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:
- on our All Campus Platform and content contained therein; and
- in e-mail, text, and other electronic messages between you and this All Campus Platform.
It does not apply to information collected by:
- us offline or through any other means except in relation to us helping you populate any field on our All Campus Platform.
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:
- by which you may be personally identified, such as name, postal address, e-mail address, telephone number, or any other identifier including potential information about and/or from third parties, (note: this information may be collected online or offline) (“personal information”);
- that is about you but individually does not identify you, which we may pair with your personal information, such as your location or metropolitan statistical area (MSA); and/or
- about your internet connection, the equipment you use to access our All Campus Platform and usage details.
We may collect this information:
- directly from you when you provide it to us, and/or
- automatically as you navigate through the site. (Information collected automatically may include usage details, IP addresses and information collected through cookies, web beacons and other tracking technologies.)
Depending to the extent you utilize the All Campus Platform, we also may collect information for third parties including but not exclusively:
- information from you or those acting on your behalf, for the purposes of providing it to the University in order for the University to make decisions regarding admission (This may include your: transcripts from other educational institutions; personal information ((name, address, phone number, email addresses)); standardized test and/or competency scores; honors, awards or affiliation; personal information or references; and resume((s)). It also may include identifying information of third parties for references.);
- information about you to third parties that serve support functions for us or the University; and/or
- data about you for audit, technical support or other legal functions, to any affiliate or subsidiary and any assignee.
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 that you provide by filling in forms provided on the All Campus Platform. (This includes information provided at the time of registering to use the All Campus Platform and/or posting information or material or requesting further services. We may also ask for this information when we assist in repairing the All Campus Platform);
- records and copies of any correspondence (including e-mail addresses), if you contact us regarding your inputs on the All Campus Platform that we, in our independent judgment, believe should be transmitted to a University and/or its agent to further the goals of your use of the All Compus Platform and/or
- data to third party services providers whose SAAS features or code is embedded in the All Campus Platform to assist in the features and functionality of the All Campus Platform.
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:
- details of your visits to our All Campus Platform, including traffic data, location data, logs, and other communication data and the resources that you access and use on the All Campus Platform; and
- information about your computer and internet connection, including your IP address, operating All Campus Platform and browser type.
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:
- estimate our audience size and usage patterns;
- store information about your preferences, allowing us to customize our All Campus Platform according to your individual interests;
- speed up your searches and ability for us to optimize the All Campus Platform; and/or
- recognize you when you return to our All Campus Platform.
The technologies we use for this automatic data collection may include:
- Flash Cookies. Certain features of our All Campus Platform may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from and on our All Campus Platform. Flash cookies are not managed by the same browser settings as are used for browser cookies.
- Web Beacons. Pages of our All Campus Platform and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, single-pixel gifs, etc.) that permit the Company, for example, to count users who have visited those pages or opened an e-mail and for other related All Campus Platform statistics (for example, recording the popularity of certain All Campus Platform content and verifying All Campus Platform and server integrity).
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:
- to present and provide access to our All Campus Platform and related services to you;
- to provide you with information, products or services including interest based/behavioral advertising or other targeted content on third-party sites;
- to fulfill any other purpose for which you provide it including, but not exclusively, to provide personal data to determine mutual interest in University admission;
- to fulfil legal/regulatory requirements;
- to perform administrative or programming duties and tasks;
- to carry out our obligations with the University;
- to notify you about changes to our All Campus Platform or any products or services we offer or provide though it;
- to allow you to participate in any functionality on our All Campus Platform;
- in any other way we may describe when you provide the information;
- to use personal information to invite individuals to take part in market research;
- protecting the security and functionality of the All Campus Platform, including using personal information you provide to investigate any complaints received from you or from others about our All Campus Platform or our products and services;
- to personalize your experience on the All Campus Platform and helping us to better respond to your individual needs;
- to target advertising to groups of individuals with similar interests or characteristics through services offered by third-party service providers, such as Facebook Custom Audiences or other similar business tools;
- to develop new products or services or conducting analyses to enhance current products and services;
- to review the usage and operations of the All Campus Platform and analyzing and improving the All Campus Platform (we continually strive to improve the All Campus Platform based on the information and feedback we receive from you);
- to contacting you for legitimate business purposes; and/or
- where consent is not required by applicable law for direct marketing purposes;
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:
- Tracking Technologies and Advertising. You can set whichever browser you are using browser to refuse all or some browser cookies, or to alert you when cookies are being sent. See e.g. https://support.google.com/chrome, https://support.apple.com/guide/safari/manage-cookies-and-website-data-sfri11471/mac.;
- Removing Cookies. We are providing an informational link on how to remove any cookies which contains information and instructions for removal in several browsers. https://www.allaboutcookies.org/manage-cookies/clear-cookies-installed.html;
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:
- entirely deregister your account; and/or
- change or edit your email preferences.
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:
- entirely deregister your profile; and/or
- indicate that you do not wish to be called in the future
All Campus Privacy Notice for California Residents
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:
- publicly available information from government records; or
- de-identified or aggregated consumer information.
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:
- the categories of personal information we collected about you;
- the categories of sources for the personal information we collected about you;
- our business or commercial purpose for collecting or selling that personal information;
- the categories of third parties with whom we share that personal information;
- the specific pieces of personal information we collected about you (also called a data portability request); and
- if we sold or disclosed your personal information for a business purpose, two separate lists disclosing sales, identifying the personal information categories that each category of recipient purchased; and disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
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:
- complete the transaction for which we collected the personal information, provide a service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you;
- detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
- debug products to identify and repair errors that impair existing intended functionality;
- exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
- comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.);
- engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent;
- enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
- comply with a legal obligation; and
- make other internal and lawful uses of that information that are compatible with the context in which you provided it.
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:
- provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative; and
- describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
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:
- deny you services;
- charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
- provide you a different level or quality of goods or services; or
- suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
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.
All Campus Privacy Notice for users in the European Union
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:
- Personal identifiers such as name, Social Security number, passport number or similar identifiers;
- Contact data such as postal address and email address;
- Account data such as username;
- Data about the user’s education and working history;
- Special categories of personal data such as data revealing racial or ethnic origin and data concerning health (If the All Campus Platform collects such “special” categories of data only if you want to share and/or it its required to be shared by the University. This data usually includes racial or ethnic origin. It generally does not include: political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation. Regardless, we will obtain your express e-signature written consent to collect such Special categories of data as defined in Art. 9 (2)(a) GDPR
- Technical usage data such as IP Address and geolocation;
- Usage data such as browsing history, information on interaction with website;
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:
- you have given your express consent to this pursuant to Art. 6 (1)(a) GDPR;
- disclosure is necessary pursuant to Art. 6 (1)(f) GDPR in order to assert, exercise or defend legal claims and there is no reason to assume that there is an overriding legitimate interest in not disclosing the data;
- we are legally obliged to do so under Art. 6 (1)(c) GDPR; or
- if this is permitted by law and is required under Art. 6 (1)(b) GDPR for the processing of contractual relationships with you or for taking steps at your request prior to entering into a contract.
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:
- your personal data is no longer needed for the purposes for which it was collected;
- the legal basis for the processing was solely your consent and you have withdrawn this;
- you have objected to processing for advertising purposes;
- you have objected to processing, citing the legal basis of the balancing of interests for personal reasons, and we cannot prove that there are overriding legitimate reasons for a processing;
- your personal data has been unlawfully processed; or
- your personal data must be erased in order to comply with legal requirements.
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:
- the accuracy of your personal data is disputed by you, in which case we will restrict the processing until we have had the opportunity to verify its accuracy;
- the processing is not lawful, and you request a restriction of use instead of erasure (see previous section);
- we no longer require your personal data for the purposes of processing, but you need it to establish, exercise or defend your legal claims;
- you have objected for personal reasons; in which case we will restrict the processing until it is established whether your interests prevail.
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/board/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.