onlinecybersecurity.seas.gwu.edu is operated by All Campus, LLC (“All Campus” or “Company”). The All Campus Platform is published and maintained by All Campus.
All Campus recognizes the importance of protecting the privacy of Personal Information you may provide All Campus. If you have any questions, concerns or complaints involving our use or disclosure of your personal information, please contact us at email@example.com.
This policy applies to information we collect:
It does not apply to information collected by:
We collect this information when you choose to provide it to us. Please use caution when disclosing personal information including metadata provided by you intentionally or otherwise while entering information into All Campus Platform through any of your technological devices. We also provide methods for you to opt out of receiving additional emails and or related phone calls generated through your use of the All Campus Platform (see Your Ability to Opt Out of Further All Campus Communication section below).
Children Under the Age of 13.
The All Campus Platform is offered and available only to users who are 16 years of age or older. Accordingly, our All Campus content, including that on the interrelated All Campus Platform is not under any circumstances intended for children under 13 years of age. No one under age 13 may provide any information to or on the All Campus Platform. We do not knowingly collect personal information from children under 13. If you are under 16 and especially under 13, please immediately exit this All Campus Platform. 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. If you believe we might have any information from or about a child under 13, please contact our legal department at firstname.lastname@example.org.
Information We May Collect About You on our All Campus Platform and How We Collect It.
If you access our All Campus Platform:
We will collect several types of information about users of our All Campus Platform, including information:
We may collect this information:
Depending to the extent you utilize the All Campus Platform, we also may collect information for third parties including but not exclusively:
Depending to the extent you utilize the All Campus Platform, we also may collect information from third parties utilizing their platform and technologies. For example, we may ask for and/or you may voluntarily provide SAAS/online surveys regarding your experience with the All Campus Platform and/or the University.
Information You Provide to Third Parties on our All Campus Platform.
The information that may be provided to third parties through our All Campus Platform may include:
Information We Collect Through Automatic Data Collection Technologies.
As you navigate through and interact with our All Campus Platform, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including:
The information we collect automatically is statistical data and may include personal information, or we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our All Campus Platform and to deliver a better and more personalized service, including by enabling us to:
The technologies we use for this automatic data collection may include:
We currently do not collect personal information automatically, but we may tie this information to personal information about you that we collect from other sources or you provide to us.
Where We Collect and Store Data.
How We Use Your Information.
We use information that we collect about you or that you provide to us, including any personal information:
Choices About How We Use and Disclose Your Information.
We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:
Your Ability to Opt Out of Further All Campus Communication.
If you no longer wish to receive email communications from All Campus, please email email@example.com requesting to:
You may also use the opt-out mechanism that is contained in any email you receive from the All Campus Platform.
If you wish to not receive telephonic communication on the phone number you provided on the All Campus Platform, you may either inform our phone agent, or you may email us at firstname.lastname@example.org to:
Effective Date: May 31, 2020
Last Reviewed on: May 26, 2020
Information We Collect
The All Campus Platform collects information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“personal information”).
Personal information does not include:
In particular, we have collected the following categories of personal information from our consumers within the last twelve (12) months:
|A. Identifiers.||A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.||YES|
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).|| A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
Some personal information included in this category may overlap with other categories.
|C. Protected classification characteristics under California or federal law.||Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).||YES|
|D. Commercial information.||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||NO|
|E. Biometric information.||Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.||NO|
|F. Internet or other similar network activity.||Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.||YES|
|G. Geolocation data.||Physical location or movements.||YES|
|H. Sensory data.||Audio, electronic, visual, thermal, olfactory, or similar information.||YES|
|I. Professional or employment-related information.||Current or past job history or performance evaluations.||YES|
|J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).||Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.||YES|
|K. Inferences drawn from other personal information.||Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||YES|
We have collected the categories of personal information listed above directly from you. For example, from forms you complete.
Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion), we will disclose to you:
Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights below), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by contacting us in any manner identified in the Contact Information section below.
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
Making a verifiable consumer request does not require you to create an account with us.
We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.
We will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
Changes to Our Privacy Notice
We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Website and update the notice’s effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.
Effective Date: May 31, 2020
Last Reviewed on: May 26, 2020
When this Privacy Notice mentions GDPR Compliance, it refers to
All Campus, LLC
500 West Madison Street
Chicago, IL 60661
Online Submission: click here
as the entity that is responsible for your information under this Privacy Notice (the “Controller”).
Purpose of Data Processing
The All Campus Platform collects ‘personal data’ relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Categories of personal data being processed
Depending on the use of the All Campus Platform, the following categories of personal data may be processed:
All Campus uses the personal data collected from you in connection with the use of our All Campus Platform for a range of different business purposes according to different legal bases of processing. We process your personal data for the purposes described in this Privacy Notice, based on the following legal grounds:
Data processing required to fulfill All Campus’ to provide you with All Campus’ services prior to entering into a contract, is based on Art. 6 (1)(b) GDPR. This includes data processing activities that are necessary for the performance of the All Campus Website and Platform.
All Campus accepts your consent according to Art. 6 (1)(b) GDPR to process your information among other things, to assist the University in collecting data for your interest and possible application into its program(s) as well as to provide you information and application processes to the University and such program(s). You have the right to withdraw your consent at any time. For example, we ask for your consent to provide you with personalized services. Data processing involving special categories of personal data is always based on explicit consent in the sense of Art. 9 (2)(a) and Art. 6 (1)(a) GDPR. Your consent can be withdrawn at any time. For more information regards the withdrawal of a consent please see the section “Exercising your rights”.
All Campus also processes your personal data based on its legitimate interests according to Art. 6(1)(f) GDPR while applying appropriate safeguards that protect your privacy. This means that All Campus may process your personal data for things like detecting or otherwise addressing fraud, abuse, security, or technical issues related to All Campus’ services.
Retention and Deletion
All Campus generally retains personal data only for as long as is necessary to provide our services on the All Campus Platform All Campus deletes personal data pursuant to its Data Deletion Policy including all personal data with the exception of data that we are required to maintain in order to comply with contractual or legal (e.g. under tax or commercial law) retention periods (e.g. invoices).
All Campus may also need to retain some of your personal data even after you have completed the application process if we have a legitimate interest in doing so or if we have to comply with our legal obligations. For instance, All Campus must store some of your personal data for purposes of book-keeping. All Campus has an obligation to do so under statutory duties of documentation which may arise either for us or contractually for the University. The periods stipulated for the storage of documents are up to ten years.
Disclosure of Data
In principal, All Campus will only pass on the personal data we collect if:
In addition, personal data may be disclosed in connection with official requests, court orders and legal proceedings, if this is necessary to pursue or enforce rights.
Part of the data processing described in this Privacy Notice may be carried out by All Campus’ service providers. In addition to the service providers mentioned in this Privacy Notice, this may in particular include data centers that maintain our systems and operate the All Campus Platform. If we pass data on to our service providers, they may use the data exclusively for the fulfilment of their tasks. All Campus has carefully selected and commissioned the service providers. They are contractually bound by All Campus’ instructions, have appropriate technical and organizational measures in place to protect the rights of data subjects, guarantee an appropriate level of data protection and are carefully monitored by us.
If these service providers process your data outside the European Union, this may result in your data being transferred to a country with a lower data protection standard than that of the European Union. In such cases, All Campus ensures that the service providers concerned guarantee an equivalent level of data protection, either by contract or otherwise (e.g. by including Standard Contractual Clauses with the service provider or by ensuring that the service provider is certified according to the EU-US-Privacy Shield).
Exercising your rights
We do our best to give you as much choice as possible regarding the amount of information you provide to us, and the control you have over that information. To assert your rights, please use the information in the “Controller” or “EU-Representative” section. Please make sure that we are able to uniquely identify you.
Your rights of access and rectification
You may request that we confirm whether we process personal data concerning you, and you have a right of access to the personal data of yours which we process. Should your data be inaccurate or incomplete, you may request that it be rectified or completed. If we have passed on your data to third parties, we will inform them about the rectification to the extent required by law.
Your right to erasure
If the legal requirements are met, you can request that we erase your personal data without delay. In particular, this is possible if:
If we have passed on your data to third parties, we will inform them about the erasure to the extent required by law.
Please note that your right to erasure is subject to restrictions. For example, we do not have to, or rather are not allowed to, erase any data that we have to retain further due to legal retention periods. Data which we require for the establishment, exercise or deference of legal claims is also excluded from your right to erasure.
Your right to restriction of processing
If the legal requirements are met, you can request that we restrict processing. In particular, this is possible if:
If there is a right to restriction of processing, we will mark the data concerned in order to ensure that it will only be processed within the narrow limits that apply to such limited data (in particular to defend legal claims or with your consent).
Your right to data portability
You have the right to receive, in a transferable format, personal data that you have provided to us for the performance of the contract or on the basis of your consent. In this case, you can also request that we transfer this data directly to a third party, to the extent that this is technically feasible.
Your right to withdraw your consent
If you have consented to us processing your data, you can withdraw this at any time with effect for the future. This will not affect the lawfulness of the processing of your data before the withdrawal.
Your right to object to direct marketing
You can also object to the processing of your personal data for advertising purposes at any time (“advertising objection”).
Your right to object for personal reasons
You have the right to object to data processing by us for reasons arising from your particular situation, insofar as this is based on the legal basis of a legitimate interest. We will then cease processing your data, unless we can – in accordance with the statutory provisions – prove compelling legitimate reasons for further processing which outweigh your rights.
You have the right to lodge complaints about the data processing activities carried out by All Campus before a competent data protection authority. A list of EU data protection authorities is available at https://edpb.europa.eu/about-edpb/about-edpb/members_en.
All Campus has named a representative in the European Union. This representative can be reached under the following contact details:
Jan Baier, SCHÜRMANN ROSENTHAL DREYER, Partnerschaft von Rechtsanwälten mbB
Registergericht und Sitz: Berlin | PR 1253 B
Am Hamburger Bahnhof 4 | D-10557 Berlin
Fon: +49 (0)30 21300280 | Fax: +49 (0)30 213002849
Changes to Our Privacy Notice
All Campus reserves the right to amend this Privacy Notice at its own discretion and at any time. When All Campus makes changes to this Privacy Notice, All Campus will post the updated notice on the Website and update the notice’s effective date.