Effective: January 1, 2020
Last Reviewed: December 20, 2020
This Policy describes:
PERSONAL INFORMATION WE COLLECT
“Personal Information,” means any information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, to any individual or a household. It does not include anonymous or aggregated data that cannot be associated with an individual or household.
We may collect, use, store and transfer different kinds of Personal Information about you, which we have grouped together as follows:
- Identifiers such as first name, maiden name, last name, alias, username or similar unique personal identifier, student ID, account name, online identifier, social security number, driver’s license number, state identification card number, passport number, physical characteristics or description, criminal background status, marital status, disability status, date of birth, place of birth, race, ethnicity, tribal affiliation, gender, or country of origin.
- Contact Information such as billing address, delivery address, email address and telephone numbers.
- Educational Information such as educational records that contain information directly related to a student and which are maintained by an educational institution or agency or party acting for the institution or agency.
- Financial Information such as student financial aid information, tax information, bank account number, credit or debit card number, and account balance and payment details.
- Commercial Information such as details about payments to and from you, other details of products and services you have purchased from us, or purchasing or consuming tendencies or histories.
- Professional or Employment-Related Information such as your education, training, prior work experience, references, certificate, licensure, or other professional information, military affiliation and status, and post-graduation employment and earnings.
- Audio and Visual Information such as digital photographs and videos.
- Technical Information includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our Services.
- Usage Data includes information about how you use our Services.
- Marketing and Communications Information such as marketing campaign data, click throughs, your preferences and consent in receiving marketing from us and our third parties, and your communication preferences.
We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your Personal Information but is not considered Personal Information as this data does not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your Personal Information so that it can directly or indirectly identify you, we treat the combined data as Personal Information which will be used in accordance with this privacy notice.
Children’s Privacy. The Services are intended for adult use only and is not directed towards children, minors, or anyone under the age of 16. If you are under the age of 13, you are not authorized to provide us with any Personal Information. If the parent or guardian of a child under 13 believes that the child has provided us with any Personal Information, the parent or guardian of that child should contact us at the email address below and ask to have this Personal Information deleted from our files.
HOW WE COLLECT YOUR PERSONAL INFORMATION
We may collect Personal Information from a variety of sources and methods. This includes:
Information You Voluntarily Provide to Us
You may give us your Personal Information by filling in forms, enrolling in one of our educational programs, or by corresponding with us by post, phone, text, email or otherwise. This includes Personal Information you provide when you:
- Submit a Request for Information form
- Submit a Contact Us form
- Use the chat feature on our website
- Call, email, or text us
- Apply to enroll and/or enroll in one of our educational programs
- Request a student ID
- Register for classes
- Apply for financial aid
- Request a transcript, diploma, or education verification
- Create a student account, including a student portal, LMS or other account
- Order or purchase educational or other products and services
- Attend our courses, programs or other events where we collect information about you
- Submit a review or student testimonial
- Use one of our career resources
- Use one of our online learning management, student portal, or other interactive tools
Information We Collect When You Use Our Services
Automated technologies or interactions. As is true of most websites, we receive and store certain types of Personal Information whenever you interact with us online. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. When you access and use our Services from your mobile devices, we receive data from that mobile device. This may include your device ID, location data, IP address and device type. You may manage how your mobile device and mobile browser share location information with us, as well as how your mobile browser handles cookies and related technologies by adjusting your mobile device privacy and security settings. Please refer to instructions provided by your mobile service provider or the manufacturer of your device to learn how to adjust your settings.
Information We Collect From Third Parties
We collect Personal Information from various third parties, including those listed below. The collection, use, and disclosure of Personal Information received from third parties is governed by the privacy policies listed on the website where the information was submitted by the user. Third parties may send their own cookies and pixel tags to you, and may collect information and use it in a way inconsistent with this Policy. Please carefully review these third-party privacy policies to understand how your information may be collected, used and disclosed by these third parties.
Third Party Service Providers. We collect Personal Information from service providers, including where we operate accounts on third-party platforms, such as online application submission and management platforms, student information platforms, learning management platforms, email platforms, and social media platforms.
Third Party Advertising Partners. We collect Personal Data received from third party advertising partners, including partners who host and manage various advertisements and online forms where you can request additional information.
Third Party Private Loan Vendors. If you set up an account with an institutional loan vendor, we may collect Personal Information from them related to your institutional loan.
Google Analytics We use third party cookies provided by Google Analytics to assist us in better understanding our website visitors. These cookies collect IP address and usage data, such as the length of time a user spends on a page, the pages a user visits, and the websites a user visits before and after visiting our website. Based on this information, Google Analytics compiles Aggregate Data about website traffic and interactions, which we use to offer better user experiences and tools in the future. For more information on Google Analytics, visit https://support.google.com/analytics.
Third Party Cookies and Tags. We may engage third-parties such as Google and Facebook to serve ads to you about our products and services as you browse the Internet. These third-party providers may use their own cookies and pixels to track your online activities and purchases in order to deliver targeted advertising based on your interests. Pixels deliver information or event data to these third parties while cookies store information on your browsers to be read by third party servers again later. This is discussed further below in the How We Share Your Personal Information section. You can learn more about Google’s cookies by visiting http://www.google.com/policies/technologies/types/. You can learn more about Facebook’s cookies by visiting https://www.facebook.com/policy/cookies/.
Your “Do Not Track” Browser Setting. Some web browsers incorporate a “Do Not Track” feature (DNT) that signals to the websites that you visit that you do not want to have your online activity tracked. Many websites and applications, including the Services, do not currently respond to web browser DNT signals because such signals are not yet uniform. For more information about DNT signals, please visit http://allaboutdnt.com. Other third party websites may keep track of your browsing activities when they provide you with content, which enables them to customize what they present to you on their websites.
HOW WE USE YOUR PERSONAL INFORMATION
Our primary purpose for collecting Personal Information is to provide you with products and services you request. We may also use your Personal Information for the following business purposes:
- To determine your admissibility for your selected educational program
- To process your application and enroll you in an education program
- To determine your eligibility for financial aid, scholarships, and grants
- To provide career services assistance
- To provide you with information, products and/or services you request
- To facilitate recruitment efforts
- To facilitate the creation of and secure any student accounts
- To communicate with individuals in written, electronic, and verbal form
- To analyze academic and learning outcomes and preferences
- To develop new tools, software applications, products and services
- To obtain payment for services that we provide to you
- For our internal marketing purposes, which include, but are not limited to, sending you material about products, services, updates, etc. that we think may be of interest to you
- To customize the advertising and content you see
- To maintain students records and transcripts
- For internal business purposes such as complying with our internal policies or improving our Services
- To analyze how our Services are being accessed and used
- To verify information
- To protect our interests, including establishing, exercising and defending legal rights and claims
- For purposes disclosed at the time you provide your information or as otherwise set forth in this Policy
HOW WE SHARE PERSONAL INFORMATION WITH THIRD PARTIES
We share your Personal Information with third parties only in the ways that are described in this Policy and with our business partners, suppliers and sub-contractors in order to provide you with our Services and perform any contract we enter into with them or you.
Information You Instruct Us to Share. You may be presented with an option to have us send certain information to third parties or give them access to it. If you choose to do so, your Personal Information and other information may be disclosed to such third parties and all information you disclose will be subject to the third-party privacy policies and practices of such third parties.
Service Providers. We may use third-party service providers to perform certain business services on behalf of us or the Service, and may disclose Personal Information to such service providers as needed for them to perform these business services. Service providers are only allowed to use, disclose or retain the Personal Information to provide these services and are prohibited from selling Personal Information. Business services provided include, but are not limited to, hosting services, software as a service, document management services, communications services such as email, text, and chat services, software and website development services, scholarship and financial aid services, lending and loan processing services, collection services, accounting and audit services, compliance services, quality control services, analytic services, call center services, housing services, marketing services, employment and employment verification services.
Internal Third Parties. We may share Personal Information with our subsidiaries and other affiliated entities/companies owned by or controlled by IEC, who may use the Personal Information for the purposes described above.
Business Transactions. We may do business with third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your Personal Information in the same way as set out in this Policy.
Legal Process. Subject to applicable law, we may disclose information about you (i) if we are required to do so by law, regulation or legal process, such as a subpoena; (ii) in response to requests by government entities, such as law enforcement authorities; (iii) when we believe disclosure is necessary or appropriate to prevent physical, financial or other harm, injury or loss; or (iv) in connection with an investigation of suspected or actual unlawful activity.
User Disclosures. Some Personal Information is disclosed as a matter of course as a result of your use of certain Services. Any Personal Information shared via any public forum using the Services or on another website (such as Facebook, Google, LinkedIn, Instagram or Twitter) may become public information. We cannot control the use of information disclosed in these public forums. You should exercise caution when disclosing information in these public areas, especially your health information and location data, and be careful how you disclose your Personal Information. Content posted in public areas of the Services, including advice and opinions, represents the views and is the responsibility of those who post the content. We do not necessarily endorse, support, verify, or agree with the content posted. If you have any questions or comments about any content posted using the Services, please contact us at the address below.
USERS ASSUME ALL RESPONSIBILITY FOR ANY LOSS OF PRIVACY OR OTHER HARM RESULTING FROM THEIR OWN VOLUNTARY DISCLOSURE OF PERSONAL INFORMATION IN PUBLIC FORUMS
Sales of Personal Information. Like many companies, we allow certain third party advertising partners to place tracking technology such as cookies and pixels on our websites. This technology allows these advertising partners to receive information about your activities on our website, which is then associated with your browser, device, or online identifier. These companies may use this data to serve you more relevant ads as you browse the internet. Under some state laws, this sharing data for online advertising may be considered a “sale” of information. Options for opting out of this sharing are set forth below in the California Privacy Rights section.
You cannot opt out from the reporting of your personal information to the U.S. Department of Education. However, California residents may opt out of the Clearinghouse’s use of your personal information for research purposes and non-consented verifications by emailing us at [email protected] and requesting a Clearinghouse Privacy Block.
Except for this limited sharing or your data as outlined above, IEC does not sell any of your information.
HOW WE PROTECT YOUR INFORMATION
We endeavor to incorporate reasonable safeguards to help protect and secure your Personal Information. However, no data transmission over the Internet, mobile networks, wireless transmission or electronic storage of information can be guaranteed to be 100% secure. Therefore, we cannot guarantee its absolute security. It may be possible for third parties to intercept or access transmissions or private communications unlawfully. Any such transmission is done at your own risk.
CALIFORNIA PRIVACY RIGHTS
California Consumer Privacy Act. The California Consumer Privacy Act of 2018 (“CCPA”) provides California residents with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.
Upon verification of your identity you may:
- No more than twice in any 12-month period, request disclosure of the following information:
- Categories of Personal Information we collect.
- Categories of sources from which Personal Information is collected.
- Categories of Personal Information sold or disclosed to third parties.
- Categories of third parties with whom such Personal Information is sold or disclosed.
- Business or commercial purpose for collecting or selling Personal Information.
- Specific pieces of Personal Information we collect.
- Request deletion of your Personal Information, subject to the exceptions provided by law.
- Opt-out from having your Personal Information sold to third parties, if applicable.
Requests can be submitted by calling our toll free number (800)248-2237 or through our online request form. You can also opt out of having Personal Information transmitted through third party cookies and pixels by clicking on the “Do Not Sell My Personal Information” link.
Please note that these rights apply only to select California consumers and exclude job applicants, employees, and business contacts. Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child.
The verifiable consumer request must:
- Include your full legal name and phone number, which we will need to contact you in order to verify that you are the person about whom we collected Personal Information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. Making a verifiable consumer request does not require you to create an account with us. In order to verify your identity, one of our representatives will call you at the phone number provided.
The CCPA provides the right to be free from discrimination if you choose to exercise your rights under the statute, and IEC will not discriminate by:
- Denying you goods or services.
- Charging you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Providing you a different level or quality of goods or services.
- Suggesting that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Other California Privacy Rights. California Civil Code Section 1798.83 permits California residents who have provided personally identifiable information to us or our third-party advertisers and marketing partners, if any, to request certain information regarding our disclosure of personally identifiable information to third parties for direct marketing purposes. We do not share information we collect about you with third parties for those third parties’ direct marketing purposes.
CHANGES TO THIS PRIVACY NOTICE
IEC may modify or update this Policy from time to time. We encourage you to revisit this page often to remain fully informed of our Policy or you can contact us at any time to obtain the latest copy of this Policy. Where changes to this Privacy will have a fundamental impact on the nature of how we collect, use, or share your data, IEC will give advance notice of such changes.
QUESTIONS ABOUT THIS POLICY
ARBITRATION AGREEMENT AND WAIVER OF JURY TRIAL
Agreement to Arbitrate. Any dispute I may bring against IEC, or any of its officers, directors, or employees, with the sole exception of any Borrower Defense Claims described below, or which IEC may bring against me, no matter how characterized, pleaded or styled, shall be resolved by binding arbitration conducted by the American Arbitration Association (the “AAA”) under its Consumer Arbitration Rules (“Consumer Rules”), and decided by a single Arbitrator. The arbitration hearing will be conducted in the city in which the campus I attended is located.
Notice Regarding Borrower Defense Claims: The following provisions are included pursuant to U.S. Department of Education regulations at 34 C.F.R. § 685.300(e) and (f) and shall apply to this Arbitration Agreement for any period during which regulations requiring such notices are in effect: (1) IEC agrees that neither it nor anyone else who later becomes a party to this pre-dispute Arbitration Agreement will use it to stop you from bringing a lawsuit concerning IEC’s acts or omissions regarding the making of the Federal Direct Loan or the provision by IEC of educational services for which the Federal Direct Loan was obtained. You may file a lawsuit for such a claim or you may be a member of a class action lawsuit for such a claim even if you do not file it. This provision does not apply to other claims. We agree that only the court is to decide whether a claim asserted in the lawsuit is a claim regarding the making of the Federal Direct Loan or the provision of educational services for which the loan was obtained. (2) IEC agrees that neither it nor anyone else who later becomes a party to this Arbitration Agreement will use it to stop you from being part of a class action lawsuit in court. You may file a class action lawsuit in court or you may be a member of a class action lawsuit even if you do not file it. This provision applies only to class action claims concerning IEC’s acts or omissions regarding the making of the Federal Direct Loan or the provision by us of educational services for which the Federal Direct Loan was obtained. We agree that only the court is to decide whether a claim asserted in the lawsuit is a claim regarding the making of the Federal Direct Loan or the provision of educational services for which the loan was obtained.
The Federal Arbitration Act (“FAA”) shall govern the interpretation, scope, and enforcement of this Arbitration Agreement. Any and all disputes concerning the interpretation, scope, and enforcement of this Arbitration Agreement shall be decided exclusively by a court of competent jurisdiction, and not by the Arbitrator.
Waiver of Jury Trial: Except as set forth in the Borrower Defense Claim section above, both IEC and I explicitly waive any right to a jury trial. I understand that the decision of the Arbitrator will be binding, and not merely advisory. The award of the Arbitrator may be entered as a judgment in any court having jurisdiction.
Small Claims: This Arbitration Agreement does not affect either party’s right to seek relief in small claims court for disputes or claims within the scope of the small claims court’s jurisdiction.
Class Action Waiver: Except as set forth in Paragraph 2 above, I agree that any dispute or claim I may bring shall be brought solely in my individual capacity, and not as a plaintiff or class member in any purported class action, representative proceeding, mass action, consolidated or joint action.
Effective Date: 2/4/2021