Last Updated: June 15, 2020
- What Personal Information (as defined below) is collected from you on the Sites and Services
- The organization collecting the information
- How the Personal Information is used
- With whom the Personal Information may be shared
- What choices are available to you regarding collection, use and distribution of the Personal Information
- The kind of security procedures that are in place to protect the loss, misuse or alteration of Personal Information under CSI’s control
- How you can correct any inaccuracies in the information.
Information Collection and Use:
When you use the Sites and Services, CSI may collect and use Personal Information about you, as well as Anonymous Information. “Personal Information” information that can be used to identify you (whether alone or in combination) such as your first and last name, email address, zip code/post code, address, phone number, age, credit card information, and date of birth. “Anonymous Information” aggregated information (information about CSI’s users that it renders in such a way that it no longer identifies or references an individual user) and other pseudonimized information which cannot be used to identify you. More specifically, when you use the Sites and Services, CSI may collect the following information:
- Information you provide to us voluntarily and directly (online or offline) including when you: respond to an advertisement; communicate directly or indirectly with CSI; participate in a survey or a drawing; request information; apply for admission to CSI; register for classes; order educational or other products and services; set up a Site profile; use one of CSI’s interactive tools; contact CSI’s offices; or otherwise interact with us online or offline. The exact nature of the Personal Information may vary depending on the type of response or service requested, but could include name, contact details, date of birth, education history, immigration status, financial information, employment status, photos, interests, demographic information, and other information.
- CSI may also obtain Personal Information from its education partners, Service Providers, publicly available sources, and other third parties, which may be combined with other Personal Information CSI has collected.For example, CSI may receive Personal Information about you from educational institutions which you have attended; financial institutions (e.g., related to student loans); government entities (e.g., related to education grants); employers (e.g. related to education or career initiatives); third party platforms or accounts that you connect to or integrate with one or more of CSI Services; providers that CSI works with to verify, update, or append data to the information that CSI has otherwise collected about you; third parties that CSI works with to identify prospective students or other individuals who may be interested in CSI’s Services; and other third parties they support or that work with CSI to provide or make available CSI’s Services.
CSI may use Personal Information collected by and through your use of the Sites and Services for the following purposes:
- To support CSI’s general business operations, including, without limitation, to review and administer applications, enrollment, registration, financial services, and other student services;
- To provide you with information and offerings relating to CSI, including via your email address, with updates, newsletters, and offers;
- To respond to your inquiries and fulfill your requests (e.g., send newsletters or provide you with information about the Site);
- To communicate with you about your access to and use of the Sites and Services, provide technical support and other customer service and support purposes;
- To provide, improve, test, monitor, and develop the Sites and Services, including, without limitation, to provide you access to the Site, and identify usage trends;
- To administer, monitor, analyze, develop, diagnose, fix, and test Services and Sites;
- To curate offerings, information, programs, and Services to you from CSI or its partners, affiliates, and other third parties that may be of interest to you;
- To serve you advertisements of CSI’s Sites and Services on the Sites and on third party sites, including by using retargeting, remarketing, or similar audiences tools provided by Service Providers;
We also may de-identify and/or aggregate information to create aggregate or de-identified data sets and reports in order to assess, improve, and develop CSI’s business, products, and services; prepare benchmarking reports; and for other research and analytics purposes.
CSI will not sell, share, or rent this information to others in ways different from what is disclosed in this statement, or otherwise without your consent. Notwithstanding, CSI may disclose your Personal Information or Anonymous Information to third parties as follows:
- To its Service Providers to (i) provide the services necessary for them to perform tasks on CSI’s behalf, including, without limitation, hosting, data analysis, student service, process transactions, email delivery, and other similar tasks; or (ii) provide advertising, campaign measurement, online and mobile analytics, and related services. These Service Providers access and use of such Personal Information and Anonymous Information to allow CSI better reach individuals with relevant ads and measure CSI’s ad campaigns, or to better understand how individuals interact with CSI’s Services and online services over time and across devices;
- To its education partners for certain education and career initiatives or who may be doing academic or other institutional research;
- To courts, law enforcement agencies, and governmental authorities (i) to comply with applicable law, including laws outside your country of residence; (ii) to comply with legal process; (iii) to respond to requests from public or government authorities, including public or government authorities outside your country of residence; (iv) to enforce the Terms; (v) to protect CSI’s operations; (vi) to protect CSI’s rights, privacy, safety or property, or that of you or others; or (vii) to allow CSI to pursue available remedies or limit the damages that CSI may sustain; and
In connection with CSI’s Site and Services, it utilizes “cookies”, web beacons and other tracking technologies and may also permit third parties to do so. A “cookie” is a small computer file that is sent to your computer when you visit a website. When you visit the website again, the cookie allows that site to recognize your browser. Cookies may store user preferences and other information.
Web beacons are tiny and/or invisible graphics with a unique identifier, similar in function to cookies, that CSI and its third-party publishers place on a site, the proxy site and other publishers’ locations that host or may host your ads. When users access these pages, web beacons generate a generic notice of that visit. They usually work in conjunction with cookies, registering when a particular computer visits a particular page. If a user turns off cookies, the web beacon will simply detect an anonymous website visit.
A pixel tag is a type of technology placed on a website or within the body of an email for the purpose of tracking activity on websites, or when emails are opened or accessed, and is often used in combination with cookies.
An Internet Protocol (IP) address is a number that is automatically assigned to your device from which you are accessing the Site by your Internet Service Provider (ISP), and is identified and logged automatically in the server log files whenever you visit the Sites, along with the time of the visit and the activity on the Sites, browser type and operating system, device information, device event information, and the page you’ve viewed or engaged with before or after using the Site. CSI and its Service Providers use IP addresses for purposes such as calculating Site usage levels, helping diagnose server problems, administering the Sites and determining your approximate geographic location. If you use any location-enabled products or services, you may be sending CSI location information (e.g. IP address). When you use a location-enabled service, CSI may collect and process information about your precise geographical location, such as GPS signals sent by a mobile device. CSI and its Service Providers and partners may use your device’s physical location to provide you with personalized location-based services, content and advertisements. In some instances, you may be permitted to allow or deny such uses of your device’s location, but if you choose to deny such uses, CSI may not be able to provide you with the applicable personalized services and content.
Cookies and the other similar tools listed above are useful because they allow a website to recognize a user’s device. Cookies allow website visitors to navigate between pages efficiently, the website to remember preferences, and CSI to generally improve the user experience. Separately and in conjunction with web beacons from CSI and its Service Providers, they can also be used by CSI and its Service Providers to tailor advertising to the consumer’s interests through tracking of browsing across websites, report about the effectiveness of that advertising, and determine which consumers to target marketing products and services. Cookies may be disabled by following the instructions for specific browsers or using certain opt-out mechanisms, some of which are outlined below. However, some of CSI’s Services and other website features or services may lose functionality if cookies are disabled.
When users submit sensitive information via the web site, your information is protected both online and offline. CSI takes the following precautions to protect its users’ Personal Information:
- CSI uses commercially suitable physical, electronic, and managerial procedures to safeguard and secure the information it collects on the Site. These procedures include, but are not limited to, firewalls, encryption, intrusion detection, and Site monitoring.
- Certain users’ Personal Information is stored in restricted areas of CSI’s offices. Only employees who need the Personal Information to perform a specific job (for example, a CSI representative) are granted access thereto. All employees are kept up-to-date on CSI’s security and privacy practices.
Notwithstanding the above, no data protection procedures are entirely infallible. As a result, while CSI strives to protect your Personal Information, CSI cannot guarantee that it will be 100% secure. Your transmission of your Personal Information is done entirely at your own risk. If you have any questions about the security of CSI’s Sites, please contact us at the below address, email, or phone number.
The Site is hosted and operated in the United States (“US”) and elsewhere in the world. By using the Site, you are consenting to the transfer of your personal information to the US. If you are accessing the Site from outside the US, please be advised that US law may not offer the same privacy protections as the law of your jurisdiction.
Opting Out: You may opt out of certain collection practices, including, without limitation, in accordance with the following:
- To opt out of notifications on the Site(s), newsletters, and other products or Services, please follow the directions included on the relevant page. For example, to opt out of CSI’s newsletter, please indicate your notifications preferences at the bottom of the relevant email.
- To opt out of Google Analytics, you may install the Google Analytics Opt-Out Browser Add-On found at https://tools.google.com/dlpage/gaoptout. To opt out of Google Analytics for display advertising or customize Google display network ads, you can visit the Google Ads Settings page found at https://adssettings.google.com/authenticated;
- To opt out of Microsoft Advertising’s behavioral advertising practices, you may adjust your preferences at https://account.microsoft.com/privacy/ad-settings/signedout?ru=https:%2F%2Faccount.microsoft.com%2Fprivacy%2Fad-settings;
- To opt out of ReachLocal’s Capture Code and other similar tracking tools, you may adjust your preferences at https://www.reachlocal.com/us/en/legal/opt-out-preferences;
- If you use certain social media accounts, including, without limitation, Facebook, and you do not wish for such social media platform to collect certain data relating to you via our Sites and Services, we recommend you (i) hide social media platform plug-ins using an ad blocker, (ii) always log off completely from the social media platform before visiting other websites, and delete related cookies, and (iii) where the option is available via the social media platform, disable the advertising services and networks operated by that platform. Please check the social media platform’s relevant policies for more information.
- If your device stores Flash LSOs, and if you do not want Flash LSOs stored on your device through which you access the Site, you can adjust the settings of your Flash player to block Flash LSO storage using the tools contained using the Website Storage Settings Panel. You can also control Flash LSOs by going to the Global Storage Settings Panel and following the instructions (which may include instructions that explain, for example, how to delete existing Flash LSOs (referred to as “information” on the Macromedia site), how to prevent Flash LSOs from being placed on your device without you being asked, and (for Flash Player 8 and later) how to block Flash LSOs that are not being delivered by the operator of the page you are on at the time). Please note that setting the Flash Player to restrict or limit acceptance of Flash LSOs may reduce or impede the functionality of some Flash applications, including, potentially, Flash applications used in connection with the Site. CSI expects Service Providers and technology suppliers to honor any decision by you to restrict or limit Flash LSOs, but cannot guarantee that they will do so.
- On your mobile device, enable the “Limit Ad Tracking” setting in your iOS phone’s settings, or the setting to “Opt out of Ads Personalization” in your Android phone’s settings. To opt-out of location tracking when using the Site, you can use the settings of your device. You can disable mobile analytics and bug reporting through these same settings as well. For more information about analytics and advertising cookies and how you can opt out, you can visit the Network Advertising Initiative’s opt-out page found at http://optout.networkadvertising.org/?c=1, the Digital Advertising Alliance’s opt-out page found at http://optout.aboutads.info/?c=2&lang=EN, or EDAA’s Your Online Choices page found at http://www.youronlinechoices.com/.
Privacy Rights by Jurisdiction: Certain privacy laws require CSI to tell you about categories of Personal Information that CSI discloses for business purposes, as well as categories it “sells”. Other than as outlined above, CSI does not sell or disclose your Personal Information to third parties without your prior written notice.
Notification of Changes: