Privacy Policy Addendum For Virginia Residents

This Special Notice for Virginia residents supplements our Privacy Policy and applies only to Virginia residents. This notice describes how we collect, use, and share your personal data in our capacity as a “Controller” under Virginia’s Consumer Data Protection Act (“CDPA”), 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 meanings given in the CDPA and do not include information excluded from the CDPA’s scope. In general, personal data is information reasonably linkable to an identifiable person.

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 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 CDPA.

To the extent that we collect Personal Data that is subject to the CDPA, that information, our practices, and your rights are described below. Persons with disabilities may obtain this notice in alternative format through any contact method at Accessibility Support.

1. What Personal Data Do We Process and Share?

Consistent with the "Information We Collect" and “How We Use Information”  sections in the general privacy policy, we may collect certain categories of information about Virginia consumers (“Personal Data”). The chart below summarizes the Personal Data we process, the purposes for processing this data, the categories of personal data that we share with third parties, and the categories of third parties that we share the data with as specified in the CDPA.  We do not sell personal data to third parties. 

 

Categories of Personal Data

 

Identifiers

 

Personal data we collect in this category: Your name, phone number(s), postal address(es), and email address(es).

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 to 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 report your attendance, performance, completion data; 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 school, we store this information to optimize your experience with us and assist you in achieving your lifetime and career goals; Research and development 

Categories of third parties with whom we share Personal Data: Service Providers such as Payment processors; Other Kaplan Businesses; Courts of Law/Enforcement; Data Analytic, Intelligence and Augmentation Firms.

 

Commercial Information

 

Personal data we collect in this category: 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.  

Purpose for Processing Personal Data: To provide lifelong learners information of interest and opportunities for development.

Categories of third parties with whom we share Personal Data: Service Providers such as Payment processors; Other Kaplan Businesses; Courts of Law/Enforcement; Data Analytic, Intelligence and Augmentation Firms.

 

Financial Information

 

Personal data we collect in this category: Credit card number, debit card number, or any other financial information.

Purpose for Processing Personal Data: To provide lifelong learners information of interest and opportunities for development.

Categories of third parties with whom we share Personal Data: Service Providers such as Payment processors.

 

Inferences

 

Personal data we collect in this category: Information from sources other than you, to build a consumer profile of your preferences.

Purpose for Processing Personal Data: 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.

Categories of third parties with whom we share Personal Data: Other Kaplan Businesses.

 

Sensory Information

 

Personal data we collect in this category: Your audio or voice recordings if you submit or post a recording when applying to or participating in the program, for instance in a personal statement, assignment, or discussion board, as part of delivering service to you; or if your program is recorded as part of the delivery of services for quality assurance and internal review.

Purpose for Processing Personal Data: We retain recordings you submit as part of your educational record. We retain program recordings for the benefit of other participants in the program,  internal research and quality assurance.

Categories of third parties with whom we share Personal Data: We do not share Sensory Information with third parties.

 

Sensitive Data

 

Personal data we collect in this category: Your demographic information.

Purpose for Processing Personal Data: We obtain demographic information from sources other than you to further understand our customers and personalize offerings of products or service to optimize your experience with us.

Categories of third parties with whom we share Personal 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 whom we share it.  Additionally, you have the right to correct inaccurate or incomplete Personal Information. 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. 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 by Kaplan to third parties at  “Opt Out of Sale of Personal Data and Targeted Advertising.”   We do not sell Personal Data to third parties for their own direct marketing purposes.  

Right to Portability. 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, disclosure, and sale of Personal Information 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.

Right to Opt Out of Profiling. You have the right to opt out of having your personal data processed for the purpose of profiling in the furtherance of decisions that produce legal or similarly significant effects concerning you.

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)  that you receive the decision. You must ask us to reconsider our decision within 45 days after we send you our decision. 

 

3. How to Exercise My Rights?

You may submit a request to exercise your rights above through any of the following means:

(1)   By sending us an email at privacy.universitypartners@kaplan.com

(2)   By calling us at (877) 881-7313.

To protect consumers’ Personal Data and to comply with the CDPA, we will use a verification process to confirm your identity before we act on your request.  You or your authorized agent may make a verifiable 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 verifying 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 verify 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 information 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 verifying information. 

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 your identity or authority to make the request.

Rev. December 19, 2022