Privacy Policy

Last Updated: May 30, 2024

Summary

Thank you for visiting the Aspen University® website located at www.aspen.edu (the “Site”). The Site is an Internet property of Aspen University Inc. (“Company,” “we,” “our” or “us“). The following Aspen University® Website Privacy Policy (“Privacy Policy“) sets forth our policy with respect to the collection, storage and use of your Personal Information. For purposes of this Privacy Policy, “Personal Information” means any information concerning the personal or material circumstances of an identified or identifiable individual. This includes information such as your name, your address, your phone number and your email address. 

Please note, if you are a resident of, or physically located in, a European Union Member State (“EU Resident“), additional terms, conditions and provisions apply to the collection, storage and use of your Personal Information (“EU Privacy Terms“), as required by the General Data Protection Regulation (“GDPR“). Please note, if you are a resident of, or physically located in, the United Kingdom (“UK Resident“), additional terms, conditions and provisions apply to the collection, storage and use of your Personal Information (“UK Privacy Terms“), as required by the UK General Data Protection Regulation (“UK GDPR“).

Where there is a conflict between the EU Privacy Terms and/or UK Privacy Terms and any other provision of this Privacy Policy, the EU Privacy Terms and UK Privacy Terms, as applicable, shall govern with respect to EU Residents and UK Residents, respectively. While certain EU Privacy Terms are included throughout this Privacy Policy, please see the “EU Resident Privacy Terms” section below for additional EU Privacy Terms. While certain UK Privacy Terms are included throughout this Privacy Policy, please see the “UK Resident Privacy Terms” section below for additional UK Privacy Terms.

Users with disabilities who wish to access this Privacy Policy in an alternative format can contact us by calling us at: 888-841-4352; emailing us at: privacy@aspen.edu; or sending us U.S. Mail to: Aspen University, 4615 E. Elwood St., Suite 100, Phoenix, AZ 85040.

Background

This Privacy Policy covers our treatment of Personal Information and other information that we collect when an end-user visitor to the Site (“User,” “you” or “your“): (a) accesses or uses the Site; (b) accesses, downloads and/or views: (i) any of the links to various third-party operated websites, information and/or resources (“Links“), as featured on the Site; (ii) our current course catalogue (“Course Catalogue“); (iii) our academic policies; (iv) information pertaining to available courses, coursework, admission requirements, credit transfers, faculty, tuition, scholarships, examinations, student policies, codes of conduct and any other information pertaining to our academic offerings (“Academic Content“); and/or (v) any of the other text, brochures, audio, video, photographs, graphics, artwork and/or other Company content featured on the Site (the “General Content,” and together with the Links, Course Catalogue and Academic Content, the “Content“); (c) accesses links to Company’s social media pages/accounts featured on third-party social media websites, such as Facebook®, LinkedIn® and X®(collectively, “Social Media Pages“); (d) utilizes the various service portals featured on the Site, as made available by our third-party service providers (“Third-Party Service Providers“), for use by students (“Students“) in order to: (i) make tuition payments via the payment portal (“Payment Portal“); and/or (ii) manage aspects of the applicable Student’s current enrollment with Aspen University (“Aspen University“) including, without limitation, accessing testing services and participating in classroom-related activities via the student portal (“Student Portal,” and together with the Payment Portal, the “Portals“); (e) applies for admission to Aspen University (“Admission Application Services“); (f) accesses certain student forums, classroom forums, message boards, comments sections and other interactive features of the Student Portal and/or Site (collectively, “Interactive Services“); (g) accesses information pertaining to and/or registers to enter one or more promotions and/or sweepstakes that may be offered by Company from time-to-time (collectively, “Promotions”);; and/or (g) utilizes the various contact forms and/or contact information made available on the Site as a means to contact directly, or request to be contacted by, Company (collectively, the “Contact Services,” and together with the Site, Content, Social Media Pages, Portals, Admission Application Services, Interactive Services and Promotions, the “Site Offerings“).

Capitalized terms not defined herein shall have the meanings set forth in the Aspen University® Website Terms and Conditions (“Terms and Conditions“). IF YOU DO NOT AGREE TO TERMS OF THIS PRIVACY POLICY IN THEIR ENTIRETY, YOU MAY NOT ACCESS OR OTHERWISE USE THE SITE OFFERINGS.

Facebook® is a registered trademark of Facebook, Inc. (“Facebook”). LinkedIn® is a registered trademark of LinkedIn Corporation (“LinkedIn”). X® is a registered trademark of X Corp. (“X”). Please be advised that Company is not in any way affiliated with Facebook, LinkedIn or Twitter, nor are the Site Offerings endorsed, administered or sponsored by any of the foregoing entities.

Your State Specific Privacy Rights

Residents of the States of California, Colorado, Connecticut, Delaware, Iowa, Montana, Nebraska, Nevada, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah and Virginia, businesses organized under the laws of the State of California, as well as California-based employees of Company, and Covered Users who submit job applications to, Company (collectively, “Covered Users”), are afforded additional rights pursuant to applicable state law. Please see our “Privacy Provisions for Covered Users” below for a more complete description of your rights as a Covered User.

1. Your California Privacy Rights

Shine the Light.  If you are a resident of the State of California and would like to learn how your “personal information” (as defined in the Shine the Light Law, Cal. Civ. Code § 1798.83) is shared with third-parties, what categories of personal information we have shared with third-parties in the preceding year, as well as the names and addresses of those third-parties, please e-mail us at: privacy@aspen.edu; call us at: (888) 841-4352; or send us U.S. Mail to: Aspen University, 4615 E. Elwood St., Suite 100, Phoenix, AZ 85040.

Further, if you are a resident of the State of California and would like to opt-out from the disclosure of your personal information to any third-party for marketing purposes, please e-mail us at:  privacy@aspen.edu; call us at: (888) 841-4352; or send us U.S. Mail to: Aspen University, 4615 E. Elwood St., Suite 100, Phoenix, AZ 85040. Please be advised that where California State residents opt-out from permitting their personal information to be shared, such individuals may still receive selected offers directly from us, in accordance with applicable law.

California Consumer Privacy Act of 2018 (“CCPA”).  In addition to the foregoing, if you are a resident of the State of California, certain other privacy-related rights may apply to you in accordance with the CCPA, including the right to delete the personal information we have collected about you, and the right to opt-out of our sale of your personal information, as well as the right to know what personal information about you we have collected, whether your personal information was shared with third-parties in the preceding year and, if so, what categories of personal information were shared, as well as the categories of third parties with whom we shared that personal information.  Please see our “Privacy Provisions for Covered Users” below for a more complete description of your rights under the CCPA as a California State resident.

The California Privacy Rights Act (“CPRA”).  In addition to the foregoing, if you are a resident of the State of California, certain other privacy-related rights may apply to you in accordance with the CPRA, including the right to opt-out from the use of your personal data for certain profiling activities, the right to opt-out of the use of your personal information for targeted advertising, the right to correct personal information we have collected about you, the right to opt-out of our use/sharing of your sensitive personal information, the right to know how long we retain your sensitive and non-sensitive personal information, the right to know what sensitive personal information about you we have collected, whether your sensitive personal information was shared with third-parties in the preceding year and, if so, what categories of sensitive personal information were shared, as well as the categories of third parties with whom we shared that sensitive personal information. Please see our “Privacy Provisions for Covered Users” below for a more complete description of your rights under the CPRA as a California State resident.

Browser “Do Not Track” Signals. Most browsers contain a “do-not-track” setting. In general, when a “do-not-track” setting is active, the user’s browser notifies other websites that the user does not want her/his personal information and online behavior to be tracked and used, for example, for interest-based advertising.  As required by California Online Privacy Protection Act (“CalOPPA”), we are required to inform you that, as is the case with most websites, we do not honor or alter our behavior when a Site user has activated the “do-not-track” setting on her/his browser; provided, however, that you may have certain rights with respect to the use of automated technologies to deliver targeted advertising to you, as well as to create profiles about you using your personal information.

2. Your Colorado Privacy Rights 

If you are a resident of the State of Colorado, certain privacy-related rights may apply to you in accordance with the Colorado Privacy Act (“CPA”), including the right to correct personal information we have collected about you, the right to delete the personal information we have collected about you, the right to opt-out of our use/sharing of your sensitive personal information, the right to opt-out from the use of your personal data for certain profiling activities, the right to opt-out of the use of your personal information for targeted advertising, and the right to opt-out of our sale/sharing of your personal information, as well as the right to know what personal information about you we have collected, whether your personal information was shared with third-parties in the preceding year and, if so, what categories of personal information were shared, as well as the categories of third parties with whom we shared that personal information. Please see our “Privacy Provisions for Covered Users” below for a more complete description of your rights under the CPA as a Colorado State resident.

3. Your Connecticut Privacy Rights 

If you are a resident of the State of Connecticut, certain privacy-related rights may apply to you in accordance with the Connecticut Data Privacy Act (“CTDPA”), including the right to correct personal information we have collected about you, the right to delete the personal information we have collected about you, the right to opt-out of our use/sharing of your sensitive personal information, the right to opt-out from the use of your personal data for certain profiling activities, the right to opt-out of the use of your personal information for targeted advertising, and the right to opt-out of our sale/sharing of your personal information, as well as the right to know what personal information about you we have collected, whether your personal information was shared with third-parties in the preceding year and, if so, what categories of personal information were shared, as well as the categories of third parties with whom we shared that personal information. Please see our “Privacy Provisions for Covered Users” below for a more complete description of your rights under the CTDPA as a Connecticut State resident.

4. Your Delaware Privacy Rights

If you are a resident of the State of Delaware, certain privacy-related rights may apply to you in accordance with the Delaware Personal Data Privacy Act (“DPDPA”), including the right to correct personal information we have collected about you, the right to delete the personal information we have collected about you, the right to opt-out of our use/sharing of your sensitive personal information, the right to opt-out from the use of your personal data for certain profiling activities, the right to opt-out of the use of your personal information for targeted advertising, and the right to opt-out of our sale/sharing of your personal information, as well as the right to know what personal information about you we have collected, whether your personal information was shared with third-parties in the preceding year and, if so, what categories of personal information were shared, as well as the categories of third parties with whom we shared that personal information. Please see our “Privacy Provisions for Covered Users” below for a more complete description of your rights under the DPDPA as a Delaware State resident.

5. Your Iowa Privacy Rights

If you are a resident of the State of Iowa, certain privacy-related rights may apply to you in accordance with the Iowa Data Protection Act (“IDPA”), including the right to opt-out of our sale/sharing of your personal information, as well as the right to know what personal information about you we have collected, whether your personal information was shared with third-parties in the preceding year and, if so, what categories of personal information were shared, as well as the categories of third parties with whom we shared that personal information. Please see our “Privacy Provisions for Covered Users” below for a more complete description of your rights under the IDPA as an Iowa State resident.

6. Your Montana Privacy Rights

If you are a resident of the State of Montana, certain privacy-related rights may apply to you in accordance with the Montana Consumer Data Privacy Act (“MCDPA”), including the right to correct personal information we have collected about you, the right to delete the personal information we have collected about you, the right to opt-out of our use/sharing of your sensitive personal information, the right to opt-out from the use of your personal data for certain profiling activities, the right to opt-out of the use of your personal information for targeted advertising, and the right to opt-out of our sale/sharing of your personal information, as well as the right to know what personal information about you we have collected, whether your personal information was shared with third-parties in the preceding year and, if so, what categories of personal information were shared, as well as the categories of third parties with whom we shared that personal information. Please see our “Privacy Provisions for Covered Users” below for a more complete description of your rights under the MCDPA as a Montana State resident.

7. Your Nebraska Privacy Rights

If you are a resident of the State of Nebraska, certain privacy-related rights may apply to you in accordance with the Nebraska Data Privacy Act (“NDPA”), including the right to correct personal information we have collected about you, the right to delete the personal information we have collected about you, the right to opt-out of our use/sharing of your sensitive personal information, the right to opt-out from the use of your personal data for certain profiling activities, the right to opt-out of the use of your personal information for targeted advertising, and the right to opt-out of our sale/sharing of your personal information, as well as the right to know what personal information about you we have collected, whether your personal information was shared with third-parties in the preceding year and, if so, what categories of personal information were shared, as well as the categories of third parties with whom we shared that personal information. Please see our “Privacy Provisions for Covered Users” below for a more complete description of your rights under the NDPA as a Nebraska State resident.

8. Your Nevada Privacy Rights

Nevada State residents have the right to submit opt-out requests to website operators instructing those website operators not to sell any “covered information” that the website operators have collected about Nevada State residents to any third party data broker(s). Covered information includes a consumer’s name, postal and email address, telephone number and Social Security Number, and includes the Information described below in the “Personal Information Collected” section.

If you are a Nevada State resident and you wish to exercise your right to request that we to stop the sale of your Information to third party data brokers, please e-mail us at: privacy@aspen.edu; call us at: (888) 841-4352; or send us U.S. Mail to: Aspen University, 4615 E. Elwood St., Suite 100, Phoenix, AZ 85040. In your request, please specify that you want to exercise your rights to opt-out from the sale of covered information under the Nevada Privacy Law and specify the website that you visited and the email address you registered with. Please allow thirty (30) days for a response.

9. Your New Hampshire Privacy Rights

If you are a resident of the State of New Hampshire, certain privacy-related rights may apply to you in accordance with SB 255-FN (“NHDPA”), including the right to correct personal information we have collected about you, the right to delete the personal information we have collected about you, the right to opt-out of our use/sharing of your sensitive personal information, the right to opt-out from the use of your personal data for certain profiling activities, the right to opt-out of the use of your personal information for targeted advertising, and the right to opt-out of our sale/sharing of your personal information, as well as the right to know what personal information about you we have collected, whether your personal information was shared with third-parties in the preceding year and, if so, what categories of personal information were shared, as well as the categories of third parties with whom we shared that personal information. Please see our “Privacy Provisions for Covered Users” below for a more complete description of your rights under the NHDPA as a New Hampshire State resident.

10. Your New Jersey Privacy Rights

If you are a resident of the State of New Jersey, certain privacy-related rights may apply to you in accordance with the New Jersey Privacy Act (“NJPA”), including the right to correct personal information we have collected about you, the right to delete the personal information we have collected about you, the right to opt-out of our use/sharing of your sensitive personal information, the right to opt-out from the use of your personal data for certain profiling activities, the right to opt-out of the use of your personal information for targeted advertising, and the right to opt-out of our sale/sharing of your personal information, as well as the right to know what personal information about you we have collected, whether your personal information was shared with third-parties in the preceding year and, if so, what categories of personal information were shared, as well as the categories of third parties with whom we shared that personal information. Please see our “Privacy Provisions for Covered Users” below for a more complete description of your rights under the NJPA as a New Jersey State resident.

11. Your Oregon Privacy Rights

If you are a resident of the State of Oregon, certain privacy-related rights may apply to you in accordance with the Oregon Consumer Privacy Act (“OCPA”), including the right to correct personal information we have collected about you, the right to delete the personal information we have collected about you, the right to opt-out of our use/sharing of your sensitive personal information, the right to opt-out from the use of your personal data for certain profiling activities, the right to opt-out of the use of your personal information for targeted advertising, and the right to opt-out of our sale/sharing of your personal information, as well as the right to know what personal information about you we have collected, whether your personal information was shared with third-parties in the preceding year and, if so, what categories of personal information were shared, as well as the categories of third parties with whom we shared that personal information. Please see our “Privacy Provisions for Covered Users” below for a more complete description of your rights under the OCPA as an Oregon State resident.

12. Your Tennessee Privacy Rights

If you are a resident of the State of Tennessee, certain privacy-related rights may apply to you in accordance with the Tennessee Information Protection Act (“TIPA”), including the right to correct personal information we have collected about you, the right to delete the personal information we have collected about you, the right to opt-out of our use/sharing of your sensitive personal information, the right to opt-out from the use of your personal data for certain profiling activities, the right to opt-out of the use of your personal information for targeted advertising, and the right to opt-out of our sale/sharing of your personal information, as well as the right to know what personal information about you we have collected, whether your personal information was shared with third-parties in the preceding year and, if so, what categories of personal information were shared, as well as the categories of third parties with whom we shared that personal information. Please see our “Privacy Provisions for Covered Users” below for a more complete description of your rights under the TIPA as a Tennessee State resident.

13. Your Texas Privacy Rights

If you are a resident of the State of Texas, certain privacy-related rights may apply to you in accordance with the Texas Data Privacy and Security Act (“TDPSA”), including the right to correct personal information we have collected about you, the right to delete the personal information we have collected about you, the right to opt-out of our use/sharing of your sensitive personal information, the right to opt-out from the use of your personal data for certain profiling activities, the right to opt-out of the use of your personal information for targeted advertising, and the right to opt-out of our sale/sharing of your personal information, as well as the right to know what personal information about you we have collected, whether your personal information was shared with third-parties in the preceding year and, if so, what categories of personal information were shared, as well as the categories of third parties with whom we shared that personal information. Please see our “Privacy Provisions for Covered Users” below for a more complete description of your rights under the TDSPA as a Texas State resident.

14. Your Utah Privacy Rights 

If you are a resident of the State of Utah, certain privacy-related rights may apply to you in accordance with the Utah Consumer Privacy Act (“UCPA”), including the right to correct personal information we have collected about you, the right to delete the personal information we have collected about you, the right to opt-out of our use/sharing of your sensitive personal information, the right to opt-out from the use of your personal data for certain profiling activities, the right to opt-out of the use of your personal information for targeted advertising, and the right to opt-out of our sale/sharing of your personal information, as well as the right to know what personal information about you we have collected, whether your personal information was shared with third-parties in the preceding year and, if so, what categories of personal information were shared, as well as the categories of third parties with whom we shared that personal information. Please see our “Privacy Provisions for Covered Users” below for a more complete description of your rights under the UCPA as a Utah State resident.

15. Your Virginia Privacy Rights 

If you are a resident of the State of Virginia, certain privacy-related rights may apply to you in accordance with the Virginia Consumer Data Protection Act (“VCDPA”), including the right to correct personal information we have collected about you, the right to delete the personal information we have collected about you, the right to opt-out of our use/sharing of your sensitive personal information, the right to opt-out from the use of your personal data for certain profiling activities, the right to opt-out of the use of your personal information for targeted advertising, and the right to opt-out of our sale/sharing of your personal information, as well as the right to know what personal information about you we have collected, whether your personal information was shared with third-parties in the preceding year and, if so, what categories of personal information were shared, as well as the categories of third parties with whom we shared that personal information. Please see our “Privacy Provisions for Covered Users” below for a more complete description of your rights under the VCDPA as a Virginia State resident.

General Privacy Provisions

Privacy Policy Quick Links

Below are links to key sections of our Privacy Policy:

Family Educational Rights and Privacy Act

Personal Information Collected

Use and Sharing of Personal Information

Non-Personal Information Collection and Use

EU Resident Privacy Terms

UK Resident Privacy Terms [PLEASE HYPERLINK]

Credit Card Transactions

Security of Your Personal Information

Minors

Opt-Out/Unsubscribe

Individual Rights: Deleting, Modifying and Updating Your Personal Information

Changes to this Privacy Policy

Contact Us

Family Educational Rights and Privacy Act

If you are a Student (or are applying to become a Student) at Aspen University, your Personal Information may also be protected under the Family Educational Rights and Privacy Act (“FERPA”). Please see our FERPA Annual Notification of Student Rights for more information about FERPA and the rights and options granted to you under FERPA. Where there is any conflict between FERPA and the terms and conditions of this Privacy Policy, FERPA shall govern in all respects.

Personal Information Collected

Please see our Privacy Provisions for Covered Users below for additional details regarding the categories of Personal Information collected. 

We collect Personal Information when you access certain of the Site Offerings including the Portals, Contact Services and Admission Application Services, and submit the applicable registration Form.

The information that you must supply on a Form may include, without limitation: (a) your full name; (b) your gender; (c) your date of birth; (d) your military affiliation and branch (if applicable); (e) your mailing/billing address; (f) your e-mail address; (g) your telephone number; (h) your preferred time of day to be contacted; (i) your credit card and/or debit card information (where making a tuition payment); (j) information pertaining to your financial aid or military-related tuition assistance (where making a tuition payment); (k) your academic program of interest; (l) your anticipated start date for your chosen academic program; (m) your anticipated payment method for your chosen academic program; (n) your previous education experience, including any applicable college(s) attended, the country where such college(s) is/are located and any degree(s) earned from such college(s); (o) whether or not English is your first language; (p) your current employer; and/or (q) any other information requested on the Form. In addition, Users attempting to utilize a Portal may be required to submit their ID and Password.

For purposes of this Privacy Policy, items (i), (j), (m) and (o) in the preceding sentence shall be referred to as “Sensitive Information.”

Use and Sharing of Personal Information

Please see our Privacy Provisions for Covered Users below for details regarding our use and sharing of Personal Information.  

By submitting your Personal Information by and through the Site Offerings (other than for EU Residents and UK Residents), you agree that we may share, sell, rent, lease or otherwise provide that Personal Information (other than Sensitive Information) to any third-party for any purpose permitted by law, and we may work with other businesses to bring selected retail opportunities to our Users. These businesses and third-parties may include, but are not limited to: (a) providers of direct marketing services and applications, including lookup and reference, data enhancement, suppression and validation; (b) e-mail marketers; (c) telemarketers (where permitted by applicable law); and (d) direct marketers. We may also use your Personal Information (other than that of EU Residents and UK Residents) to send you promotional messages regarding various Company products and/or services, as well as third-party products and/or services that we think may be of interest to you.

Where you submit Personal Information, we use the Personal Information that you make available to personalize your experience with the Site and to facilitate the delivery of the applicable Site Offerings to you, including to respond to any inquiries made by you.

You also agree that we may contact you at any time with updates and/or any other information that we may deem appropriate for you to receive in connection with your continued use of the Site Offerings.

We may also employ other companies and individuals to perform certain functions on our behalf. Examples include sending direct and electronic mail, removing duplicate information from User lists, analyzing data and providing marketing analysis. The agents performing these limited functions on our behalf shall have access to our Users’ Personal Information as needed to perform these functions for us, but we do not permit them to use User Personal Information for other purposes.

We will also use your Personal Information for customer service, to provide you with information that you may request and/or to customize your experience with the Site Offerings. We may also use your Personal Information for internal business purposes, such as analyzing and managing our service offerings including, without limitation, the Site Offerings. We may also combine the information we have gathered about you (other than that of and UK Residents  Residents) with information from other sources.

By submitting your Personal Information by and through the Site Offerings, you agree that such act constitutes an inquiry and/or application for purposes of the Amended Telemarketing Sales Rule (16 CFR §310 et seq.), as amended from time to time (the “Rule“) and applicable state do-not-call regulations. As such, notwithstanding that your telephone number may be listed on the Federal Trade Commission’s Do-Not-Call List, and/or on applicable state do-not-call lists, we retain the right to contact you via telemarketing in accordance with the Rule and applicable state do-not-call regulations; provided, however, that this paragraph only applies to EU Residents and UK Residents where those individuals have provided consent as required under the GDPR and UK GDPR, respectively.  EU Residents and UK Residents are not required to provide this consent in order to obtain access to the Site Offerings. EU residents and UK Residents may revoke this consent at any time by emailing us at: privacy@aspen.edu.

Where you provide “prior express consent” within the meaning of the Telephone Consumer Protection Act (47 USC § 227), and its implementing regulations adopted by the Federal Communications Commission (47 CFR § 64.1200), as amended from time-to-time (“TCPA”), you consent to receive telephone calls from Company and designated Third-Party Service Providers, including SMS text messages delivered via automated technology, to the telephone number(s) that you provided; provided, however, that this consent only applies to EU Residents and UK Residents where those individuals have provided consent as required under the GDPR. Please note that you are not required to provide consent under the TCPA or GDPR in order to obtain access to the Site Offerings, and your consent simply allows Company, as well as the designated Third-Party Service Providers, to contact you via these means. Please be advised that by agreeing to this Privacy Policy, you are obligated to immediately inform us if and when the telephone number that you have previously provided to us changes. Without limiting the foregoing, if you: (i) have your telephone number reassigned to another person or entity; (ii) give up your telephone number so that it is no longer used by you; (iii) port your telephone number to a landline or vice versa; or (iv) otherwise stop using that telephone number for any reason (collectively “Phone Number Change”), you agree that you shall promptly notify Company of the Phone Number Change via e-mail at: privacy@aspen.edu, or by using one of the methods set forth in the “Contact Us” section below.

We reserve the right to release current or past Personal Information (including Sensitive Information): (A) in the event that we believe that the Site Offerings are being or have been used in violation of the Terms and Conditions or to commit unlawful acts; (B) if the information is subpoenaed or requested pursuant to any court order or legal proceeding; provided, however, that, where permitted by applicable law, we shall provide you with e-mail notice, and opportunity to challenge the subpoena/court order, prior to disclosure of any Personal Information pursuant to a subpoena; (C) if we are sold, merge with a third-party or are acquired by a third-party (collectively, “M&A Transactions”) (including where we share your personal information, including Sensitive Information, in connection with the due diligence process associated with a potential M&A Transaction); or (D) if we are the subject of bankruptcy proceedings; provided, however, that if Company is involved in a bankruptcy proceeding or M&A Transaction, you will be notified via email and/or a prominent notice on the Site of any change in ownership or uses of your Personal Information, as well as any choices that you may have regarding your Personal Information.

You hereby consent to the disclosure of any record or communication to any third-party when we, in our sole discretion, determine the disclosure to be required by applicable law, including sharing your e-mail address with third-parties for suppression purposes in compliance with the CAN-SPAM Act of 2003, as amended from time to time, and other e-mail marketing laws. Users should also be aware that courts of equity, such as U.S. Bankruptcy Courts, might have the authority under certain circumstances to permit Personal Information to be shared or transferred to third-parties without permission.

Non-Personal Information Collection and Use

Please see our Privacy Provisions for Covered Users below for more details regarding the categories and types of non-Personal Information collected.

IP Addresses/Browser Type
We may collect certain non-personally identifiable information about you and your desktop computer and/or mobile device when you visit many of the pages of the Site. This non-personally identifiable information includes, without limitation, the type of browser that you use (e.g., Safari, Chrome, Internet Explorer), your IP address, the type of operating system that you use (e.g., Windows or iOS) and the domain name of your Internet service provider (e.g., Verizon, AT&T). We use the non-personally identifiable information that we collect to improve the design and content of the Site Offerings and to enable us to personalize your Internet experience. We also may use this information in the aggregate to analyze usage of the Site Offerings.

Cookies
When a User visits the Site, we send one (1) or more cookies and/or gif files (collectively, “Cookies”) to assign an anonymous, unique identifier to the applicable User’s computer; provided, however, that we will only utilize tracking Cookies in connection with the computers of EU Residents and UK Residents where those individuals have provided consent for same as required under the GDPR and UK GDPR, respectively.  EU Residents and UK Residents are not required to provide this consent in order to obtain access to the Site Offerings. EU residents and UK Residents may revoke this consent at any time by emailing us at: privacy@aspen.edu. A Cookie is a piece of data stored on your hard drive containing non-personally identifiable information about you. Cookies have many benefits to enhance your experience at the Site. To find out more about Cookies, please visit www.cookiecentral.com. We use Cookies to improve the quality of the Site Offerings, including for storing User preferences and tracking Site-User trends (such as pages opened and length of stay at the Site).

Most Internet browsers are initially set up to accept Cookies, but you can reset your browser to refuse all Cookies or to indicate when a Cookie is being sent. To disable and reject certain Cookies, follow the instructions associated with your Internet browser. Even in the case where a User rejects a Cookie, he or she may still use the Site Offerings; provided, however, that certain functions of the Site Offerings may be impaired or rendered inoperable if the use of Cookies is disabled. We reserve the right to retain Cookie data indefinitely.

Behavioral Tracking
Company, as well as third party entities such as Facebook®, Google® and HotJar®, use Cookies, pixels and other tracking technology (collectively, “Tracking Technology“) in connection with the Site for purposes of tracking Users’ activities (such as websites visited, advertisements selected and pages viewed) while they are active on the Site, as well as after they leave the Site. Company, and its third-party partners, may use this Tracking Technology to target applicable Users with advertisements featuring Company products and/or services, as well as third-party products and/or services, that may be of interest to applicable Users; provided, however, that the tracking described in this paragraph will only be undertaken in connection with EU Residents and UK Residents where those individuals have provided consent for same as required under the GDPR and UK GDPR, respectively. EU Residents and UK Residents are not required to provide this consent in order to obtain access to the Site Offerings.  EU residents and UK Residents may revoke this consent at any time by emailing us at: privacy@aspen.edu.

In general, Users may be able to disable some, but not all, of this tracking activity by utilizing the “Do Not Track” setting or similar options within most major Internet browsers. In addition, Users may be able to opt-out of this form of tracking utilizing the options made available by the Network Advertising Initiative or Digital Advertising Alliance.

As referenced above, we may use a web analysis tool called Meta Pixel®, as made available by Facebook, Inc. (“Facebook®”).  Facebook® may collect some or all of the following information by and through the Meta Pixel® tracking technology: (a) traffic data from Facebook® users who visit the Site; (b) actions taken on the Site (clicks, downloads, form submissions, registrations, etc.); (c) attribution for purposes of Facebook® ad conversion; and (d) click-through rates from the Site (collectively, “Meta Pixel® Data”).  Facebook® shares the Meta Pixel® Data with us.

We may combine the Meta Pixel® Data with your personal information, and we and/or Facebook® may use that Meta Pixel® Data to serve you targeted ads after you leave the Site.  Information pertaining to Facebook’s® use of Facebook’s® Meta Pixel® Data and Facebook’s® privacy policy can be found here 

Without limiting the foregoing, we may also use a tool called “Google Analytics®,” as made available by Google, Inc. (“Google®”), on the Site.  Google® may collect some or all of the following information by and through the Google Analytics® tracking technology: (a) city and country of the user; (b) device type (desktop, mobile, tablet, etc.); (c) browser type; (d) referring website, search engine or social media platform; (e) Site pages visited; (f) time spent on each page; (g) navigation path through the Site; (h) actions taken on the Site (clicks, downloads, form submissions, registrations, etc.); and (i) exit pages (collectively, “Google Analytics® Data”).  Google® shares the Google Analytics® Data with us.

We may combine Google Analytics® Data with your personal information, and we and/or Google® may use Google Analytics® Data to serve you targeted ads after you leave the Site.  Google’s® ability to use and share the Google Analytics® Data and other information collected about your visits to (and use of) the Site and/or in connection with the Services through the Google Analytics® tool is restricted by the Google Analytics® Terms of Service, available here, and the Google® Privacy Policy, available here. You may learn more about how Google® collects and processes data specifically in connection with Google Analytics here. You may prevent your data from being tracked and/or used by Google Analytics® by downloading and installing the Google® Analytics Opt-out Browser Add-on, available here.

Without limiting the foregoing, we may also use a tool called “HotJar®,” as made available by HotJar Ltd. (“HotJar®”), on the Site.  HotJar® may collect some or all of the following information by and through the HotJar® tracking technology: (a) device type (desktop, mobile, tablet, etc.); (b) browser type; (c) navigation path through the Site; (d) actions taken on the Site (clicks, downloads, form submissions, registrations, etc.); and (i) exit pages (collectively, “HotJar® Data”).  HotJar® shares the HotJar® Data with us.

We may combine HotJar® Data with your personal information, and we and/or HotJar® may use HotJar® Data. Users can opt-out of HotJar®-related tracking by utilizing the options made available here: https://www.hotjar.com/legal/compliance/opt-out.

Cross Device Tracking
Company tracks Users’ use of the Site Offerings across various devices, including your personal computer and mobile device, in order to optimize and personalize your Site Offerings experience. Company may collect certain of your Personal Information across various devices; provided, however, that the tracking described in this paragraph will only be undertaken in connection with EU Residents and UK Residents where those individuals have provided consent for same as required under the GDPR and UK GDPR, respectively.  EU Residents and UK Residents are not required to provide this consent in order to obtain access to the Site Offerings.  EU residents and UK Residents may revoke this consent at any time by emailing us at: privacy@aspen.edu.

Aggregate Data
Company reserves the right to transfer and/or sell aggregate or group data about Users of the Site Offerings for lawful purposes. Aggregate or group data is data that describes the demographics, usage and other characteristics of Site Offerings Users as a group, without disclosing personally identifiable information.

Live Chat/Chat Bots

Company utilizes third-party service providers to provide live chat and automated chat services (collectively, “Chat”) to Users on the Site.  These third party Chat service providers, including Text, Inc. through its “LiveChat” Chat offering, may collect and/or store the following information: (a) content of the Chat conversations; (b) the time spent during each Chat session; (c) the number of Chat interactions; (d) the Site pages visited during each Chat session; (e) ratings and feedback provided by Users after Chat sessions; and (f) any expression of interest and/or intent with respect to obtaining the Site Offerings (collectively, “Chat-Related Data”).  Text, Inc. and other third-party Chat service providers will share the Chat-Related Data with Company; provided, however, that these third-party Chat service providers are not permitted to utilize or share Chat-Related Data (including User personal information collected via Chat conversations) for any purpose other than: (i) to provide the Chat services on the Site; and (ii) to assist Company with its marketing and customer service functionality associated with the Chat services.  Please see our “Privacy Provisions for Covered Users” below for details regarding our use and sharing of personal information. 

EU Resident Privacy Terms

Data Controller. Company is considered the “Data Controller” in connection with the Personal Information collected pursuant to this Privacy Policy for purposes of applicable data protection laws, including the GDPR.

Legal Basis. We collect Personal Information from EU Residents during the registration process to fulfill requests to receive additional information and for the purpose of handling the contractual relationship that EU Residents have with Company, including EU Residents’ enrollment as Students at Aspen University. We also collect Personal Information from EU Residents passively. We only use and store the Personal Information of EU Residents if we have a legal basis for doing so, including where EU Residents have given us their express consent, where we have a legitimate business interest or pursuant to the contractual relationship between EU Residents and Company. Please note that EU Residents have a right to object to processing of their Personal Information where the sole legal basis is that such processing is being carried out for our legitimate business interest.

Personal Information Use. Company will never share, sell, rent, exchange or barter the Personal Information of EU Residents to or with any third-party for financial gain or marketing purposes. As an EU Resident, by making that Personal Information available to Company, you grant Company the right, subject to applicable law, to use that Personal Information solely to contact you regarding your request for Contact Services, your enrollment as a Student at Aspen University and your other use(s) of the Site Offerings. If you wish to stop receiving future communications from us, please follow the instructions at the end of each such e-mail message or see the “Opt-Out/Unsubscribe” section below.

UK Resident Privacy Terms

Data Controller. Company is considered the “Data Controller” in connection with the Personal Information collected pursuant to this Privacy Policy for purposes of applicable data protection laws, including the UK GDPR.

Legal Basis. We collect Personal Information from UK Residents during the registration process to fulfill requests to receive additional information and for the purpose of handling the contractual relationship that UK Residents have with Company, including UK Residents’ enrollment as Students at Aspen University. We also collect Personal Information from UK Residents passively. We only use and store the Personal Information of UK Residents if we have a legal basis for doing so, including where UK Residents have given us their express consent, where we have a legitimate business interest or pursuant to the contractual relationship between UK Residents and Company. Please note that UK Residents have a right to object to processing of their Personal Information where the sole legal basis is that such processing is being carried out for our legitimate business interest.

Personal Information Use. Company will never share, sell, rent, exchange or barter the Personal Information of UK Residents to or with any third-party for financial gain or marketing purposes. As a UK Resident, by making that Personal Information available to Company, you grant Company the right, subject to applicable law, to use that Personal Information solely to contact you regarding your request for Contact Services, your enrollment as a Student at Aspen University and your other use(s) of the Site Offerings. If you wish to stop receiving future communications from us, please follow the instructions at the end of each such e-mail message or see the “Opt-Out/Unsubscribe” section below.

Credit Card Transactions

Company utilizes third-party service providers to provide credit card payment processing services. If you choose to make a tuition payment via the Student Portal, the credit card information provided will either be collected directly by such third-party service provider, or we will share that payment information with our contracted third-party service provider(s). Company requires that its third-party payment processing service provider(s) has/have in place privacy policies and practices consistent with this Privacy Policy; provided, however, that we cannot guarantee the privacy practices of our third-party payment processing service provider(s).

Social Media Websites

If you engage in any interaction with Company, other end-users or any third-party on any Social Media Pages, you should be aware that: (a) the Personal Information that you submit by and through such Social Media Pages can be read, collected and/or used by other users of these websites/services (depending on your privacy settings associated with your accounts with the applicable Social Media Websites), and could be used to send you unsolicited messages or otherwise to contact you without your consent or desire; and (b) where Company responds to any interaction on such Social Media Pages, your account name/handle may be viewable by any and all members/users of Company’s social media accounts.

We are not responsible for the Personal Information that you choose to submit on any Social Media Websites. The Social Media Websites operate independently from Company, and we are not responsible for such Social Media Websites’ interfaces or privacy or security practices. We encourage you to review the privacy policies and settings of the Social Media Websites with which you interact to help you understand those Social Media Websites’ privacy practices. If you have questions about the security and privacy settings of any Social Media Websites that you use, please refer to their applicable privacy notices or policies.

Third-Party Websites

This Site may contain links to third-party owned and/or operated websites including, without limitation, the Links and Social Media Websites. Company is not responsible for the privacy practices or the content of such websites. In some cases, you may be able to make a purchase through one of these third-party websites. In these instances, you may be required to provide certain information, such as a credit card number, to register or complete a transaction at such website. These third-party websites have separate privacy and data collection practices and Company has no responsibility or liability relating to them.

Security of Your Personal Information

We endeavor to safeguard and protect our Users’ Personal Information. When Users make Personal Information available to us, their Personal Information is protected both online and offline (to the extent that we maintain any Personal Information offline). Where our registration/application process prompts: (a) Users to enter Sensitive Information (such as medical information, driver’s license/ID card number, health insurance information, data collected from an automated license plate recognition system, Social Security Number and credit card information); (b) EU Residents and/or UK Residents to enter any Personal Information; and (c) when we store and transmit such Sensitive Information, EU Resident Personal Information and/or UK Resident Personal Information; then (d) this information is encrypted with advanced TLS (Transport Layer Security).

Access to your Personal Information is strictly limited, and we take reasonable measures to ensure that your Personal Information is not accessible to the public. All of our Users’ Personal Information is restricted in our offices, as well as the offices of our third-party service providers. Only employees or third-party agents who need User Personal Information to perform a specific job are granted access to User Personal Information. Our employees are dedicated to ensuring the security and privacy of all User Personal Information. Employees not adhering to our firm policies are subject to disciplinary action. The servers that we store User Personal Information on are kept in a secure physical environment. We also have security measures in place to protect the loss, misuse and alteration of Personal Information under our control.

Please be advised, however, that while we take every reasonable precaution available to protect your data, no storage facility, technology, software, security protocols or data transmission over the Internet or via wireless networks can be guaranteed to be 100% secure. Computer hackers that circumvent our security measures may gain access to certain portions of your Personal Information, and technological bugs, errors and glitches may cause inadvertent disclosures of your Personal Information; provided, however, that any attempt to breach the security of the network, our servers, databases or other hardware or software may constitute a crime punishable by law. For the reasons mentioned above, we cannot warrant that your Personal Information will be absolutely secure. Any transmission of data at or through the Site, other Site Offerings or otherwise via the Internet or wireless networks, is done at your own risk.

In compliance with applicable federal and state laws, we shall notify you and any applicable regulatory agencies in the event that we learn of an information security breach with respect to your Personal Information. You will be notified via e-mail in the event of such a breach. Please be advised that notice may be delayed in order to address the needs of law enforcement, determine the scope of network damage, and to engage in remedial measures.

Minors

Please see our Privacy Provisions for Covered Users below for more details regarding the Personal Information of minors.

Visitors under sixteen (16) years of age are not permitted to use and/or submit their Personal Information at the Site. Company does not knowingly solicit or collect information from visitors under sixteen (16) years of age. Company encourages parents and guardians to spend time online with their children and to participate and monitor the interactive activities of their children.

Opt-Out/Unsubscribe

Please see our Privacy Provisions for Covered Users for instructions on how Covered Users can opt-out of the sale of their Personal Information to third parties.

To opt-out of receiving e-mail and other forms of communications from us, you can: (a) follow the instructions included in the applicable e-mail message or other communication; or (b) e-mail us at: privacy@aspen.edu.

Notwithstanding the foregoing, we may continue to contact you for the purpose of communicating information relating to your request for Site Offerings, as well as to respond to any inquiry or request made by you. To opt-out of receiving Site Offerings-related and/or inquiry response-related messages from Company, you must cease requesting and/or utilizing the Site Offerings and/or cease submitting inquiries to Company, as applicable.

Individual Rights: Deleting, Modifying and Updating Your Personal Information

Please see our Privacy Provisions for Covered Users for instructions on how Covered Users can access and/or delete Personal Information that we have collected.

At your request, we will: (a) inform you of what Personal Information we have on file for you, in a machine-readable format; (b) amend the Personal Information that we have on file for you; and/or (c) completely remove Personal Information that you have provided to us, or that we have collected, from our servers/databases. In addition, where requested by EU Residents and/or UK Residents, we will ensure the removal of the Personal Information that those individuals have provided to us from the servers/databases of any third-party that we have provided that Personal Information to. You may make such a request by e-mailing us at: privacy@aspen.edu. We ask individual users to identify themselves and the information requested to be accessed, corrected or removed before processing such requests.

Please be advised that deleting your Personal Information may terminate your access to certain of the Site Offerings. If you wish to continue using the full complement of Site Offerings, you may not be able to delete all of the Personal Information that we have on file for you.

Transfer of Personal Information Internationally

If you are visiting the Site from a country other than the country in which our servers are located, your communications with us may result in the transfer of Personal Information across international boundaries. By visiting the Site and/or otherwise communicating electronically with us, you consent to such transfers; provided, however, that the international transfer of Personal Information described in this paragraph will only be undertaken in connection with the Personal Information of: (a) EU Residents where such transfer complies with the provisions of the GDPR; and (b) UK Residents where such transfer complies with the provisions of the UK GDPR.  Even if your jurisdiction does not have the same privacy laws as the jurisdiction where our servers are located, we will treat your information as subject to the protections described in this Privacy Policy.

Changes to this Privacy Policy

Company reserves the right to change or update this Privacy Policy at any time by posting a notice on the Site that we are changing our Privacy Policy. If the manner in which we use Personal Information changes, Company will notify Users by: (a) sending the modified policy to our Users via email; and/or (b) by any other reasonable means acceptable under applicable state and federal law. You will have a choice as to whether or not we use your information in this different manner and we will only use your information in this different manner where you affirmatively consent to such use.

Contact Us

If you have any questions about this Privacy Policy or our privacy practices in general, you may email us as at: privacy@aspen.edu; call us at: 888-841-4352; or send us U.S. Mail to: Aspen University, 4615 E. Elwood St., Suite 100, Phoenix, AZ 85040​.

Privacy Provisions for Covered Users

These Privacy Provisions for Covered Users (“Provisions”) supplement, and do not limit in any way, the Privacy Policy set forth above.  These Privacy Provisions apply solely to the Covered Users, who are residents of the States of California, Colorado, Connecticut, Delaware, Iowa, Montana, Nebraska, Nevada, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Virginia and Utah, as well as California-based employees of, and California residents who submit job applicants to, Company and businesses organized under the laws of the State of California. We adopt these Provisions in compliance with the CCPA, CPRA, CPA, CTDPA, DPDPA, IDPA, MCDPA, NDPA, NHDPA , NJPA, OCPA,  VCDPA TIPA, TDPSA, UCPA and VCDPA (collectively, “Applicable State Laws”). Any terms defined in Applicable State Laws have the same meaning when used in these Privacy Provisions.  Users with disabilities who wish to access these Provisions in an alternative format can contact us by calling us at: 888-841-4352; emailing us at: privacy@aspen.edu; or sending us U.S. Mail to: Aspen University, 4615 E. Elwood St., Suite 100, Phoenix, AZ 85040​.

Categories of Information We Collect

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Covered User or device (“personal information”). In particular, we have collected the following categories of personal information from Covered Users within the last twelve (12) months:

Personal information does not include:

• Publicly available information from government records.
• Publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, 34 C.F.R Part 99) (FERPA).
• De-identified or aggregated Covered User information.
• Information excluded from the scope of Applicable State Laws, such as:
  • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; and
  • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

We obtain the categories of personal information for which we indicated “YES” above from the following categories of sources (with the specific categories of personal information indicated in parenthesis):

• Directly from our Covered Users. For example, from online registration forms that our Covered Users submit to us related to the courses, products and/or services that we (and our third party service providers) offer by and through the Site and/or provided through the course of employment and/or through job applications. (Categories A, B, C, I, J, K and L)
• Indirectly from our Covered Users. For example, through information we collect from our Covered Users in the course of providing our courses, products and/or services to them. (Categories A, B, C, F, I, J, K and L)
• Directly and indirectly from activity on the Site. This includes the type of browser that you use (e.g., Safari, Chrome, Internet Explorer), your IP address, the type of operating system that you use (e.g., Windows or iOS) and the domain name of your Internet Service Provider.  In addition, we obtain certain Site usage details and analytics as same are collected automatically by us and our third party partners, such as Facebook®, Google®, Hotjar® and Text, Inc. (Categories F and K)
• From surveys and other questionnaires that we ask Covered Users to complete. (Categories A, B, C, I, J, K and L)
• From third-parties that interact with us in connection with the courses, products and/or services that we offer to our Covered Users. For example, third party entities that assist us in sending direct and electronic mail, removing duplicate information from Covered User lists, analyzing data and providing marketing analysis. (Categories A, B, C, I, J, K and L)

Retention of Personal Information and Sensitive Personal Information 

We retain all categories of your personal information and Sensitive Information that we collect for the maximum period permitted by applicable law. We may also use certain criteria to determine whether and when to delete certain categories of collected personal and sensitive personal information, including:

• Date of collection.
• Frequency of consumer interaction with us.
• Last interaction the consumer had with us.
• Whether the purpose of collection has been completed.

Use of Personal Information

We may use or disclose the personal information that we collect (including: (a) your full name; (b) your gender; (c) your date of birth; (d) your military affiliation and branch (if applicable); (e) your mailing/billing address; (f) your e-mail address; (g) your telephone number; (h) your preferred time of day to be contacted; (i) your credit card and/or debit card information (where making a tuition payment); (j) information pertaining to your financial aid or military-related tuition assistance (where making a tuition payment); (k) your academic program of interest; (l) your anticipated start date for your chosen academic program; (m) your anticipated payment method for your chosen academic program; (n) your previous education experience, including any applicable college(s) attended, the country where such college(s) is/are located and any degree(s) earned from such college(s); (o) whether or not English is your first language; and (p) your current employer) for one or more of the following business purposes (with the specific categories of personal information indicated in parenthesis):

• To fulfill or meet the reason for which the information is provided. For example, if you provide us with personal information in connection with your request for information regarding higher education programs and courses, as well as information regarding the other products and/or services featured on the Site, we will use that personal information to better provide you with the requested information. (Categories A, B, C, F, I, J, K and L)
• To provide you with information, courses, products or services that you request from us. (Categories A, B, C, F, I, J, K and L)
• To create, maintain, customize and secure your account with us. (Categories A, B, C, F, I, J, K and L)
• To provide you with e-mail, direct mail and telemarketing messages concerning certain Company courses, products and/or services, as well as third-party products and/or services, that we believe may be of interest to you. (Categories A, B, C, F, I, J, K and L)
• To deliver relevant Site content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you. (Categories A, B, C, F, I, J, K and L)
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including the Site’s Terms and Conditions. (Categories A, B, C, F, I, J, K and L)
• To carry out operations associated with, or your employment and/or job application submitted to, us. (Categories A, B, C, I and L)
• To improve the Site and better present its contents to you. (Categories A, B, C, F, I, J, K and L)
• For customer service purposes and to respond to inquiries from you. (Categories A, B and C)
• For testing, research, analysis and product development. (Categories A, B, C, F, I, J, K and L)
• As necessary or appropriate to protect our rights, property or safety, and that of our clients or others.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations. (Categories A, B, C, F, I, J, K and L)
• To fulfill or meet the requirements for which a disclosure can be made through FERPA. (Categories A, B, C, I, J, K and L)
• As described to you when collecting your personal information or as otherwise set forth in Applicable State Laws. (Categories A, B, C, F, I, J, K and L)
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by us is among the assets transferred. (Categories A, B, C, F, I, J, K and L)

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated or incompatible purposes without providing you with notice.

Sharing Personal Information

Subject to your right to opt-out of such sharing/sale, we may share your personal information with third parties for a business purposes, as detailed below (including, as permitted by applicable law and subject to the restrictions on sales/sharing of Sensitive Information as set forth in the Privacy Policy): (a) your full name; (b) your gender; (c) your date of birth; (d) your military affiliation and branch (if applicable); (e) your mailing/billing address; (f) your e-mail address; (g) your telephone number; (h) your preferred time of day to be contacted; (i) your credit card and/or debit card information (where making a tuition payment); (j) information pertaining to your financial aid or military-related tuition assistance (where making a tuition payment); (k) your academic program of interest; (l) your anticipated start date for your chosen academic program; (m) your anticipated payment method for your chosen academic program; (n) your previous education experience, including any applicable college(s) attended, the country where such college(s) is/are located and any degree(s) earned from such college(s); (o) whether or not English is your first language; and (p) your current employer): (i) with/to third parties for marketing purposes; and (ii) for the other business purposes set forth above. 

When we disclose personal information to a third party service provider or other entity, we enter into a contractual relationship that describes the purpose for which such third party may use the personal information and requires that third party to both keep the personal information confidential and not use it for any purpose other than the performance of its services under the applicable contract.  Please note, we do not collect information from Covered Users that we actually know are less than eighteen (18) years of age and we do not share or sell the personal information of Covered Users that we actually know are less than eighteen (18) years of age.  Without limiting the foregoing, we have not shared or sold the personal information of Covered Users that we actually know are less than sixteen (16) years of age in the preceding twelve (12) months.

In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

Category A:      Identifiers.
Category B:      Personal information categories listed in Applicable State Laws.
Category C:      Protected classification characteristics under Applicable State Laws or federal law.
Category F:      Internet or other similar network activities.
Category I:       Professional or employment-related information.
Category J:       Non-public education information.
Category K:      Inferences drawn from other personal information.
Category L:      Sensitive Information.

We disclose your personal information (including: (a) your full name; (b) your gender; (c) your date of birth; (d) your military affiliation and branch (if applicable); (e) your mailing/billing address; (f) your e-mail address; (g) your telephone number; (h) your preferred time of day to be contacted; (i) your credit card and/or debit card information (where making a tuition payment); (j) information pertaining to your financial aid or military-related tuition assistance (where making a tuition payment); (k) your academic program of interest; (l) your anticipated start date for your chosen academic program; (m) your anticipated payment method for your chosen academic program; (n) your previous education experience, including any applicable college(s) attended, the country where such college(s) is/are located and any degree(s) earned from such college(s); (o) whether or not English is your first language; and (p) your current employer) for a business purpose to the following categories of third parties (with the specific categories of personal information indicated in parenthesis):

• Our affiliates. (Categories A, B, C, F, I, J, K and L)
• Third parties to whom you authorize us to disclose your personal information in connection with the courses, products and/or services that we provide to you. (Categories A, B, C, F, I, J, K and L)

Subject to your right to opt-out of such sharing/sale, we may share your personal information (but not Sensitive Information) with our corporate affiliates as detailed below, including the following information: (a) your full name; (b) your gender; (c) your date of birth; (d) your military affiliation and branch (if applicable); (e) your mailing/billing address; (f) your e-mail address; (g) your telephone number; (h) your preferred time of day to be contacted; (i) your academic program of interest; (j) your anticipated start date for your chosen academic program; (k) your anticipated payment method for your chosen academic program; (l) your previous education experience, including any applicable college(s) attended, the country where such college(s) is/are located and any degree(s) earned from such college(s); (m) whether or not English is your first language; and (o) your current employer).  In the preceding twelve (12) months, we have sold the following categories of personal information (but not Sensitive Information) to our corporate affiliates:

Category A:           Identifiers.
Category B:           Personal information categories listed in Applicable State Laws.
Category C:           Protected classification characteristics under Applicable State Laws or federal law.
Category F:           Internet or other similar network activities.

Your Rights and Choices

Applicable State Laws provide Covered Users with specific rights regarding their personal information. This section describes your rights under Applicable State Laws and explains how to exercise those rights.

Opt-Out from the Sale of Your Personal Information

You have the right to opt-out of our sale of your personal information to third parties.  To exercise your right to opt-out of our sale of your personal information to third parties, please submit a verifiable Covered User request to us by either:

• Clicking here;
• Calling us at: 888-841-4352;
• Emailing us at: privacy@aspen.edu; or
• Sending us U.S. Mail to: Aspen University, 4615 E. Elwood St., Suite 100, Phoenix, AZ 85040​.

We endeavor to act on all opt-out requests as soon as practicable, but in all cases within fifteen (15) days of the receipt of your request.

Opt-Out from the Sharing of Your Personal Information 

You have the right to opt-out of our sharing your personal information with third parties. To exercise your right to opt-out of our sharing your personal information with third parties, please submit a verifiable Covered User request to us by either:

• Clicking here;
• Calling us at: 888-841-4352;
• Emailing us at: privacy@aspen.edu; or
• Sending us U.S. Mail to: Aspen University, 4615 E. Elwood St., Suite 100, Phoenix, AZ 85040.

We endeavor to act on all opt-out requests as soon as practicable, but in all cases within fifteen (15) business days of the receipt of your request. Subject to the aforementioned fifteen (15) business day period, where we receive and confirm your verifiable opt-out request, we will cease sharing your Personal Information with third parties.

Opt-Out from the Use and/or Sharing of Your Sensitive Personal Information 

You have the right to limit our use of your Sensitive Personal Information, including any Sensitive Personal Information from Category B (Personal information categories established by Applicable State Laws), Category C (Protected classification characteristics under Applicable State Laws), Category I (Professional or employment-related information), Category K (Inferences drawn from other personal information) and/or Category L (Sensitive Personal Information), to those uses which: (i) are necessary to provide the services requested by you, and perform our obligations in connection therewith; (ii) help us to ensure security and integrity of your personal information to the extent the use of your Sensitive Personal Information is reasonably necessary and proportionate for these purposes; (iii) are short-term, transient uses including, but not limited to, non-personalized advertising shown as part of your then-current interaction with the Site, provided that your personal information is not disclosed to another third party and is not used to build a profile about you or otherwise alter your experience outside the then-current interaction with the Site; (iv) involve performing services on behalf of Company, including maintaining or servicing accounts, providing customer service, processing transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of Company; and (v) include activities to verify or maintain the quality or safety of a service or device that is owned by or controlled by, Company, and to improve, upgrade, or enhance the service or device that is owned by, manufactured by, manufactured for, or controlled by, Company.

You also have the right opt-out of our sharing your Sensitive Personal Information with third parties, including any sensitive information from Category B (Personal information categories established by Applicable State Laws), Category C (Protected classification characteristics under Applicable State Laws), Category I (Professional or employment-related information), Category K (Inferences drawn from other personal information) and/or Category L (Sensitive Personal Information).

To exercise your right to limit our use of your Sensitive Personal Information and/or opt-out of our sharing your Sensitive Personal Information with third parties, please submit a verifiable Covered User request to us by either:

• Clicking here; 
• Calling us at: 888-841-4352;
• Emailing us at: privacy@aspen.edu; or
• Sending us U.S. Mail to: Aspen University, 4615 E. Elwood St., Suite 100, Phoenix, AZ 85040.

We endeavor to act on all such requests as soon as practicable, but in all cases within fifteen (15) business days of the receipt of your request.  Subject to the aforementioned fifteen (15) business day period, where we receive and confirm your verifiable opt-out request, we will cease using your Sensitive Personal Information/sharing your Sensitive Personal Information with third parties (and direct our service providers and contractors to do the same).

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past twelve (12) months. Once we receive and confirm your verifiable Covered User access/portability request, we will disclose to you:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we have shared that personal information.
• The specific pieces of personal information we collected about you (also called a data portability request).
• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
  • sales, identifying the personal information categories that each category of recipient purchased; and
  • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Subject to the time period allotted to comply with such requests, where we receive and confirm your verifiable Covered User deletion request, we will delete (and direct our service providers, contractors and third parties to whom we sold/shared your personal information, to delete) your personal information from our (their) records, unless an exception applies; provided, however, that in some cases, strictly for regulatory compliance purposes and to better evidence/honor opt-out/unsubscribe requests (and for no other purposes), we may retain certain items of your personal information on a de-identified and aggregated basis in such a manner that the data no longer identifies you.

We may deny your deletion request if retaining the information is necessary for us or our service providers, contractors and/or third parties to whom we sold/shared your personal information, to:

1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our obligations in connection with our contract with you.
2. Detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech rights, ensure the right of another Covered User to exercise their free speech rights or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.) or other similar state law.
6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
7. Enable solely internal uses that are reasonably aligned with Covered User expectations based on your relationship with us.
8. Comply with a legal obligation.
9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Right to Request Correction of Inaccurate Personal or Sensitive Personal Information

You have the right to request correction of inaccurate Personal Information and/or Sensitive Personal Information that we collect. Upon receiving a verifiable consumer request for correction, we will make commercially reasonable efforts to correct information identified as inaccurate.  Where we correct inaccurate Personal Information and/or Sensitive Personal Information, we shall instruct all service providers and/or contractors that maintain such Personal Information and/or Sensitive Personal Information in the course of providing services to us to make the necessary corrections in their respective systems.

Exercising Access, Data Portability, Right to Correct and Deletion Rights

To exercise your access, data portability, right to correct and/or deletion rights described above, please submit a verifiable Covered User request to us by either:

• Clicking here;
• Calling us at: 888-841-4352;
• Emailing us at: privacy@aspen.edu; or
• Sending us U.S. Mail to: Aspen University, 4615 E. Elwood St., Suite 100, Phoenix, AZ 85040​.

The verifiable Covered User access, data portability, right to correct and/or deletion rights request must:

• Provide sufficient information that allows us to reasonably 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 that the personal information relates to you.  Making a verifiable Covered User request does not require you to create an account with us.  We will only use personal information provided in a verifiable Covered User request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We endeavor to respond to all verifiable Covered User access, data portability, right to correct and/or deletion rights requests within forty-five (45) days of the receipt thereof.  If we require more time (up to an additional forty-five (45) days), we will inform you of the reason and extension period in writing.  We will deliver our written response by mail or electronically, at your option.  Any disclosures we provide will only cover the twelve (12) month period preceding the receipt of your verifiable request.  The response we provide will also explain the reasons we cannot comply with a request, if applicable.  For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable Covered User request unless it is excessive, repetitive, or manifestly unfounded.  If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Right to Opt-Out of Profiling 

You have the right to opt-out from any Profiling that may be conducted by Company.  For purposes of these Provisions, “Profiling” means any form of automated processing performed on your personal data to evaluate, analyze or predict personal aspects related to you or your economic situation, health, personal preferences, interests, reliability, behavior, location or movements. You have the right to opt-out of our Profiling you. To exercise your right to opt-out of our Profiling you, please submit a verifiable Covered User request to us by either:

• Clicking here;
• Calling us at: 888-841-4352;
• Emailing us at: privacy@aspen.edu; or
• Sending us U.S. Mail to: Aspen University, 4615 E. Elwood St., Suite 100, Phoenix, AZ 85040.

We endeavor to act on all Profiling opt-out requests as soon as practicable, but in all cases within fifteen (15) days of the receipt of your request.

Right to Opt-Out of Targeted Advertising

You have the right to opt-out from Targeted Advertising conducted by Company.  For purposes of these Provisions, “Targeted Advertising” means displaying advertisements to you where the advertisements are selected based on personal data obtained from your activities over time and across nonaffiliated websites or online applications to predict your preferences or interests.  You have the right to opt-out from Targeted Advertising. To exercise your right to opt-out of our Targeted Advertising, please submit a verifiable Covered User request to us by either:

• Clicking here;
• Calling us at: 888-841-4352;
• Emailing us at: privacy@aspen.edu; or
• Sending us U.S. Mail to: Aspen University, 4615 E. Elwood St., Suite 100, Phoenix, AZ 85040.

We endeavor to act on all Targeted Advertising opt-out requests as soon as practicable, but in all cases within fifteen (15) days of the receipt of your request.

Authorized Agents

Covered Users may permit an Authorized Agent to exercise any rights granted under Applicable State Laws as set forth above.   In order to utilize an Authorized Agent, you must provide the Authorized Agent with written permission from you to act on your behalf for these purposes.  When you use an Authorized Agent to submit a request to delete, request to correct or a request to know, we may require the Authorized Agent to provide proof that you gave the agent signed permission to submit the subject request.  We may also require you to do either of the following: (a) verify your own identity directly with us; or (b) directly confirm with us that you provided the Authorized Agent permission to submit the request.  

For California residents, only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable Covered User request related to your personal information.

Non-Discrimination

We will not discriminate against you for exercising any of your rights under Applicable State Laws. Unless permitted by Applicable State Laws., we will not:

• Deny you courses, goods or services;
• Charge you different prices or rates for courses, goods or services, including through granting discounts or other benefits, or imposing penalties;
• Provide you a different level or quality of courses, goods or services;
• Retaliate against any employee, job applicant or independent contractor; and/or
• Suggest that you may receive a different price or rate for courses, goods or services or a different level or quality of goods or services.

Changes to these Privacy Provisions

We reserve the right to amend these Privacy Provisions in our discretion and at any time. When we make changes to these Privacy Provisions, we will notify you by email or through a notice on the Site’s homepage.

Contact Information

If you have any questions or comments about these Privacy Provisions, our Privacy Policy, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under Applicable State Laws., please do not hesitate to contact us by either:

• Calling us at: 888-841-4352;
• Emailing us at: privacy@aspen.edu; or
• Sending us U.S. Mail to: Aspen University, 4615 E. Elwood St., Suite 100, Phoenix, AZ 85040​.