Special Notice for Connecticut Residents
This Special Notice for Connecticut Residents supplements the general Privacy Policy and applies only to individuals who are Connecticut residents.
This notice describes how we collect, use, and share your personal data in our capacity as a “Controller” under Connecticut’s Data Protection Act (“CTDPA”) and the rights that you have with respect to your personal data, including sensitive personal data. For purposes of this section, “personal data” and “sensitive data” have the meaning given in the CTDPA and do not include information excluded from the CTDPA’s scope.
The personal data we collect about you will depend upon how you interact with our Sites and the information you voluntarily provide us. Accordingly, we may not collect all of the below information about you. In addition, we may collect information about you from other sources or we may collect and/or use additional types of information after providing notice to you and obtaining your consent to the extent such notice and consent is required by the CTDPA.
To the extent that we collect personal data subject to the CTDPA, that information, our practices, and your rights are described below. Persons with disabilities may obtain this notice in alternative format by emailing us at privacy.universitypartners@kaplan.com or calling (877) 881-7313.
1. What Personal Data Do We Collect, Process and Share?
Consistent with the "Information We Collect" and “How We Use Information” sections in the general privacy policy, the below information provides additional detail about certain information that is linked or reasonably linkable to an identified or identifiable Connecticut consumer (“Personal Data”) we process, the purposes for processing this data, and the Personal Data that we share with third parties as defined by the CTDPA. Please carefully review the general privacy policy for complete information about Kaplan’s data privacy practices.
Personal Data We Collect
Personal data means any information that is linked or reasonably linkable to an identified or identifiable individual. Personal data does not include de-identified data or publicly available information
We collect your name, phone number(s), postal address(es), and email address(es).
We collect online activity data, information about products or services purchased or considered, or other purchasing or consuming histories or tendencies to provide you with information, products, or services that you request from us and to improve them.
Our service providers collect bank account numbers, credit card number, debit card number, or any other financial information.
Purpose for Processing Personal Data: To fulfill or meet the reason for which the information was provided to us; To provide the services you requested; To manage payments, fees, and charges; To provide you with support and respond to your inquiries, including to investigate and address your concerns; To monitor and improve our responses; To provide you with email alerts, event registrations, and other notices concerning our products or services, or events or news that may be of interest to you; To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations; To personalize your website experience; To improve and deliver content and product and service offerings relevant to your interests through our website, third-party sites, and via email or text messages; As an education and enablement service provider with consumers from middle school through professional we store this information to optimize your experience with us and assist you in achieving your lifetime and career goals; and Research and development.
Third Parties With Which We Share Personal Data: Service providers such as payment processors; Courts of law/enforcement; and data analytic, intelligence, and augmentation firms.
Profiling Information We Collect
Profiling Information means any form of automated processing performed on personal data to evaluate, analyze or predict personal aspects related to an identified or identifiable individual's economic situation, health, personal preferences, interests, reliability, behavior, location or movements. We may collect information from sources other than you to build a consumer profile of your preferences.
Purpose for Processing Profiling Information: To determine how best to serve you over your lifetime, how you may achieve success when using our products, and how we may modify our offerings for the success of others
Third Parties With Which We Share Profiling Information: Kaplan companies and affiliates.
Sensitive Data We Collect
Sensitive data means personal data that includes (A) data revealing racial or ethnic origin, religious beliefs, mental or physical health condition or diagnosis, sex life, sexual orientation or citizenship or immigration status, (B) the processing of genetic or biometric data for the purpose of uniquely identifying an individual, (C) personal data collected from a known child, or (D) precise geolocation data.
We may collect age from you in interest forms to validate that you are not under the age of thirteen (13) because children under the age of thirteen (13) are not permitted to use the Site. From sources other than you, we may collect other demographic information such as marital status, estimated household income, education, and employment. We do not collect this information from a known child.
Purpose for Processing Sensitive Data: We collect age to comply with the law. We obtain demographic information from sources other than you to further understand our customers and personalize offerings of products or services to optimize your experience with us.
Third Parties With Which We Share Sensitive Data: We do not share Sensitive Data with third parties.
2. What Are My Rights?
Right to Access Information/Correct Inaccurate Personal Data
You have the right to request access to Personal Data collected about you and information regarding the purposes for which we collect it and the third parties and service providers with which we share it. Additionally, you have the right to correct inaccurate or incomplete Personal Data. You may submit such a request as described below.
Right to Deletion of Personal Data
You have the right to request in certain circumstances that we delete any Personal Data that we have collected directly from you or from a third party. You may submit such a request as described below. We may have a reason under the law why we do not have to comply with your request or why we may comply in a more limited way than you anticipated. If we do, we will explain that to you in our response.
Right to Opt Out of Sale of Personal Data to Third Parties
You have the right to opt out of any sale of your Personal Data. We do not sell Personal Data to third parties.
Right to Obtain a Copy of Personal Data
You have the right to request a copy of the Personal Data that you previously provided to us as controller in a portable format. Our collection, use, and disclosure of Personal Data is described in our Privacy Policy.
Right to Opt Out of Targeted Advertising
You have the right to opt out of Targeted Advertising based on your Personal Data obtained from your activities over time and across websites or applications. You may exercise your right to opt-out of targeted advertising by clicking below and completing the form.
Right to Opt Out of Profiling
You have the right to opt out of automated processing of your Personal Data used to analyze or predict personal preferences or interests.
Right to Appeal
If we decline to take action in any request that you submit in connection with the rights described in the above sections, you may ask that we reconsider our response by sending an email to the same email box (referenced in section below) from which you receive the decision. You must ask us to reconsider our decision within 45 days after we send you our decision.
3. How Do I Exercise My Rights?
You may submit a request to exercise your rights above through any of the following means:
(1) By filling out a Privacy Request Form available at this link
(2) By sending us an email at privacy.universitypartners@kaplan.com
If you choose to send an email, please help us locate your data by including the website(s) you interacted with and any email addresses you provided or used to create an account.
Authentication Process
To protect consumers’ Personal Data and to comply with the CTDPA, we will use an authentication process to confirm your identity before we act on your request. You or your authorized agent may make an authenticated consumer request related to your Personal Data. If you use an authorized agent to submit a request on your behalf, we may require that you (1) provide the authorized agent written permission to do so and (2) provide us a copy of the authorization or a copy of a power of attorney.
In authenticating requests, we employ reasonable measures to detect fraudulent requests and prevent unauthorized access to your personal information. To meet our obligations, we are required to authenticate your identity and the identity of your authorized agent, if the request is submitted via an agent, by associating the information provided in your request to personal data previously collected by us.
If we suspect fraudulent or malicious activity on or from the password-protected account, we may decline a request or request that you provide further authenticating information.
Making an authenticated consumer request does not require you to create an account with us. We will only use personal data provided in an authenticated consumer request to authenticate your identity or authority to make the request.
Published August 2024