In this Privacy Policy (“Policy”), we describe how Davis College (“we,” “us,” or “our”) collects, uses and discloses personal data that we obtain about visitors to our website https://www.daviscollege.com/ (the “Site”) and the services available through our Site (collectively, the “Services”).
By visiting the Site, or using any of our Services, you agree that your personal data will be handled as described in this Policy. Your use of our Site or Services, and any dispute
over privacy, is subject to this Policy.
The Personal Data We Collect About You
We collect personal data about you directly from you, from third parties, and automatically through your use of our Site or Services.
Personal Data We Collect Directly From You. The personal data we collect from you depends on how you use our Services.
● Students and Prospective Students. If you are a prospective student or request information about our programs, we will collect your name, email address, telephone number, and information about the programs you are interested in.
If you apply to become a student in one of our programs, we will collect your name, contact information, your home address, date of birth, national identification number, your country of residence, nationality, gender, graduation details, test scores, English speaking abilities, information about your work and volunteer experience, your refugee status, and contact information for your parent or guardian.
● Online classes. If you participate in one of our online classes, whether on the Site or through one of our service providers’ online platforms, we will collect information about your online class attendance, such as your login activity, the classes you attend, and your in-class participation, which may include audio and video recordings of you participating in class activities.
● Donors. If you are a donor, we will collect your name, contact information, such as your email address and phone number. Our payment processor will then collect and process your payment information.
If you do not wish to provide us with any personal data which is indicated as mandatory when we collect it (e.g. marked by an asterisk or similar on an online form), we may not be able to communicate with you or provide certain Services or features on the Site to you.
Personal Data We Collect From Other Entities.
We also may collect personal data about you from third party sources.
● Students and Prospective Students. We may collect personal data about you from other educational institutions, including your grades, transcripts, and information about coursework you have attended or completed. We also may collect information about you from your academic advisors, mentors, or other persons you designate to provide recommendations or letters of support.
● Donors. We may collect personal data about donors and prospective donors from our payment processor and other parties to assist us with our fundraising efforts. This may include profiles and reports based on publicly available information and information our donors self-report to these parties.
Personal Data We Collect Automatically.
We automatically collect personal data about your use of our Site through cookies, web beacons, and other technologies. To the extent permitted by applicable law, we combine this information with other information we collect about you, including your personal data. Please see the section “Cookies and Other Tracking Mechanisms” below for more information
● your browser type and operating system;
● web pages you view on the Site; links you click on the Site; your device’s IP address;
● the length of time you visit our Site and or use our Services;
● the referring URL, or the webpage that led you to our Site.
How We Use Your Personal Information
We use your information, including your personal data, for the following purposes (and directly related purposes):
● Service Provisioning:
● To provide our Site and Services to you.
● To evaluate prospective students for enrollment with Davis College.
● To communicate with you about your use of our Site and Services, to respond to your inquiries, and for other student- and donor-service purposes.
● To tailor the content and information that we may send or display to you, to provide personalized help and instructions, and to otherwise personalize your experiences while using the Services.
● Marketing:
● To send marketing emails, text and WhatsApp messages and phone calls, in accordance with applicable law and with your consent, about: (1) our fundraising campaigns and events, (2) newsletters and updates about Davis College and our events; (3) our new courses and class offerings; and (4) products and services of our affiliated organizations or organizations we believe you may be interested in.
● Advertising:
● To assist us in determining relevant advertising content and media.
● To evaluate the success of our advertising campaigns (including our online targeted advertising and offline promotional campaigns).
● To engage in online advertising. Please see also Ad Networks section discussed below.
● Site and Services Improvement/Research:
● To better understand how users access and use our Site and Services, both on an aggregated and individualized basis. For example, we will evaluate which features of our Site are more (or least) used by visitors, and we will use this information to improve our Site.
● To administer surveys and questionnaires, such as for market and donor research or user satisfaction purposes.
● Legal Purposes:
● To comply with legal obligations, as part of our general business operations, and for other business administration purposes.
● Where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person or violations of this Policy or other terms or agreements you have entered into with us.
We will obtain your consent if we wish to use your personal data for purposes other than those (or those directly related to those) stated in this Policy.
How We Share Your Personal Data
We may share your personal data, as follows:
● Service Providers. We may disclose your personal data to service providers, contractors or agents who perform functions on our behalf. These service providers include, for example, providers of the platforms upon which our online classes are hosted, our payment processor, organizations who provide our enrollment application forms, and our website hosting provider.
We may also disclose your personal data in the following circumstances:
● Business Transfers. If: (i) we or our affiliates are or may be acquired by, merged with, or invested in by another organization, or (ii) if any of our assets are or may be transferred to another organization, whether as part of a bankruptcy or insolvency proceeding or otherwise, we may transfer your personal data we to the other organization. As part of the business transfer process, we may share certain of your personal data with lenders, auditors, and third party advisors, including (but not limited to) attorneys and consultants.
● In Response to Legal Process. We may disclose your personal data to comply with the law, a judicial proceeding, court order, or other legal process, including without limitation in response to a subpoena, in each case anywhere in the world.
● To Protect Us and Others. We may disclose your personal data when we believe it is appropriate to do so to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our agreements or this Policy, or as evidence in litigation in which we are involved.
● Aggregate and De-Identified Data. We may share aggregate, anonymized, or de-identified information about users with third parties for marketing, advertising, research or similar purposes.
International Transfers
In certain cases, your personal data may be shared, transferred or stored in jurisdictions outside of the jurisdiction in which you reside or are located (including in the United States and Hong Kong SAR). We may do this where we are satisfied that adequate levels of protection are in place to protect the integrity and security of your Personal Data, and/or adequate security measures are adopted, in compliance with applicable privacy and data protection laws.
Our Use of Cookies and Other Tracking Mechanisms
We and our service providers use cookies and other tracking mechanisms to track information about your use of our Site or Services. We may combine this information with other personal data we collect from you (and our service providers may do so on our behalf).
Cookies. Cookies are alphanumeric identifiers that we transfer to your device’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Site and Services, while others are used to enable a faster log-in process or to allow us to track your activities at our Site and Service.
Disabling Cookies. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Site and Services who disable cookies will be able to browse certain areas of the Site, but some features may not function.
Clear GIFs, pixel tags and other technologies. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your device’s hard drive, clear GIFs are embedded invisibly on web pages. We may use clear GIFs (also known as web beacons, web bugs or pixel tags), in connection with our Site and Services to, among other things, track the activities of Site visitors and Services users, help us manage content, and compile statistics about Site and Services usage. We and our service providers also use clear GIFs in HTML emails to our students and donors, to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.
Third Party Analytics. We use automated devices and applications, such as Google Analytics, to evaluate usage of our Site and Services. We also may use other analytic means to evaluate our Site and Services. We use these tools to help us improve our Site’s and Services’ performance and user experiences. These entities may use cookies and other tracking technologies, such as web beacons or local storage objects (LSOs), to perform their services. To learn more about Google’s privacy practices, please review the Google Privacy Policy at https://www.google.com/policies/privacy/. You can also download the Google Analytics Opt-out Browser Add-on to prevent their data from being used by Google Analytics at https://tools.google.com/dlpage/gaoptout.
Do-Not-Track. Currently, our systems do not recognize browser “do-not-track” requests.
Ad Networks
We use network advertisers to serve advertisements on non-affiliated websites or other media (e.g., social networking platforms). This enables us and these network advertisers to target advertisements to you for products and services in which you might be interested. Ad network providers, advertisers, sponsors and/or traffic measurement services may use cookies, JavaScript, web beacons (including clear GIFs), LSOs and other tracking technologies to measure the effectiveness of their ads and to personalize advertising content to you. These cookies and other technologies are governed by each entity's specific privacy policy, not this one. We may provide these advertisers with your personal data.
We may disclose certain personal data (such as your email address) to Facebook Custom Audiences (for more information on Facebook Custom Audience go here or to opt-out, go to the Facebook ad preferences page)—so that we can better target ads and content to you and others with similar interests on third parties’ websites or media (“Custom Audiences”). We may also work with other ad networks and marketing platforms that enable us and other participants to target ads to Custom Audiences submitted by us and others. You may also control how Facebook and other third parties display certain ads to you, as explained further in their respective privacy policies or by using the opt-outs described below.
Users may opt out of many ad networks. For example, visitors in the United States may go to the Digital Advertising Alliance ("DAA") Consumer Choice Page for information about opting out of interest-based advertising and their choices regarding having information used by DAA companies. You may also go to the Network Advertising Initiative ("NAI") Consumer Opt-Out Page for information about opting out of interest-based advertising and their choices regarding having information used by NAI members.
Opting out from one or more companies listed on the DAA Consumer Choice Page or the NAI Consumer Opt-Out Page will opt you out from those companies' delivery of interest-based content or ads to you, but it does not mean you will no longer receive any advertising through our Site, Services, or on other websites. You may continue to receive advertisements, for example, based on the particular website that you are viewing (i.e., contextually based ads). Also, if your browsers are configured to reject cookies when you opt out on the DAA or NAI websites, your opt out may not be effective. Additional information is available on the DAA's website at www.aboutads.info or the NAI's website at www.networkadvertising.org.
Third-Party Links
Our Site and Services may contain links to third-party websites. Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those third party websites. We are not responsible for the personal data practices of such third party websites. We strongly recommend you to review the privacy policies of any third party before you provide any personal data to them.
Security and Retention of My Personal Data
We have implemented reasonable steps to protect the personal data we collect from unauthorized or accidental access, processing, erasure, loss or use. Please be aware that despite our efforts, no data security measures can guarantee security.
You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.
Your personal data will not be retained for longer than is necessary to fulfil the purposes set forth in this Policy or directly related purposes, or for such longer period as may be permitted or required by law.
Children’s Data
Our Services are not designed for minors (that is, individuals aged under 13 if in the United States, or individuals aged under 18 if elsewhere). If we discover that a minor has provided us with personal data, we will delete such data from our systems.
Your Rights and Contact Us
You may have the right under applicable law to request access to, and/or correction of, your personal data. If you wish to exercise these rights, or have questions about the privacy aspects of our Services or would like to make a complaint, please contact us at info@daviscollege.com.
What Choices Do I Have Regarding Marketing Communications?
We may send periodic promotional marketing communications to you in accordance with applicable law or, where required by applicable law, with your consent. You may opt-out of promotional communications by following the opt-out instructions contained in the communications or by contacting us info@daviscollege.com. If you opt-out of receiving promotional emails, we may still send you communications about your account or any services you have requested or received from us where we are permitted to do so by applicable law.
Changes to this Policy
This Policy is current as of the Effective Date set forth above. We may change this Policy from time to time, so please be sure to check back periodically. We will post any changes to this Policy on our Site. If we make any changes to this Policy that materially affect our practices with regard to the personal data we have previously collected from you, we will endeavor to provide you with notice in advance of such change by highlighting the change on our Site, and will obtain your consent to changes to this Policy where required to do so by applicable law.
By accepting the Terms and Conditions as set out in this Privacy Policy, you confirm that you will be bound by them each and every time you access our Site or otherwise interact with us online. If you do not agree to these Terms and Conditions, you may not access to or otherwise use our Site.