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Terms of Service

Terms of Service

Updated 9 June 2017

Welcome to Gateway Academy.

Please read these Terms of Service ("TOS") and the Gateway Academy Privacy Policy prior to registering for or using Gateway. Academy or using any portion of the Gateway Academy website (the "Site," which consists of all content and pages located within the Gateway. Academy web domain), including accessing any course material, chat rooms, or other electronic services. These TOS, and the Privacy Policy are agreements (the "Agreements") between you and Humentum, a United States not-for-profit hosting the Gateway Academy, ("Gateway Academy," "us," "we," or "our"). By using the Site, you accept and agree to be legally bound by the Agreements, whether or not you are a registered user. If you do not understand or do not wish to be bound by the terms of the Agreements, you should not use the Site.

Humentum reserves the right to modify these TOS at any time with notice. By accessing the Site after any changes have been made and following notice, you signify your agreement on a prospective basis to the modified TOS and all of the changes. Be sure to return to this page periodically to ensure familiarity with the most current version of these TOS.

DESCRIPTION OF GATEWAY ACADEMY

Gateway Academy is a digital learning platform that offers both online and blended learning courses, as well as cultivate communities of practice, focused on financial inclusion in Sub-Saharan Africa.

LICENSE GRANT

These TOS provide to you a personal, revocable, limited, non-exclusive, royalty-free, non-sublicenseable, non-transferable license to use the Site conditioned on your continued compliance with the terms and conditions of this TOS. You may print and download materials and information from the Site solely for your personal use, provided that all hard copies contain all copyright and other applicable notices contained in such materials and information.

RESTRICTIONS

Notwithstanding the foregoing, You may not modify, translate, decompile, create derivative work(s) of, copy, distribute, disassemble, broadcast, transmit, publish, remove or alter any proprietary notices or labels, license, sublicense, transfer, sell, mirror, frame, exploit, rent, lease, private label, grant a security interest in, or otherwise use in any manner not expressly permitted herein the Site.

TERM AND TERMINATION

These TOS will take effect the moment you register, respond to a request for information, and/or begin downloading, accessing, or using the Site, whichever is earliest. We reserves the right at any time and on reasonable grounds, which shall include, without limitation, any reasonable belief of fraudulent or unlawful activity or actions or omissions that violate any term or condition of these TOS, to deny you access to the Site or to any portion thereof in order to protect its name and goodwill, its business, and/or other users, and these TOS will also terminate automatically if you fail to comply with its terms and conditions, subject to the survival rights of certain provisions identified below. Termination will be effective without notice. You may also terminate these TOS at any time by ceasing to use the Site, but all applicable provisions of these TOS will survive termination, as identified below, and each re-access or use of the Site will reapply this TOS (then in effect) to you. Upon termination, you must destroy all copies of any aspect of the Site in your possession. The provisions concerning Humentum’s proprietary rights, disclaimers of warranty and liability, waiver and severability, entire agreement, and choice of law will survive the termination of this TOS for any reason.

RULES FOR ONLINE CONDUCT

You agree that you are responsible for your own use of the Site and for your User Postings. "User Postings" include all content submitted, posted, published or distributed on the Site by you or other users of the Site, including but not limited to all forum posts, document edits, notes, questions, comments, videos and file uploads. You agree that you will use the Site in compliance with these TOS, and all applicable local, state, national and international laws, rules and regulations, including copyright laws, any laws regarding the transmission of technical data exported from your country of residence, and all United States export control laws.

Our Site is not directed to individuals younger than 18 or the legal age of majority, whichever is greater, and access and use of our Site is only offered to users 18 years of age or the legal age of majority, whichever is older. If you are under 18 years old or the legal age of majority, please do not register to use our Site. Any person who registers as a user or provides their personal information to our Services represents that they are 18 years of age or older or the legal age of majority.

As a condition of your use of the Gateway Academy services, you will not use the Site in any manner intended to damage, disable, overburden or impair any Gateway Academy server or the network(s) connected to any Gateway Academy server or to interfere with any other party's use and enjoyment of the Site. You may not attempt to gain unauthorized access to the Site, other accounts, computer systems or networks connected to any Gateway Academy server through hacking, password mining or any other means. You may not obtain or attempt to obtain any materials or information stored on the Site, its servers or associated computers through any means not intentionally made available through the Site.

THE FOLLOWING LIST OF ITEMS IS STRICTLY PROHIBITED ON THE SITE:

  • Content that defames, harasses or threatens others;
  • Content that discusses illegal activities with the intent to commit them;
  • Content that infringes another's intellectual property, including, but not limited to, copyrights or trademarks;
  • Profane, pornographic, obscene, indecent or unlawful content;
  • Advertising or any form of commercial solicitation;
  • Content related to partisan political activities;
  • Viruses, trojan horses, worms, time bombs, corrupted files, malware, spyware or any other similar software that may damage the operation of another's computer or property; and
  • Content that contains intentionally inaccurate information or that is posted with the intent of misleading others.
  • Furthermore, you agree not to scrape, or otherwise download in bulk, any Site content, including but not limited to a list or directory of users on the system, on-line textbooks, User Postings or user information. You agree not to misrepresent or attempt to misrepresent your identity while using the Site.

You also aren't allowed to:

  • Do anything that violates local, state, national or international law or breaches any of your contractual obligations or fiduciary duties.
  • Share your password, let anyone access your account, or do anything that might put your account at risk.
  • Attempt to access any other user's account.
  • Reproduce, transfer, sell, resell, or otherwise misuse any content from our Site, unless specifically authorized to do so.
  • Access, tamper with, or use non-public areas of our systems, unless specifically authorized to do so.
  • Break or circumvent our authentication or security measures or otherwise test the vulnerability of our systems or networks, unless specifically authorized to do so.
  • Try to reverse engineer any portion of our Site.
  • Try to interfere with any user, host, or network, for example by sending a virus, overloading, spamming, or mail-bombing.
  • Use our site to distribute malware.
  • Impersonate or misrepresent your affiliation with any person or entity.
  • Encourage or help anyone do any of the things on this list.

USER ACCOUNTS AND AUTHORITY

In order to participate fully in Site activities, you must provide your name, email address and a user password in order to create a user account ("User Account"). You agree that you will never divulge or share access or access information for your User Account with any third party for any reason. In setting up your User Account, you may be prompted to enter additional optional information (e.g., your address). You represent that all information provided by you is accurate and current. You agree to maintain and update your information to keep it accurate and current.

We care about the confidentiality and security of your personal information. Please see our Privacy Policy for more information about what information we collect about you and how we use that information.

YOUR RIGHT TO USE CONTENT ON THE SITE

Unless expressly indicated as being in the public domain, the content on the Site is protected by United States and foreign copyright laws. Unless otherwise expressly stated on the Site, the instructional materials provided with the courses offered on this Site are for your personal use in connection with those courses only.

You agree to retain all copyright and other notices on any content you obtain from the Site. All rights in the Site and its content, if not expressly granted, are reserved.

You will have the ability to access and/or use content provided by instructors, other users, and/or other third parties and links to websites and services maintained by third parties. We cannot guarantee that such third party content, in the courses or elsewhere, will be free of material you may find objectionable or otherwise inappropriate or of malware or other contaminants that may harm your computer, mobile device, or any files therein. We disclaim any responsibility or liability related to your access or use of such third party content.

USER POSTINGS

User Postings Representations and Warranties. By submitting or distributing your User Postings, you affirm, represent and warrant (1) that you have the necessary rights, licenses, consents and/or permissions to reproduce and publish the User Postings and to authorize us to reproduce, modify, publish and otherwise use and distribute your User Postings in a manner consistent with the licenses granted by you below, and (2) that neither your submission of your User Postings nor the exercise of the licenses granted below will infringe or violate the rights of any third party. You, and not Humentum, are solely responsible for your User Postings and the consequences of posting or publishing them.

License Grant to Humentum. By submitting or distributing your User Postings, you hereby grant to Humentum a worldwide, non-exclusive, transferable, assignable, sub licensable, fully paid-up, royalty-free, perpetual, irrevocable right and license to host, transfer, display, perform, reproduce, modify, distribute, re-distribute, relicense and otherwise use, make available and exploit your User Postings, in whole or in part, in any form and in any media formats and through any media channels (now known or hereafter developed).

License Grant to Gateway Academy Users. By submitting or distributing your User Postings, you hereby grant to each user of the Site a non-exclusive license to access and use your User Postings in connection with their use of the Site for their own personal purposes.

TRADEMARKS/PROPRIETARY RIGHTS

Use of Gateway Academy and Training Provider Names, Trademarks and Service Marks. These TOS provide only a limited license to access and use the Site. Accordingly, you expressly acknowledge and agree that we transfer no ownership or intellectual property interest or title in and to the Site to you or anyone else. The "Gateway Academy," names, logos and seals are trademarks ("Trademarks") of the respective entities. Likewise, the names, logos, and seals of the other training providers offering courses (“Providers”) on the Site are Trademarks owned by the respective Provider. You may not use any of these Trademarks, or any variations thereof, without the owner's prior written consent. You may not use any of these Trademarks, or any variations thereof, for promotional purposes, or in any way that deliberately or inadvertently claims, suggests or, in these institutions' sole judgment, gives the appearance or impression of a relationship with or endorsement by these institutions.

All Trademarks not owned by Humentum or the Providers that appear on the Site or on or through the services made available on or through the Site, if any, are the property of their respective owners.

Nothing contained on the Site should be construed as granting, by implication, estoppel or otherwise, any license or right to use any Trademark displayed on the Site without the written permission of the owner of the applicable Trademark.

DIGITAL MILLENNIUM COPYRIGHT ACT

Copyright owners who believe their material has been infringed on the Site may request removal of the materials from the Site by submitting written notification to our Copyright Agent (as designated below) pursuant to the Digital Millennium Copyright Act (17 U.S.C. § 512 (“DCMA”).

NOTE TO HUMENTUM: Humentum must register a designated copyright agent with the Copyright Office. Venable can assist. Fee is nominal and process is simple.

Notification must include:

  • Identification of the copyrighted work, or, in the case of multiple works at the same location, a representative list of such works at that site.
  • Identification of the material that is claimed to be infringing or to be the subject of infringing activity. You must include sufficient information for us to locate the material (e.g., URL, IP address, computer name).
  • Information for us to be able to contact the complaining party (e.g., email address, phone number).
  • A statement that the complaining party believes in good faith that the use of the material has not been authorized by the copyright owner or an authorized agent.
  • A statement that the information in the notification is accurate and that the complaining party is authorized to act on behalf of the copyright owner.

The designated Copyright Agent to receive DCMA notice is:

Name
Address
info@gateway.academy

If you believe that your material was removed or access to it was disabled by mistake or misidentification, You may file a counter-notification with us (a "Counter-Notice") by submitting written notification to the the designated Copyright Agent. Pursuant to the DMCA, the Counter-Notice must include substantially the following:

  • Your physical or electronic signature.
  • An identification of the material that has been removed or to which access has been disabled and the location at which the material appeared before it was removed or access disabled.
  • Adequate information by which we can contact you (including your name, postal address, telephone number, and, if available, email address).
  • A statement under penalty of perjury by you that you have a good faith belief that the material identified above was removed or disabled as a result of a mistake or misidentification of the material to be removed or disabled.
  • A statement that you will consent to the jurisdiction of the Federal District Court for the judicial district in which your address is located (or if you reside outside the United States for any judicial district in which the Site may be found) and that you will accept service from the person (or an agent of that person) who provided the Site with the complaint at issue.

SECURITY

While we work to protect the security of your account and related information, we cannot guarantee that unauthorized third parties will not be able to defeat our security measures.

DISCLAIMERS OF WARRANTY / LIMITATIONS OF LIABILITIES

THE SITE AND ANY INFORMATION, CONTENT OR SERVICES MADE AVAILABLE ON OR THROUGH THE SITE ARE PROVIDED "AS IS" AND "AS AVAILABLE" WITHOUT WARRANTY OF ANY KIND (EXPRESS, IMPLIED OR OTHERWISE), INCLUDING, WITHOUT LIMITATION, ANY IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE AND NON-INFRINGEMENT, EXCEPT INSOFAR AS ANY SUCH IMPLIED WARRANTIES MAY NOT BE DISCLAIMED UNDER APPLICABLE LAW.

HUMENTUM AND THE GATEWAY ACADEMY PROVIDERS (AS HERINAFTER DEFINED) DO NOT WARRANT THAT THE SITE WILL OPERATE IN AN UNINTERRUPTED OR ERROR-FREE MANNER, THAT THE SITE IS FREE OF VIRUSES OR OTHER HARMFUL COMPONENTS, OR THAT THE COURSES OR CONTENT PROVIDED WILL MEET YOUR NEEDS OR EXPECTATIONS. HUMENTUM AND THE GATEWAY ACADEMY PROVIDERS ALSO MAKE NO WARRANTY ABOUT THE ACCURACY, COMPLETENESS, TIMELINESS, OR QUALITY OF THE SITE OR ANY COURSES OR CONTENT, OR THAT ANY PARTICULAR COURSES OR CONTENT WILL CONTINUE TO BE MADE AVAILABLE. “GATEWAY ACADEMY PROVIDERS” MEANS THE ENTITIES PROVIDING INFORMATION, CONTENT OR SERVICES FOR THE SITE, THE COURSE INSTRUCTORS AND THEIR STAFFS.

USE OF THE SITE, AND THE CONTENT AND SERVICES OBTAINED FROM OR THROUGH THE SITE, IS AT YOUR OWN RISK. YOUR ACCESS TO OR DOWNLOAD OF INFORMATION, MATERIALS OR DATA THROUGH THE SITE OR ANY REFERENCE SITES IS AT YOUR OWN DISCRETION AND RISK, AND YOU WILL BE SOLELY RESPONSIBLE FOR ANY DAMAGE TO YOUR PROPERTY (INCLUDING YOUR COMPUTER SYSTEM) OR LOSS OF DATA THAT RESULTS FROM THE DOWNLOAD OR USE OF SUCH MATERIAL OR DATA, UNLESS OTHERWISE EXPRESSLY PROVIDED FOR IN THE GATEWAY ACADEMY PRIVACY POLICY.

User Postings Disclaimer. You understand that when using the Site you will be exposed to User Postings from a variety of sources and that neither Humentum nor the Gateway Academy Providers are responsible for the accuracy, usefulness, reliability or intellectual property rights of or relating to such User Postings. You further understand and acknowledge that you may be exposed to User Postings that are inaccurate, offensive, defamatory, indecent or objectionable and you agree to waive, and hereby do waive, any legal or equitable rights or remedies you have or may have against us or any of the Gateway Academy Providers with respect thereto. Neither we nor any of the Gateway Academy Providers endorse any User Postings or any opinion, recommendation or advice expressed therein. Neither we nor any of the Gateway Academy Providers have any obligation to monitor any User Postings or any other user communications through the Site.

However, we reserve the right to review User Postings and to exercise its sole discretion to edit or remove, in whole or in part, any User Posting at any time and for any reason, or to allow the Gateway Academy Providers to do so. Without limiting the foregoing, upon receiving notice from a user or a content owner that a User Posting allegedly does not conform to these TOS, Gateway Academy may investigate the allegation and determine in its sole discretion whether to remove the User Posting, which it reserves the right to do at any time and without notice.

Links to Other Sites. The Site may include hyperlinks to sites maintained or controlled by others. We and the Gateway Academy Providers are not responsible for and do not routinely screen, approve, review or endorse the contents of or use of any of the products or services that may be offered at these sites. If you decide to access linked third-party websites, you do so at your own risk.

INDEMNIFICATION

You agree to defend, hold harmless and indemnify Humentum and the Gateway Academy Providers, and their respective subsidiaries, affiliates, officers, faculty, students, fellows, governing board members, agents and employees from and against any third-party claims, actions or demands arising out or resulting from your use of the Site in violation or breach of these TOS, including any liability or expense arising from any and all claims, losses, damages (actual and consequential), suits, judgments, litigation costs and attorneys' fees, of every kind and nature. In such a case, Humentum or one of the Gateway Academy Providers will provide you with written notice of such claim, suit or action.

MISCELLANEOUS

Termination Rights; Discontinuation of Courses and Content. You agree that Humentum, in its sole discretion, may terminate your use of the Site or your participation in it, for any reason or no reason, upon notice to you. It is our policy to terminate in appropriate circumstances the accounts of users of the Site who are repeat copyright infringers. Humentum and the Gateway Academy Providers reserve the right at any time in their sole discretion to cancel, delay, reschedule or alter the format of any course offered through Gateway Academy, or to cease providing any part or all of the Site content or related services, and you agree that neither we nor any of the Gateway Academy Providers will have any liability to you for such an action. If you no longer desire to participate in the Site, you may terminate your participation at any time. The rights granted to you hereunder will terminate upon any termination of your right to use the Site, but the other provisions of these TOS will survive any such termination.

Waiver and Severability of TOS. The failure of Humentum to exercise or enforce any right or provision of these TOS shall not constitute a waiver of such right or provision. If any provision of these TOS is found by a court of competent jurisdiction to be invalid, the parties nevertheless agree that the court should endeavor to give effect to the parties' intentions as reflected in the provision and the other provisions of these TOS shall remain in full force and effect.

Choice of Law/Forum Selection. You agree that these TOS and any claim or dispute arising out of or relating to these TOS or any content or service obtained from or through the Site will be governed by the laws of the State of New York in the United States, excluding its conflicts of law provisions. You agree that all such claims and disputes will be heard and resolved exclusively in the federal or state courts located in and serving New York. You consent to the personal jurisdiction of those courts over you for this purpose, and you waive and agree not to assert any objection to such proceedings in those courts (including any defense or objection of lack of proper jurisdiction or venue or inconvenience of forum).

Entire Agreement. These TOS and the Privacy Policy together constitute the entire agreement between you and Humentum with respect to your use of the Site, superseding any prior agreements between you and Humentum regarding your use of the Site.

Privacy Policy

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.