Career Core
Privacy Policy

Kaplan North America, LLC (“Kaplan,” “we” or “us”), a leader in online education, provides support services (“Services”) to schools and various organizations (“Organizations”) to enhance the careers of their students or members. This privacy policy explains how we use, share and protect your personally identifying information when you access the Service.

EU/UK Residents: If you are a resident of the EU or the UK, you have additional privacy rights, which are here.

California Residents: If you are a resident of the State of California you have additional privacy rights, which are here.

Information We Collect: Personal Data is any information about an individual from which that individual can be identified. Your name, address and phone number are examples of Personal Data. We collect Personal Data that you choose to provide to us. For example, we collect Personal Data when you visit careercore.org or another of our websites (“Sites”). We also collect Personal Data when you submit a form requesting additional information, enroll and/or participate in the Service, answer surveys, or participate in our social media communities. The Service is hosted by Instructure, Inc. (“Canvas”) and, in order to access the Services, you will have to agree to their privacy policies as well as ours. Please review the Canvas privacy policy, here, to understand their practices.

When you visit the Sites or interact with emails that we send to you, we may passively collect information from you and store that information on our server logs, including your internet protocol address (“IP address”), browser type, operating system, device identifier, device model, software version, or mobile or ISP carrier information. We also use Cookies and other technologies to collect information about your visit to the Sites, such as the date and time of your visit, the information you searched to find the Sites, or your activity on the Sites. “Cookies” are small files which may be stored on your computer during your use of the Sites and contain data about your use of the Sites. We may use session Cookies (which expire when you close your browser) or persistent Cookies (which stay on your computer until you delete them). We and our service providers may also use so-called "pixel tags", "web beacons", "clear GIFs" or similar means (collectively, "Pixel Tags") in connection with some Site pages and HTML-formatted email messages to, among other things, compile aggregate statistics about Site usage and response rates. A pixel tag is an electronic image, often a single pixel (1x1), that is ordinarily not visible to Site visitors and may be associated with cookies on the visitors’ hard drives. Pixel Tags allow us to count users who have visited certain pages of the Site, to deliver branded services, and to target our promotional or advertising campaigns and determine their effectiveness.

If an Organization or other third-party enrolls you in or otherwise requests ability for you to use the Service, such third parties may provide us with Personal Data about you, including your first name, last name and email address. We may also collect Personal Data about you from our business partners and third parties.

Use of Your Personal Data: We may use your Personal Data in the following ways and in accordance with applicable laws:

• For the purpose we received your Personal Data, for example to enroll you in or add you as a user to the Service or respond to a specific inquiry;
• To allow you access to the Service and to post content and communicate with others;
• To customize and personalize your experience to you;
• To administer, support, improve and develop our business;
• To send you information about the Service;
• To send you information about other programs that may be of interest to you on behalf of our university partners;
• To send you information about Kaplan products and services that may be of interest to you;
• To deliver advertising to you through our trusted third party service providers, such as Facebook Custom Audiences or other similar business tools;
• And as otherwise described to you at the point of collection.

Sharing Your Personal Data: We may share your Personal Data with:

• Authorized service providers, such as Canvas, that perform certain services on our behalf (e.g. processing credit card payments, delivering packages, providing customer service and marketing assistance, performing business and sales analysis, supporting our website functionality, and supporting surveys and other features offered through our website);
• The businesses or organizations with which we partner to offer you programs, products and services, including the Services, such as other Kaplan companies and your Organization;
• Government agencies, courts of law and law enforcement in connection with a subpoena or similar investigative demand, a court order, or a request for cooperation; or to establish or exercise our legal rights or defend against legal claims or as otherwise required by law;
• Others known to you, such as a family member, employer or other organization that have paid for your access to the Services.

Additional Disclosure: We may also disclose Personal Data in connection with a substantial corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy. Additionally, we may share anonymous, aggregated or de-identified data with third parties.

Mobile Devices, Phone Calls and SMS: If you provide us with a telephone number if prompted by the Site and consent to be contacted at that number, we may contact you by telephone and/or text message utilizing automated technology at such telephone number(s). You understand that this consent is not required to purchase goods or services from us.

Your Ability to Choose: If you do not wish to continue receiving emails from us about the Services, you may unsubscribe by clicking on the unsubscribe link in our emails and following directions. If you do not wish to continue receiving SMS messages from us, you may stop messages by replying “STOP” to any message. You may also direct us to stop marketing to you by emailing us at support@careercore.org.

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

Security and Information Retention: We employ security measures to protect your information both online and offline from access by unauthorized persons and against unlawful processing, accidental loss, destruction and damage. The Personal Data we obtain from students allows Kaplan to deliver smarter, more efficient and more effective instruction.

Third Party Websites: You may be able to link from the Site to third party websites and third party web sites may link to the Site ("Linked Sites"). This Privacy Policy governs collection and use of Personal Data by Kaplan. This Privacy Policy does not apply to Linked Sites, and Kaplan makes no representation about their data practices or policies.

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

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

By email: ktplegaldept@kaplan.com

Rev. January 2022

CALIFORNIA ADDENDUM

This Privacy Policy Addendum supplements the privacy policy at careercore.org and describes additional rights of residents of the State of California.

Persons with disabilities may obtain this notice in alternative format upon request by contacting us at privacy.universitypartners@kaplan.com or calling (877) 881-7313.

Your California Privacy Rights. California residents are entitled once a year, free of charge, to request and obtain certain information regarding our disclosure, if any, of certain categories of personal information to third parties for their direct marketing purposes in the preceding calendar year. We do not share personal information with third parties for their own direct marketing purposes.

California Consumer Privacy Act:

The California Consumer Privacy Act (“CCPA”) provides California residents with rights, upon a verifiable consumer request, to receive certain disclosures regarding the collection, use, and sharing of “Personal Information,” as well as rights to know/access, delete, and limit sharing of Personal Information. The CCPA defines “Personal Information” to mean “information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.” Certain information we collect may be exempt from the CCPA because it is considered public information (i.e., it is made available by a government entity) or covered by a specific federal privacy law, such as the Gramm–Leach–Bliley Act, the Health Insurance Portability and Accountability Act, or the Fair Credit Reporting Act.

To the extent that we collect Personal Information that is subject to the CCPA, that information, our practices, and your rights are described below.

Right to Notice at Collection Regarding the Categories of Personal Information Collected: You have the right to receive notice of the categories of Personal Information we collect, and the purposes for which those categories of Personal Information will be used. This notice should be provided at or before the time of collection. The categories we use to describe the information are those enumerated in the CCPA.

Identifiers: We collect your name, phone number, contact address and e-mail address when you engage with our website. We use this information to manage and provide the Services that you request, respond to your requests, and to communicate with you about the Services. We collect your social media handle when you interact with our Services through social media. We use this information to improve the user experience and our Service.

Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)): In addition to the identifiers in the above section, we collect your credit card number to provide you with requested Services.

Internet or other similar network activity. We automatically collect information about your browsing history and your interaction with the content of our Services to measure activity, determine the effectiveness of our Services, and improve them.

Sensory Data: We collect your audio or voice recordings to provide you with Services.

We may use any of the categories of information listed above for other business or operational purposes compatible with the context in which the Personal Information was collected.

We may share any of the above-listed information with Service Providers, as described above. Service Providers are restricted from using Personal Information for any purpose that is not related to our engagement. The types of Service Providers with whom we share information and the services they provide are described in the Privacy Policy section titled “Disclosure of Your Personal Data.”

We do not sell personal information and in the preceding twelve (12) months, we have not sold any personal information.

Right to Know/Access Personal Information: You have the right to request access to Personal Information collected about you over the past 12 months and information regarding the source of that information, the purposes for which we collect it, and the third parties and service providers with whom we share it. You may submit such a request as described below. To protect our users’ Personal Information, we are required to verify your identity before we can act on your request.

Right to Request Deletion of Personal Information: You have the right to request in certain circumstances that we delete any Personal Information that we have collected directly from you. You may submit such a request as described below. To protect our users’ Personal Information, we are required to verify your identity before we can act on your request. We may have a reason under the law why we do not have to comply with your request, or why we may comply with it in a more limited way than you anticipated. If we do, we will explain that to you in our response.

How to Submit a Request: You may submit a request to exercise your rights to know/access or delete your Personal Information through any of the following means:

1. By filling out a Consumer Data Request Form available here.
2. By sending us an email at privacy.universitypartners@kaplan.com
3. By calling us at (877) 881-7313.

Only you or your authorized agent may make a verifiable consumer request related to your personal information. If you use an authorized agent to submit a request on your behalf, we may require that you (1) provide the authorized agent written permission to do so, and (2) provide a copy of the authorization or provide a copy of a power of attorney that complies with California Probate Code sections 4000 to 4465 so that we can verify the identity of the authorized agent.

In verifying requests, we employ reasonable measures to detect fraudulent requests and prevent unauthorized access to your personal information. To meet our obligations, we are required to verify your identity, and the identity of your authorized agent, if the request is submitted via an agent, by associating the information provided in your request to personal information previously collected by us.

If we suspect fraudulent or malicious activity on or from the password-protected account, we may decline a request or request that you provide further verifying information.

You may only make a verifiable consumer request twice within a 12-month period. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify your identity or authority to make the request.

Right to Opt Out of Sale of Personal Information to Third Parties: You have the right to opt out of any sale of your Personal Information by Kaplan to third parties. We do not sell information to third parties.

Right to Information Regarding Participation in Data Sharing for Financial Incentives: You have the right to be free from discrimination based on your exercise of your CCPA rights. We do not discriminate against anyone who chooses to exercise their CCPA rights.

Rev. January 2022

EU/UK ADDENDUM

This Privacy Policy Addendum supplements the Privacy Policy at careercore.org and describes additional rights of residents of the European Union (EU) or United Kingdom (UK).

Data Protection Officer: We have appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this privacy policy.

Email: privacy.universitypartners@kaplan.com

If you are an EU national or resident in an EU country, and wish to contact our EU Representative: Kaplan Ireland Education Limited, 13/14 Aungier Street, Dublin 2, D02 WC04 Ireland

If you are a UK national or resident in the UK, and wish to contact our UK Representative: Kaplan UK Limited, UK Data Protection Representative, Palace House, 3 Cathedral St, London SE1 9DE, England

If you are located in the EU, EEA, Switzerland or UK you have the right to lodge a complaint with an EU or the UK Supervisory Authority. We would, however, appreciate the opportunity to address your concerns before you approach the ICO, so please contact us in the first instance.

Our storage and retention of your Personal Data:

We will only retain your Personal Data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements. To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements. Please contact us at privacy.universitypartners@kaplan.com if you would like more information.

It is important that the Personal Data we hold about you is accurate and current. Please keep us informed if your Personal Data changes during your working relationship with us.

In some circumstances we may anonymise your Personal Data so that it can no longer be associated with you, in which case we may use such information without further notice to you.

Your rights as a data subject:

Under certain circumstances, by law you have the right to:

• Request access to your Personal Data (commonly known as a "data subject access request"). This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.
• Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have exercised your right to object to processing (see below).
• Object to processing of your Personal Data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your Personal Data for direct marketing purposes.
• Request the restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of Personal Data about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your Personal Data to another party.

If you want to review, verify, correct or request erasure of your Personal Data, object to the processing of your Personal Data, or request that we transfer a copy of your Personal Data to another party, please contact us at privacy.universitypartners@kaplan.com

What we may need from you:

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it.

No fee usually required:

You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

Your right to withdraw consent:

In circumstances where you may have provided your consent to the collection, processing and transfer of your Personal Data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. You have the right to withdraw consent to marketing by following the opt-out links on any marketing message. To withdraw your consent for another circumstance, please contact us at privacy.universitypartners@kaplan.com. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

Rev. January 2022