Full name of legal entity: Humentum, Inc.
Email address: firstname.lastname@example.org
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 You Consent to by Using 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.
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.
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.
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.
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.
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 email@example.com.
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.
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