights, please send us an email at

mydata@globalalumni.org.

 

 

For your protection, we may need to verify your identity before implementing your request. We will attempt to comply with any reasonable requests for accessing, amending, or deleting your information.

 

Services

With respect to Personal Information collected through our Services, if you are a student or prospective student of a continuing or executive education college or university that we provide our Services to, please contact the applicable college or university with requests related to your Personal Information.  We will pass any requests along to the applicable college or university, but cannot respond to your requests directly.  We do not control or own Personal Information of students or prospective students, and only process such Personal Information on behalf of the applicable college or university. To the extent instructed by a college or university and in accordance with applicable law, we will reasonably assist a college or university to comply with a student’s or prospective student’s request by providing relevant information and support to the particular college or university to enable it to comply with the request.

 

 

CHILDREN’S PRIVACY

 

We do not knowingly collect Personal Information from children under the age of 18 and do not target our Site or Services to children under 18. If you are under 18, please do not use the Site or Services. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce this prohibition. If you have reason to believe that a child under the age of 18 has provided Personal Information to us, please contact us, and we will endeavor to delete that information from our databases.

 

 

EEA RESIDENTS

 

If you are a resident of the European Economic Area, you have certain rights regarding our use of your Personal Information. Some of these rights, e.g., the right to be forgotten or the right to request that we transfer your Personal Information to another company, will only apply in certain circumstances. Generally, these rights will not be available if there is an outstanding agreement or ongoing business relationship between us, if we need that information to continue to provide certain services to you, if we are required by law to keep the information, or if the information is relevant to a legal dispute.

 

Global Alumni is the data controller of Personal Information that you provide to us through our Site, but not if you are a student or prospective student of a continuing or executive education college or university that we provide our Services to.  In that context, we are a data processor, and we process Personal Information to fulfill our contractual obligations with continuing and executive education colleges and universities that we provide our Services to.  We may also process Personal Information on other bases permitted by the GDPR and applicable laws.

 

We have listed the rights you have over your Personal Information and how you can use them below. These rights are subject to restrictions under European data protection law and, subject to the exemptions in that law, may only apply to certain types of information or processing.

 

 

  • You have the right to access to your Personal Information, to have it corrected if the Personal Information we have is incorrect, to request that we restrict or delete your Personal Information, and to object to our processing of your Personal Information. Your rights may be subject to various limitations under applicable privacy laws. If you wish to exercise any of these rights, or if you have any concerns about our processing of your personal data, please contact us at  mydata@globalalumni.org
  • You have the right to file a complaint concerning our processing of your personal data with your national data protection authority.
  • You have the right to file a complaint with a competent data protection supervisory authority, in particular in the EU Member State where you reside, work or the place of the alleged infringement. You have the right to do so if you consider that the processing of personal data relating to you infringes applicable data protection laws.
  • You also have a right to object to us processing your Personal Information in certain circumstances. You can ask us to stop processing your Personal Information at any time. In certain circumstances, we may not be able to do this or may not be required to do this. For example, if we have an ongoing business relationship, if we required by law to keep it, or if it is relevant to a legal dispute, then we may not stop processing your Personal Information.

 

We have appointed an UE representative. If you wish to contact our UE representative, please send an email to mydata@globalalumni.org

 

 

Students and Prospective Students:  If you are a student or a prospective student of a continuing or executive education college or university that we provide our Services to, please contact the applicable college or university with requests related to your Personal Information.  We are not a “controller” of the Personal Information of students and prospective students, and will pass any requests along to the applicable college or university, but cannot respond to your requests directly.  We do not control or own Personal Information of students or prospective students, and only process such Personal Information on behalf of the applicable college or university. To the extent instructed by a college or university and in accordance with applicable law, we will reasonably assist a college or university to comply with a student’s or prospective student’s requests by providing relevant information and support to the particular college or university to enable it to comply with the request.

 

INFORMATION FOR NEVADA RESIDENTS

 

Nevada residents can opt out of the sale of their Personal Information. We do not sell Personal Information today, and we do not have plans to sell Personal Information in the future. However, Nevada residents have the legal right to opt out of the sale of their Personal Information, even if their information is not currently being sold. You may opt out by emailing a request to optout@globalalumni.org . In your request, please specify that you want to “Opt-out of Sale of Personal Information in Nevada.” Please allow 60 days for a response.

 

 

CHANGES TO THIS NOTICE

 

We may make changes to this Notice from time to time. We will post the revised Notice on our website with an “effective date” that indicates when the revised Notice will take effect. We encourage you to review this page periodically to note any changes.

 

 

QUESTIONS OR COMMENTS

 

If you have any questions or comments regarding our privacy practices or this Notice, please send us an email at mydata@globalalumni.org or contact us by mail at: 7950 NW 53rd St, Miami, FL 33166.

 

 

Your personal data

 

Your Newsletter and Email Subscriptions
You can opt out or unsubscribe to a newsletter or other email list at any time by following the instructions at the end of the newsletters or emails you receive. Please allow five to ten business days for changes to take effect. For some services, member service-related communications are an integral part of such services to which you subscribe and you may continue to receive emails as part of that particular portion of the services unless you cancel your account, even if you opt out of the newsletters or email list. If you have provided more than one email address to us, you may continue to be contacted unless you request to unsubscribe each email address you have provided.

 

Telephone Communications
Our telephone communications with you may be recorded in accordance with this Policy. By choosing to continue any telephone conversation, you acknowledge and agree to the terms of this Policy. If you do not agree, terminate the telephone conversation immediately and avoid any further telephone communications with Global Alumni.

 

Cookies and Pixel Tags
You may stop or restrict cookies and pixel tags on your computer or purge cookies from your browser by adjusting your web browser preferences. However, if you “turn off,” purge, or disable cookies or pixel tags, although you may still use the services, you may not be able to use all of the features, functions, or services available on the Site. We have also provided another measure of disabling the cookies, you will see a pop up on our website that can enable you to control the cookies tracking.

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