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Appendix A – California Specific Privacy Notice

Our California Specific Privacy Notice supplements the information in our Privacy Policy. The following material applies only to residents of California1. We have adopted this notice to comply with the California Consumer Privacy Act of 2018 ("CCPA"). Any terms defined in the CCPA have the same meaning when used in this notice. This notice does not apply to our privacy obligations under the Family Educational Rights and Privacy Act (FERPA) or other similar state laws. If at any time you have questions about this information, please contact privacymatters@careered.com or call toll-free (844)783-8627.

YOUR RIGHTS UNDER THE CCPA

Your Right to Request Disclosure of Personal Information Collected.

You have the right to request that we disclose personal information collected about you including the following:

  1. The categories of personal information collected.
  2. The categories of sources from which the personal information is collected.
  3. The business or commercial purpose for collecting or selling your personal information.
  4. The categories of third parties2 with whom we share your personal information.
  5. The specific pieces of personal information we have collected about you.

Your Right to Request Disclosure of Personal Information Sold3 or Disclosed for a Business Purpose.

You have the right to request that we disclose:

  1. The categories of personal information that we collected about you.
  2. The categories of personal information that we sold about you and the categories of third parties to whom the personal information was sold, by category or categories of personal information for each third party to whom your personal information was sold.
  3. The categories of personal information that were disclosed about you for a business purpose.

Your Right to Request Deletion of Personal Information Collected.

You have the right to request that we delete:

  1. Any of your personal information that we have collected and retained, and to direct our service provider(s) to delete your personal information, unless the personal information is necessary to:
    1. Complete the transaction for which the personal information was collected, provide a good or service requested by the consumer, or reasonably anticipated within the context of a business’s ongoing business relationship with the consumer, or otherwise perform a contract between the business and the consumer.
    2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity.
    3. Debug to identify and repair errors that impair existing intended functionality.
    4. Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law.
    5. Comply with the California Electronic Communications Privacy Act.4
    6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the businesses’ deletion of the information is likely to render impossible or seriously impair the achievement of such research, if the consumer has provided informed consent.
    7. Enable solely internal uses that are reasonably aligned with the expectations of the consumer based on the consumer’s relationship with the business.
    8. Comply with a legal obligation.
    9. Use the consumer’s personal information, internally, in a lawful manner that is compatible with the context in which the consumer provided the information.

Your Right to Opt-Out/Do Not Sell My Information. You have the right, at any time, to direct us not to sell your personal information to third parties, as defined under the CCPA. This is also referred to as your right to opt-out. A third party is not permitted to sell your personal information unless we have provided you with notice that your personal information may be sold and have been provided an opportunity to exercise your rights to opt-out.

You have the right to opt-out of sales, within the meaning of the CCPA, of certain information subject to the CCPA. You are not required to have an account with us to exercise your right to opt-out of the sale of your personal information to third parties. Please submit your request to privacymatters@careered.com. If you do not have an account, please include your name, address and e-mail address. You may also submit this request online by visiting the following site: DO NOT SELL MY PERSONAL INFOMATION

Our Platforms are meant for adults. We do not knowingly collect personally identifiable information from children under 13. If you are 16 years of age or older, under the CCPA, you have the right to direct us to not sell your personal information an any time (the right to opt-out). We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the right to opt-in) from either the consumer, who is between 13 and 16 years old, or the parent or legal guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time. Please submit your request to privacymatters@careered.com. If you do not have an account, please include your name, address and e-mail address. You may also submit this request online by visiting the following site: DO NOT SELL MY PERSONAL INFOMATION

If you would like to opt-out of behavioral advertising or certain tracking tools, please visit About Our Ads for more information.

If you would like to opt-out of marketing e-mails, you may click "UNSUBSCRIBE" on any marketing email. You may also contact privacymatters@careered.com

If you would like to opt-out of text messages you may respond to any text with the keyword “STOP” or “UNSUBSCRIBE”. You may also contact privacymatters@careered.com

If you would like to be added to our Do Not Call list, please call us and request to be added to the Do Not Call list or contact privacymatters@careered.com. We will accept your Do Not Call request by any reasonable method of communication such as e-mail, fax, text message, or mail.

Your Right to Nondiscrimination. We do not discriminate if you choose to opt-out or exercise any of your rights under the CCPA. This includes, but is not limited to (i) charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties, (ii) providing a different level or quality of goods or services, or (iii) suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services. If we offer you a financial incentive permitted under the CCPA and not prohibited by other applicable laws and regulations, we will notify you of the material terms of the incentive or incentive program. You will be given the opportunity to provide prior opt-in consent (which you may revoke at any time).

INFORMATION WE COLLECT

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, potential employee, employee, or device ("personal information")5.

We collect contact information. For example, we may collect your name and mailing address. This may include your zip code. We might also collect phone numbers and email addresses.

We collect application and tuition information. For example, we collect this information in your application for admission and financial aid. This includes Social Security number and date of birth. It also includes citizenship or military status. We may also collect information about other schools you have attended and income history. We might also collect your credit card or bank account number and billing address. For more information about how we treat education records and financial information, please view our FERPA Policy.

We collect information you post or submit. We collect information you post in a public space on our Platforms. This may include posts you make on course discussion boards or our social media pages. We may also collect your social media profile information. We might also collect the information you submit to us, such as through our live chat feature.

We collect job application information. If you apply for a job through our Platform, we collect the information you include in your application. For example, this may include the name and address of your employer and your employment history.

We collect job candidate and employee information. If you are a potential employee or an employee, we collect the information required for your employee file. For example, this may include your resume, tax forms, employee reviews, and copies of your driver’s license or passport.

We collect demographic information. We may collect your age and gender. We may also collect information about your race or ethnicity.

We collect device and location information. We collect the type and make of device you use to access our Platforms. We may also collect information about the browser you are using. We might look at what site you came from, or what site you visit when you leave us. We may collect information across the devices you use to access our Platform. If you use our app, we might look at how often you use the app and where you downloaded it. This might include your device identification number, IP address or mobile operating system.

CATEGORIES OF PERSONAL INFORMATION

We have collected the following categories (as enumerated in the CCPA) of personal information from consumers within the last twelve (12) months:

Category

Examples

Collected
(Yes or NO)

A. Identifiers.

A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.

YES

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.

YES

C. Protected classification characteristics under California or federal law.

Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

YES

D. Commercial information.

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

YES

E. Biometric information.

Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

NO

F. Internet or other similar network activity.

Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.

YES

G. Geolocation data.

Physical location or movements.

NO

H. Sensory data.

Audio, electronic, visual, thermal, olfactory, or similar information.

NO

I. Professional or employment-related information.

Current or past job history or performance evaluations.

YES

J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

YES

K. Inferences drawn from other personal information.

Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

YES

CATEGORIES OF SOURCES

We obtain the categories of personal information listed above from the following categories of sources:

  • Direct interactions. We collect personal information when you request information about our products and services or sign up for an event. We might also collect information when, for example, you sign up to receive communications from us. You may give us your information by filling in forms or by corresponding with us by email, phone, fax, mail or in-person. This includes, but is not limited to, personal data you provide when you:
    • Purchase our products or services or request information;
    • Discuss your interest in and/or your eligibility for our services with our staff, including but not limited to, personnel in Admissions, Academics, Financial Aid, Registrar’s Office, Student Advising, Faculty, Career Services or Student Accounts;
    • Apply for financial aid, scholarships, grants or other types of financial aid (e.g., military tuition assistance, employer tuition assistance, etc.).
    • Create or register for a user account on our website, virtual campus, mobile application or job/hiring information site;
    • Subscribe to our publications such as newsletters, alumni communications, career services information, investor updates or webinars;
    • Request marketing be sent to you such as by email, mail, phone, live chat or text messaging;
    • Interact with our website such as through our application center, FA calculator, live chat, or providing your contact information;
    • Interact with our social media pages, commenting on or liking posts;
    • Enter a competition, sweepstakes, or promotion;
    • Complete a survey or other assessment tool;
    • Provide information in-person at industry events, school events or other venues, or by phone, fax, online chat, text message, or email; or
    • Provide information or apply for a position on our job information website.
  • Automated technologies or interactions. As you interact with our website or mobile application, we may automatically collect data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We may also receive technical information about you if you visit other websites employing our cookies. Please see About Our Ads for further details.
  • Third parties or publicly available sources. We may receive personal information about you from various third parties and public sources.

USE OF YOUR PERSONAL INFORMATION

We may use and/or disclose the personal information we collect about you for one or more of the following business purposes:

  • We use your information to identify and authenticate. We use your information to verify when you access your account.
  • We use your information to communicate with you. This includes determining your eligibility for our services, maintaining or servicing your account, providing customer service, processing or fulfilling orders and transactions, verifying your information, processing payments, providing financial aid processing, providing advertising or marketing services, providing analytic services, collections activity, responding to your questions or inquiries or notifying you if you won a promotion. We will also use your information to send you information about your account or about our relationship. We may send push notifications to you from our mobile application, SMS text messaging services, or other similar services that you have opted into;
  • We use your information for marketing purposes. We may provide you with information about current or new products and services or other ads. We might use your information to serve you with ads. We may also have our service providers serve you with ads about our products and services. We may audit consumer transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions. We may engage in short-term, transient use of your personal information, provided your personal information is not disclosed to another third party and is not used to build a profile about you or otherwise alter your experience outside your current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction.
  • We use your information to understand your interests and improve our products and services. We may use your information to make our platform, products and services better. This may include improving student retention and user experience. We may also use your information to customize your experience with us. For example, we may use your information to determine your interest in our products and services or to better understand what products and services interest you.
  • We use your information for security purposes. This may include detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity. It may also include debugging to identify and repair errors that may impair our existing intended functionality, undertaking activities to verify, maintain, improve, upgrade or enhance the quality or safety of a service, device or system that we own, manufacture, manufacture for, or control.
  • We use your information for employee management purposes. This may include applicant and candidate evaluations or interviews. It may also include maintaining your employee file for work authorization, payment and salary records, and employee development such as reviews or disciplinary actions.
  • We use your information to support our mission, objectives and goals. We may conduct internal research for technological development and demonstration, conduct and analyze results of surveys, focus groups, interviews, employer feedback and other assessment measures.
  • We use your information as otherwise permitted or required by law, regulation, or as we may notify you. This may include protecting the rights, property or safety of our customers, job applicants, employees, shareholders or constituents; responding to law enforcement requests as required by applicable law, court order, or governmental regulations; evaluating and conducting a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, in which personal information held by us is among the assets transferred; or performing our obligations and enforcing our rights arising from any contracts entered into between you and us, including for billing and collections.

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

DISCLOSURE AND SALE OF PERSONAL INFORMATION

Category

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

In the preceding twelve (12) months, we have  “sold” the following categories of personal information (for both minors and non-minors).

A. Identifiers.

YES

NO (We do not sell information to third parties as defined under the CCPA).

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

YES

NO (We do not sell information to third parties as defined under the CCPA).

C. Protected classification characteristics under California or federal law.

YES

NO (We do not sell information to third parties as defined under the CCPA).

D. Commercial information.

YES

NO (We do not sell information to third parties as defined under the CCPA).

E. Biometric information.

NO

NO (We do not sell information to third parties as defined under the CCPA).

F. Internet or other similar network activity.

YES

NO (We do not sell information to third parties as defined under the CCPA).

G. Geolocation data.

NO

NO (We do not sell information to third parties as defined under the CCPA).

H. Sensory data.

NO

NO (We do not sell information to third parties as defined under the CCPA).

I. Professional or employment-related information.

YES

NO (We do not sell information to third parties as defined under the CCPA).

J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

YES

NO (We do not sell information to third parties as defined under the CCPA).

K. Inferences drawn from other personal information.

YES

NO (We do not sell information to third parties as defined under the CCPA).

CATEGORIES OF THIRD PARTIES

  1. We may disclose your personal information for a business purpose to the following categories of third parties:
    • Entities owned in whole or in part by us or our parent company and/or its shareholders.
    • Government agencies, regulators, accreditors, law enforcement and other authorities entitled to such personal information pursuant to law or regulation.
    • Authorized distributors of our organizations products and/or services.
    • A third party with a legitimate educational interest pursuant to FERPA or similar applicable state regulation.
    • Service providers fulfilling a business purpose for us such as:
      • Professional advisers including, but not limited to, auditors, bankers, insurers, legal counsel and professional subject matter experts.
      • Organizations we contract with for articulation (e.g., transfer of credit agreements) and affiliation purposes (e.g., internship/externship agreements).
      • Organizations we contract with for employee benefit purposes.
      • Background check providers for job candidates and/or students.

SUBMITTING A REQUEST

To exercise your access, disclosure, and deletion rights, as a California resident, you must submit a verifiable consumer request to us. We have outlined the procedure below.

1. You may submit your request6 online at: Privacy Data Request. This is the most efficient way to make your request. You may also contact us via our toll-free number (844) 783-8627 or at privacymatters@careered.com.

2. You will be asked to provide certain personal information that we will review against our records to validate your identity.

We require this personal information to prevent identity theft or fraud, and in some cases we may need to contact you for additional information or clarification to comply with your request. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. We will only use personal information provided to verify your identity or the requestor’s authority to make the request.

3. We will respond to a verifiable consumer request within forty-five (45) days of its receipt.

If we require additional time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or e-mail, per your preference.

4. For a disclosure request, once we receive and confirm your verifiable consumer request, we will provide you with:

  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting that personal information.
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we collected about you in the previous twelve (12) months.
  • If we disclosed your personal information for a business purpose, the personal information categories that each recipient was provided.
  • You are permitted to make two (2) disclosure requests in a 12-month period.

5. For a deletion request, once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exemption(s) applies.

If any exemption to your deletion request applies, we will provide a written response of the applicable CCPA deletion exemption(s) and how it applies to your personal information.

6. For disclosure requests, we will provide your personal information in a format that is readily useable and can be transmitted to another organization or business without difficulty.

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

HOW TO CONTACT US

If you have any questions about our privacy practices contact us at privacymatters@careered.com or by telephone at 847-781-3600. You may also write to us at the following address:

Career Education Corporation
Attn: Privacy Matters
231 N. Martingale Road
Schaumburg, IL 60173

1 A California resident, referred to as a Consumer, is anyone who meets the definition of resident as defined under the California Tax provisions. (Section 17014 of Title18 of the California Code of Regulations).
2 Under the CCPA, the term “third party” is limited to a person who is not any of the following: 1.The business that collects personal information from consumers under this title. 2. A person to whom the business discloses a consumer’s personal information for a business purpose pursuant to a written contract.
3 Our organization does not sell personal information for monetary gain. The CCPA defines “Sell,” “selling,” “sale,” or “sold,” as meaning selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to another business or a third party for monetary or other valuable consideration.
4 Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code.
5 Personal information does not include: • Publicly available information from government records.
• De-identified or aggregated consumer information.
• Information excluded from the CCPA's scope, like: - health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; • Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.
6 Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.