addarrow-leftasset-discussionasset-fileasset-linkasset-markdownasset-scormasset-taskasset-videoArtboardasset-workspace_markdowncheckcheckboxcheckbox-checkedclosedashboarddeletediscussiondownloaddrag-handleeditemailface-happyface-neutralface-sadfullscreenhelpinfoArtboardlocationmenuplusicon/pointerprogressquotessettingssign-outstatus-defaultstatus-donestatus-pendingstatus-progresstimemenuupcominguploaduserwarningasset-webinar

Privacy and Data Protection

Updated 25 May 2018

The purpose of this Privacy Policy is to summarize how Humentum, a United States not-for-profit hosting the Gateway Academy, ("Gateway Academy," "us," "we," or "our") collects, uses and shares Personally Identifiable Information "PII" (as defined below) about you through our U.S. online interfaces (e.g., websites, the mobile versions thereof, and any mobile applications) owned and controlled by us, including, but not limited to, www.Gateway.Academy (collectively referred to herein as the "Site"). Please read this notice carefully to understand what we do. If you do not understand any aspects of our Privacy Policy, please feel free to contact us at privacy@gateway.academy. Your use of our Site is also governed by our Terms of Use.

Controller

Humentum is the controller and responsible for individuals’ personal data (collectively referred to as Humentum, "we", "us" or "our" in this Privacy Policy). We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this Privacy Policy, please contact the DPO using the details set out below.

Contact details

Full name of legal entity: Humentum, Inc.
Email address: privacy@gateway.academy
Postal address: 1120 20th NW, Suite 520, Washington DC 20036 USA

Individuals have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

What Information this Privacy Policy Covers

This Privacy Policy covers information we collect from you through our Site. Some of our Site’s functionality can be used without revealing any PII, though for features or services related to the online courses on the Site, certain PII is required. If you do not use these specific features or services on the Site, then the only information we collect will be "Non-Personal Information" (i.e., information that cannot be used to identify you). Non-Personal Information includes, but is not limited to, information such as the web pages that you have viewed. In order to access certain features and benefits on our Site, you may need to submit "Personally Identifiable Information" (i.e., information that can be used to identify you)(also referenced herein as “PII”). PII can include information such as your name and email address, among other things. You are responsible for ensuring the accuracy of the PII you submit to us. Inaccurate information may affect your ability to use the Site, the information you receive when using the Site, and our ability to contact you. For example, your email address should be kept current because that is one of the primary manners in which we communicate with you.

What You Consent to by Using Our Site

Please understand that by submitting any PII to us, you consent and agree that we may collect, use and disclose such PII in accordance with this Privacy Policy and our Terms of Use, and as permitted or required by law. If you do not agree with these terms, then please do not provide any PII to us. If you refuse or withdraw your consent, or if you choose not to provide us with any required PII, we may not be able to provide you with the services that can be offered on our Site.

What Information We Collect

We gather two types of information about users through the Site:

Non-Personal Information. When users come to our Site, we may track, collect and aggregate Non-Personal Information indicating, among other things, which pages of our Site were visited, the order in which they were visited, when they were visited, and which hyperlinks were "clicked." We also collect information from the URLs from which you linked to our Site. Collecting such information may involve logging the IP address, operating system and browser software used by each user of the Site. Although such information is not PII, we may be able to determine from an IP address a user’s Internet Service Provider and the geographic location of his or her point of connectivity.

We also use or may use cookies and/or web beacons to help us determine and identify repeat visitors, the type of content and sites to which a user of our Site links, the length of time each user spends at any particular area of our Site, and the specific functionalities that users choose to use. Essentially, cookies are a user’s identification card for the Gateway Academy servers. Web beacons are small graphic files linked to our servers that allow us to track your use of our Site and related functionalities. Cookies and web beacons allow us to serve you better and more efficiently, and to personalize your experience at our Site. Cookies and web beacons are not used to retain PII. From time to time we may also use additional typical methods of collecting data.

You can control how and whether cookies will be accepted by your web browser. Most browsers offer instructions on how to reset the browser to reject cookies in the "Help" section of the toolbar. If you reject our cookies, many functions and conveniences of this Site may not work properly.

Personally Identifiable Information. We collect PII including, but not limited to your name and email address, that you provide to us when you register for an account, update or change information for your account, receive an update, register for courses, complete a survey, sign-up for email updates or Online Courses, participate in our public forums, send us email messages or otherwise communicate with us, participate in Online Courses or other services on our Site, submit surveys to us, and access a third-party website from the Site. If you participate in an online course, we may collect from you certain student-generated content, such as assignments you submit to instructors, peer-reviewed assignments and peer student feedback. We also collect course data, such as student responses to quizzes and exams. We may use the PII that you provide to respond to your questions, provide you the specific course and/or services you select, send you updates about online courses offered on the Gateway Academy or other Gateway Academy events, and send you email messages about Site maintenance or updates.

Partner sites providing online course related tools and services to Gateway Academy users may collect non-financial individual level user data regarding the individual’s use of that partner site while engaged with such Online Course related activities, and the partner sites may share that data with us for the purpose of improving our services, the partner site’s services, and the individual’s education experience. This data includes information such as the amount of time spent on the partner site and pages viewed.

Third Party Credit Card Processing. We may provide you with the ability to pay for online courses and other services using a credit card through a third party payment processing service provider. Please note that our service provider – not Humentum – collects and processes your credit card information.

How We Use the Information

Non-Personal Information. We use Non-Personal Information to build higher quality, more useful services by performing statistical analyses of the collective characteristics and behavior of our users, and by measuring demographics and interests regarding specific areas of our Site. We may also use it for other business purposes.

Personally Identifiable Information. Except as set forth in this Privacy Policy or as specifically agreed to by you, we will not disclose any PII we gather from you on the Site. In addition to the other uses set forth in this Privacy Policy, we may disclose and otherwise use PII as described below. We may also use it for research and business purposes, including improving and customizing the Site and the products and services we offer.

Updates. We use PII collected when you sign-up for our various email or update services to send you the messages in connection with the Site or an online course. We may also archive this information and/or use it for future communications with you.

Forums. We may offer public forums from time to time (the "Forums") where you can share comments and thoughts about the content of an online course. To facilitate your use of the Forums, we use PII collected during your use of the Forums. In addition, we may publish this information via extensions of our platform that use third-party services, like mobile applications. We also reserve the right to reuse Forum posts containing PII in future versions of the courses we offer, and to enhance future course offerings. We may archive this information and/or use it for future communications with you and/or your designee(s), and/or provide it to the university or the instructor(s) associated with the courses you have taken. We may also use or publish posts submitted on the Forums without using Personally Identification Information.

Participation in Online Courses. We use the PII that we collect from you when you participate in an online course through the Site for processing purposes, including but not limited to tracking attendance, progress and completion of an online course. Also, we may archive this information and/or use it for future communications with you.

Communications with Gateway Academy. When you send us an email message or otherwise contact us, we may use the information provided by you to respond to your communication and/or as described in this Privacy Policy. We may also archive this information and/or use it for

Research. We may share general course data (including quiz or assignment submissions, grades, and forum discussions), information about your activity on our Site, and demographic data from surveys operated by us with our Gateway Academy Providers and other business partners so that our Gateway Academy Providers and other business partners may use the data for research related to online learning.

Government Authorities, Legal Rights and Actions. Gateway Academy may share your PII with various government authorities in response to subpoenas, court orders, or other legal process; to establish or exercise our legal rights or to protect our property; to defend against legal claims; or as otherwise required by law. In such cases we reserve the right to raise or waive any legal objection or right available to us. We also may share your PII when we believe it is appropriate to investigate, prevent, or take action regarding illegal or suspected illegal activities; to protect and defend the rights, property, or safety of Humentum, the Site, our users, customers, or others; and in connection with our Terms of Use and other agreements.

Disclosure to Acquirers. Humentum may disclose and/or transfer your PII to an acquirer, assignee or other successor entity in connection with a sale, merger, or reorganization of all or substantially all of the equity, business or assets of Humentum to which your PII relates.

Data Shared with Third Parties

Other students and Instructors: For our online courses, depending on your settings, your shared content and profile data may be publicly viewable, including to other students and instructors.

We may also share your PII and your performance in a given online course with the instructor or instructors who taught the course, with teaching assistants or other individuals designated by the instructor or instructors to assist with the creation, modification or operation of the course, and with the organizations sponsoring the online course on the Site (“Gateway Academy Providers”) with which they are affiliated.

If you enrolled through your employer, we may also share PII that we collect with your employer. Also, we may archive this information and/or use it for future communications with you.

With Service Providers, Contractors, and Agents: We use various service providers, vendors and contractors (collectively, "Contractors") to assist us in providing our products and services to you. Our Contractors may have limited access to your PII in the course of providing their products or services to us, so that we in turn can provide our products and services to you. These Contractors may include vendors and suppliers that provide us with technology, services, and/or content related to the operation and maintenance of the Site or the online course. Access to your PII by these contractors is limited to the information reasonably necessary for the contractor to perform its limited function for us.

External Links

For your convenience we may provide links to sites operated by organizations other than Gateway Academy ("Third Party Sites") that we believe may be of interest to you. We do not disclose your PII to these Third Party Sites without obtaining your consent. We do not endorse and are not responsible for the privacy practices of these Third Party Sites. If you choose to click on a link to one of these Third Party Sites, you should review the privacy policy posted on the other site to understand how that Third Party Site collects and uses your PII.

Confidentiality & Security of PII

We will use industry standard physical, technical and administrative security measures to keep your PII confidential and secure. Because the Internet is not a 100% secure environment, however, we cannot guarantee the security of PII, and there is some risk that an unauthorized third party may find a way to circumvent our security systems or that transmission of your information over the Internet will be intercepted. It is your responsibility to protect the security of your login information. Please note that e-mails and other communications you send to us through our Site are not encrypted.

Your Legal Rights

Under data protection laws in relation to your PII, you have the right to:

  • Request access to your personal data
  • Request correction of your personal data.
  • Request erasure of your personal data.
  • Object to processing of your personal data.
  • Request restriction of processing your personal data.
  • Request transfer of your personal data.
  • Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us via privacy@gateway.academy.

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 is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

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 your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Opting out You can ask us to stop sending you marketing messages at any time by logging into your account, checking or unchecking relevant boxes to adjust your marketing preferences, or by following the opt-out links on any marketing message sent to you or by contacting us at any time.

What About Children?

We care about the safety of children on its Site and encourages parents and guardians to monitor their children’s use of the Internet. Although the Site is suitable for a general audience, the Site is intended for use only by users who are over eighteen (18) years of age. Accordingly, we do not knowingly solicit PII from children or send them requests for personal information. If you become aware that your child has provided PII to us, please contact us immediately so that such information can be deleted and we otherwise discontinue any further services provided to such child.

International Privacy Practices

The Gateway Academy Site is primarily operated and managed on servers located and operated within the United States. For residents located in the European Economic Area, we may transfer your data outside the European Economic Area (EEA). Whenever we transfer your personal data outside of the EEA, we ensure a similar degree of protection by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
  • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
  • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.

Cookies

We use cookies when you visit certain pages online to record your preferences to enable us to improve services for you. We may also use cookies to monitor traffic and improve the Site. However, if you wish to restrict or block the cookies which are set by the Gateway Academy website, you can do this through your browser settings.
This website is functional without the retention of cookies, but please be aware that restricting cookies may impact on the functionality of the website. For more information about the cookies we use, please contact us.

Governing Law

This Privacy Policy shall be governed by and construed in accordance with the laws of the State of New York, U.S.A. If any part of this Privacy Policy is determined to be invalid or unenforceable pursuant to applicable law, then the invalid or unenforceable provision or part will be deemed suspended by a valid, enforceable provision that most closely matches the intent of the original provision or part and the remainder of this Privacy Policy shall continue in full force and effect.

Changing Our Privacy Policy

Please note that we review our privacy practices from time to time, and that these practices are subject to change. Any change, update, or modification will be effective immediately upon posting on our Site. We will notify you of any material change to this Privacy Policy by posting a notice on our Site’s homepage for a reasonable period of time following such update, and by changing the effective date (located at the bottom of this page). Be sure to return to this page periodically to ensure familiarity with the most current version of this Privacy Policy.