Revised May 2024

This Privacy Policy applies to users of https://onlinedegrees.umassglobal.edu and webpages within https://onlinedegrees.umassglobal.edu (collectively referred to as the “Website”). Northeast Higher Education Consulting, LLC, a subsidiary of Kaplan North America, LLC (hereinafter collectively referred to as “Kaplan''), manages the Website and provides certain higher education support functions and services for University of Massachusetts Global (the “University”). This Privacy Policy explains the collection, use, choices about that use and dissemination of any personal information that Kaplan collects and processes as part of its delivery of support services for the University and processes for Kaplan services. By visiting or interacting with the Website, you accept the terms of this Privacy Policy. The Privacy Policy may be amended from time to time. Your continued use of the Website after any change in the Privacy Policy will constitute your acceptance of such change.

Children Under the Age of 13: No one under the age of 13 may provide any information to or post any information on the Website. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on the Website. If we learn we have collected or received personal information from a child under 13, we will delete that information.

Section 1: Privacy Statement

We know how important privacy is to consumers and the choices available to them. Kaplan and the University each comply with state and federal data protection laws as applicable to them. Additionally, with respect to consumers who elect to enroll in University’s programs and personal information stored by the University, the University complies with FERPA, applicable law and accreditation standards.

Supplemental state disclosures and privacy rights for individual residents in the states of California, Colorado, Connecticut, Oregon, Texas, Utah, or Virginia are described at the Kaplan Privacy Center.

Section 2: Information We Collect About You

We collect and store personal information you voluntarily provide to us to understand your interests, deliver services to you and improve those services. Personal information is information that identifies you, such as your name, postal address, email address or telephone number. Other information such as financial details (credit card, bank account or other financial information) and biographical details (birthdate, gender or demographic information) are also personal information. Personal information does not include data where the identity has been removed (anonymous data). We may collect personal information that can identify you, such as your name and email address, and other information that does not identify you. When you provide personal information to us, the information may be sent to servers located in the United States and other countries around the world.

Information collected automatically. We automatically collect information from your browser when you visit the Website. This information includes your IP address, your browser type and language, access times and the content of any undeleted cookies that your browser previously accepted from us (see "Cookies" below).

Cookies. A cookie is a string of information that is sent by a website and stored on your hard drive or temporarily in your computer's memory. Cookies are small files and won't pose any significant disk-space concerns. You can manage which cookies are set on your device using the cookie menu on this Website or on your Web browser, but doing so may materially affect the functionality of this Website and the information you can access through it.

When you visit the Website, we use cookies to allow you to move quickly through the Website, to personalize your online experience, to allow you to take advantage of some of the Website's password-protected features and to collect information about your use of the Website. As we enable further customization of the Website, cookies will help in assuring that the information provided to you will be relevant to your needs.

Types of Cookies.

Strictly necessary cookies: These cookies are essential to enable you to move around the Website and use its features, such as accessing secure areas of the Website. For example, authentication and security cookies are used to identify and recognize registered users and to enable them to gain access to requested content or features. Without these cookies, services you have asked for cannot be provided.

Functionality cookies: These cookies allow the Website to remember the choices you make and your account preferences and to provide enhanced, more personal features. For example, these cookies will remember your log-in details.

Performance cookies: These are analytics and research cookies that allow us to collect information about how visitors use a website, for instance, which pages visitors go to most often, and if they get error messages from web pages. This helps us to improve the way the Website works and allows us to test different ideas on the site.

Security cookies: We use these cookies to help identify and prevent potential security risks.

Advertising cookies: These cookies are used to display relevant advertising to visitors who use the University services or visit the Website managed by Kaplan, as well as to understand and report on the efficacy of ads serviced by our partners. They track details such as the number of unique visitors. They are also used to build user profiles, including showing you ads based on products you’ve viewed or acts you have taken on the Website.

Third-party cookies: The Website may make use of different third-party applications and services to enhance the experience of website visitors. These include social media platforms such as Facebook and Twitter (through the use of sharing buttons), or embedded content from YouTube and Vimeo. As a result, cookies may be set by these third parties and used by them to track your online activity. We have no direct control over the information that is collected by these cookies.

Other Technologies. Like many websites, we may use standard Internet technology, such as web beacons, site tags, clear GIFs and other similar technologies, to collect and maintain information about your web-surfing activity when you are visiting the Website and other third-party sites. We also may include web beacons or pixel tags in connection with some Website pages and HTML-formatted email messages to, among other things, compile aggregate statistics about Website usage and response rates. A pixel tag is an electronic image. Often a single pixel is ordinarily not visible to Website visitors and may be associated with cookies on the visitors’ hard drive. Pixel tags allow us to count users who have visited certain pages of the Website, to deliver services and to help determine the effectiveness of promotional or advertising campaigns.

Do-Not-Track Disclosures. Some web browsers may transmit "do-not-track" (DNT) or Global Privacy Control (GPC) signals to the websites with which the user communicates. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them. Through our vendor OneTrust, DNT and GPC signals are honored in all U.S. states. Globally, we will interpret the browser “do-not-track” signal as an opt-out signal of the sale of personal information to the U.S. Privacy API.

Google Analytics

We use Google Analytics, which is a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses persistent cookies to analyze how users use a site. The information generated by the cookie about your use of a Site (including your IP address) will be transmitted to and stored by Google. Google will use this information to evaluate your use of the Site, compiling reports on Site activity for Kaplan and the University and providing other services related to website activity and Internet usage. Google may also transfer this information to third parties where required to do so by law or where the third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google.

By using the Website, you consent to Google processing of data about you in the manner and for the purposes set out above. Please visit the following pages for more information about Google Analytics Terms of Service and Google’s Privacy Practices.

Section 3: How We Use the Information We Collect

We only use your personal information as permitted by law and in accordance with this Privacy Policy. The personal information you choose to share with us is collected by Kaplan and stored by both Kaplan and the University. Most commonly, your personal information is used in the following ways:

Communicate with You. To communicate with you by email, chat, postal mail, telephone and mobile devices; To respond to inquiries and inform you about University’s programs or higher education services that may be of interest to you, or products and services from Kaplan or Kaplan affiliated companies, or other third parties.

Deliver Services for the University. To deliver the services that you have requested; To manage your account and to provide you with customer service and support for the University’s programs; To service the University’s or Kaplan’s contractual requirements; To provide support services and perform functions as otherwise described to you at the time of collection.

Enhance Your Needs and Understand Progression. To monitor progress and performance in the services; To send surveys or questionnaires so that we can learn more about your needs and interests.

Administer and Personalize Your Experience. We use your personal information to recommend products and services that might be of interest to you and personalize your experience; To perform data analytics alongside other data about you that we may collect outside the product or service we deliver to improve product effectiveness, learning experience and quality.

Support, Improve and Develop. To perform research and analysis about your use of, or interest in, the services, or content, or products, services or content offered by others; To analyze performance, fix errors and improve the usability and effectiveness of products and services; To monitor and improve the services we provide the University.

Participate in Social Media. To allow you access to the Website to post comments, upload content or communicate with others.

Advertising and Promotions. We may use your personal information to inform you of special offers and new or existing services that we believe may be of interest to you; To provide you with information about the University’s programs; To send you information about Kaplan products or select third-party's products or services that may be of interest to you; To display content and advertising tailored to your interests on the Website and other sites; To verify your eligibility and deliver prizes in connection with any contests and sweepstakes.

Comply with Legal Obligations. We may use your personal information to comply with laws; perform services for the University; enforce the Privacy Policy terms and conditions; where it is needed in the public interest or for official purposes.

Process Payment and Fraud Prevention. We use personal information to prevent and detect fraud and abuse to protect the integrity of the University’s content and security of student data; We may use financial information or payment method to process payment for any purchases, subscriptions or sales made on the Website; to protect against or identify possible fraudulent transactions; and otherwise as needed to manage services for the University. To protect, investigate and deter against fraudulent, unauthorized or illegal activity.

OR as otherwise specifically described to you at the point of collection.

Section 4: How We Share Information

We do not share your personal information with others except as indicated below. We may share your personal information with:

Authorized service providers: These providers perform services on our behalf and may include fulfilling orders, processing credit card payments, delivering packages, providing customer service and marketing assistance, providing assessments, performing business and sales analysis, supporting our website functionality and supporting contests, sweepstakes, surveys and other features offered through the Website. These service providers may be supplied with or have access to your personal information solely to provide these services to us or on our behalf.

Business Partners: When you express interest in or enroll in University programs, use the services or engage in promotions offered through the Website, we share your personal information with the University and may share with other businesses with which we partner to offer you those programs, services, promotions, contests and sweepstakes.

Kaplan Businesses: We may share your personal information with Kaplan companies as part of our regular reporting activities on company performance, in the context of a business reorganization or group restructuring exercise or for system maintenance support and hosting of data. Sharing contact information with Kaplan companies enables us to provide you with information about a variety of products and services that might interest you.

Government Agencies, Courts of Law and Law Enforcement: We may disclose your personal information in response to a subpoena or similar investigative demand, a court order or a request for cooperation from law enforcement or other government agency; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law.

Other Parties in Connection with a Corporate Transaction: We may also disclose personal information in connection with a substantial corporate transaction, such as the sale of our business, a divestiture, merger, consolidation or asset sale, internal reorganization or in the unlikely event of bankruptcy.

Aggregated Data: We also may share other information with third parties (either Identified or Anonymized) to improve the programs, services and the learning experience, such as data augmentation using third-party data sources to personalize the services. We may also share personal information with third parties to develop and deliver targeted advertising on the Website and websites of third parties. We may combine nonpersonal information we collect with additional nonpersonal information collected from other sources. We also may share aggregated information with third parties, including advisors, advertisers and investors, to conduct the general business analysis.

Section 5: Information Security

Kaplan and the University are committed to ensuring that your personal information is secure. To protect the privacy of your data, we have taken important environmental, electronic and managerial steps to safeguard and secure the information. We have appropriate security measures to prevent your personal information from being accidentally lost, destroyed, used or accessed in an unauthorized way, altered or disclosed. Also, we limit access to your personal information to those employees, service providers, business partners, agents and other third parties who have a legitimate need to know. They will only process your personal information on our instructions or as otherwise agreed and they are subject to a duty of confidentiality. However, as effective as these security measures are, no security system is impenetrable. We cannot guarantee the security of our systems, nor can we guarantee that the information you supply will not be intercepted while being transmitted to us over the Internet.

Section 6: Social Media

Kaplan does not require you to disclose a username or password for accessing personal social media, access personal social media in the presence of Kaplan’s employees or representatives or divulge any personal social media information.

User Submissions: We may provide sections on the Website where you can post information about yourself and others and communicate with others, upload content (e.g., pictures, videos, audio files, etc.) and post comments or reviews of content found on the Site. Such postings may appear on other websites or when searches are executed on the subject of your posting. Whenever you voluntarily disclose personal information on publicly viewable web pages, that information will be publicly available and can be collected and used by others. For example, if you post your email address, you may receive unsolicited messages. We cannot control who reads your posting or what other users may do with the information you voluntarily post, so we encourage you to exercise discretion and caution concerning your personal information. Once you have posted information, you may not be able to edit or delete such information.

Section 7: Data Security

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, destroyed, used or accessed in an unauthorized way, altered or disclosed. Also, we limit access to your personal information to those employees, service providers, business partners, agents and other third parties who have a legitimate need to know. They will only process your personal information on our instructions or as otherwise agreed and they are subject to a duty of confidentiality. However, as effective as these security measures are, no security system is impenetrable. We cannot guarantee the security of our systems, nor can we guarantee that the information you supply will not be intercepted while being transmitted to us over the Internet.

Section 8: Transfer of Data Outside of Your Home Country

Your Personal Information will be held in the United States. Your Personal Information may also be stored, processed and accessed in other countries where Kaplan has facilities, where the University has facilities or where you are located. You consent to the transfer of your Personal Information outside your country, including to the United States.

Section 9: Third-Party Websites and Links

There are some places on the Website or through our services where you may click on a link to access other websites that do not operate under this Privacy Policy. These third-party websites may independently solicit and collect information, including personal information, from you and, in some instances, provide us with information about your activities on those websites. We recommend that you consult the privacy statements of all third-party websites you visit by clicking on the "privacy" link typically located at the bottom of the webpage you are visiting. Kaplan makes no representation about their data practices or policies.

Section 10: Storage and Retention of Your Personal Information

We will only retain your information for as long as necessary to fulfill the purposes we collected it for, including to satisfy any contractual, legal, accounting or reporting requirements. To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means and the applicable legal requirements. Please contact us using the contact details in this Privacy Policy if you would like more information.

Section 11: Changes to This Privacy Policy

We reserve the right to modify this Privacy Policy any time and from time to time. We will notify you of changes by posting changes here, or by other appropriate means. Any changes to the Privacy Policy will become effective when the updated policy is posted on the Website. Your use of the Website and University services or your provision of information to us following such changes indicates your acceptance of the revised Privacy Policy. Therefore, it is important that you read this page regularly to ensure you are familiar with the most updated Agreement.

Section 12: Consent

By using this Website, you agree to all of the terms of this Privacy Policy. If you do not agree with any term of this Privacy Policy or our Terms of Use, please do not submit any personally identifiable information. You may withdraw your consent to the processing of your personally identifiable information by contacting umass.globalprivacy@kaplan.com for personal information maintained by Kaplan and the University. If you have enrolled in the University’s program, the University will delete your personally identifiable information except as needed to comply with applicable laws, regulations, and accreditation standards, or as needed to maintain the business functions of the university. Please note, if you do not allow the University to process your personally identifiable information, it will not be possible for you to obtain services or participate in programs or activities at the University.

Section 13: How to Unsubscribe

If you prefer we do not send marketing communications, please follow the unsubscribe links on any marketing message or contact us at umass.globalprivacy@kaplan.com.

Section 14: How to Contact Us

Comments, queries and requests relating to this Privacy Policy are welcomed and should be addressed as follows:

By mail: Kaplan North America, LLC 1515 W Cypress Creek Road Fort Lauderdale, FL 33309

By email: umass.globalprivacy@kaplan.com