Last revision: 23th July, 2019
1. Use Consent
2. A Note About Children
We do not intentionally gather Personal Data from visitors who are under the age of 18. If a child under 18 submits Personal Data to Company and we learn that the Personal Data is the information of a child under 18, we will attempt to delete the information as soon as possible. If you believe that we might have any Personal Data from a child under 18, please contact us at [email protected]
3. Types of Data We Collect
“Personal Data” means data that allows someone to identify or contact you, including, for example, your name, address, telephone number, e-mail address, as well as any other non-public information about you that is associated with or linked to any of the foregoing data.
“Anonymous Data” means data that is not associated with or linked to your Personal Data; Anonymous Data does not, by itself, permit the identification of individual persons. We collect Personal Data and Anonymous Data, as described below.
Information You Provide to Us
- We may collect Personal Data from you, such as your first and last name, gender, e-mail and mailing addresses, and password when you create an account to log in to our network (“Account”).
- If you use our Services on your mobile device, including through our Application, we may collect your phone number and the unique device id number.
- If you tell us where you are (e.g., by allowing your mobile device to send us your location), we may store and use that information to provide you with location-based information and advertising. If you want to deactivate this feature, you can either reinstall the Application or deactivate GPS on your mobile device.
- Our mobile homepage may let you store preferences like your location, safe search settings, and favorites. We may associate these choices with your ID or the mobile device, and you can edit these preferences at any time on our mobile homepage.
- When connecting to our Services via a service provider that uniquely identifies your mobile device, we may receive this identification and use it to offer extended services and/or functionality.
- Certain Services may require our collection of your phone number. We may associate that phone number to your mobile device identification information.
- When you order Services on our Application, we will collect all information necessary to complete the transaction, including your name, credit card information, billing information and shipping information.
- We retain information on your behalf, such as files and messages that you store using your Account.
- If you provide us feedback or contact us via e-mail, we will collect your name and e-mail address, as well as any other content included in the e-mail, in order to send you a reply.
- When you post content (text, images, photographs, messages, comments or any other kind of content that is not your e-mail address) on our Site, the information contained in your posting will be stored in our servers and other users will be able to see it, along with your profile photo and any other information that you choose to make public on your public profile page (“Profile”). The information that you provide in your Profile will be visible to others if you choose to activate your profile.
- When you post messages on the message boards of our Site, the information contained in your posting will be stored on our servers and other users will be able to see it.
- We also collect other types of Personal Data that you provide to us voluntarily, such as your operating system and version, product registration number, and other requested information if you contact us via e-mail regarding support for the Services.
- We may also collect Personal Data at other points in our Application that state that Personal Data is being collected.
Information You Provide to Facebook and other Social Networking Sites
Information Collected via Technology
- Information Collected by Our Servers: To make our Site, Application, and Services more useful to you, our servers (which may be hosted by a third party service provider) collect information from you, including your browser type, operating system, Internet Protocol (“IP”) address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), domain name, and/or a date/time stamp for your visit.
- Pixel Tags: In addition, we use “Pixel Tags” (also referred to as clear Gifs, Web beacons, or Web bugs). Pixel Tags are tiny graphic images with a unique identifier, similar in function to Cookies, that are used to track online movements of Web users. In contrast to Cookies, which are stored on a user’s computer hard drive, Pixel Tags are embedded invisibly in Web pages. Pixel Tags also allow us to send e-mail messages in a format users can read, and they tell us whether e-mails have been opened to ensure that we are sending only messages that are of interest to our users. We may use this information to reduce or eliminate messages sent to a user. We do not tie the information gathered by Pixel Tags to our users’ Personal Data.
- Mobile Services: We may also collect non-personal information from your mobile device if you have downloaded our Application. This information is generally used to help us deliver the most relevant information to you. Examples of information that may be collected and used include your geographic location, how you use the Application, and information about the type of device you use. In addition, in the event our Application crashes on your mobile device, we will receive information about your mobile device model software version and device carrier, which allows us to identify and fix bugs and otherwise improve the performance of our Application(s). This information is sent to us as aggregated information and is not traceable to any individual and cannot be used to identify an individual.
If you have enabled location services on your phone, we collect your location information to make a map available to the recipients of your messages showing your location. If you do not want this information collected by us, you can disable location services on your phone.
4. Use of Your Personal Data
Pedago uses Personal Data in furtherance of our legitimate interests in operating our Application, Site and Services. More specifically:
In general, Personal Data you submit to us is used either to respond to requests that you make, or to aid us in serving you better. We use your Personal Data in the following ways:
- facilitate the creation of and secure your Account on our network;
- identify you as a user in our system;
- provide improved administration of our Site and Services;
- provide the Services you request;
- improve the quality of experience when you interact with our Site and Services;
- send you a welcome e-mail to verify ownership of the e-mail address provided when your Account was created;
- send you administrative e-mail notifications, such as security or support and maintenance advisories;
- make telephone calls to you, from time to time, to solicit your feedback; and
- send newsletters, surveys, offers, and other promotional materials related to our Services and for other marketing purposes of Company.
User Testimonials and Feedback
We often receive testimonials and comments from users who have had positive experiences with our Services. We occasionally publish such content. When we publish this content, we may identify our users by their first and last name, and may also additional data such as their home city, professional experience, and education. We obtain the user’s consent prior to posting his or her name along with the testimonial. We may post user feedback on the Site from time to time. We will share your feedback with your first name and last initial only. If we choose to post your first and last name along with your feedback, we will obtain your consent prior to posting you name with your feedback. If you make any comments on a blog or forum associated with your Site, you should be aware that any Personal Data you submit there can be read, collected, or used by other users of these forums, and could be used to send you unsolicited messages. We are not responsible for the personally identifiable information you choose to submit in these blogs and forums.
Creation of Anonymous Data
We may create Anonymous Data records from Personal Data by excluding information (such as your name) that makes the data personally identifiable to you. We use this Anonymous Data to analyze request and usage patterns so that we may enhance the content of our Services and improve Site navigation. We reserve the right to use Anonymous Data for any purpose and disclose Anonymous Data to third parties in our sole discretion.
5. Disclosure of Your Personal Data
Third Parties Designated by You
When you use the Services, the Personal Data you provide will be shared with the third parties that you designate to receive such information, including other websites, your friends, relatives and business associates. Depending on the type of access you grant to such third parties, they may also be permitted to edit the information you have provided to us and to designate others to access and edit such information. You may change your settings at any time as to who has access to your information by going to your account settings and changing your publishing options.
We will share your Personal data with other Users solely for the purpose of providing the Services.
Third Party Service Providers
We may share your Personal Data with third party service providers to: provide you with the Services that we offer you through our Site; to conduct quality assurance testing; to facilitate creation of accounts; to provide technical support; and/or to provide other services to the Company. These third party service providers are required not to use your Personal Data other than to provide the services requested by Company.
Social Networking Sites
6. Third Party Websites
7. Your Choices Regarding Information
You have several choices regarding the use of information on our Service:
If you decide at any time that you no longer wish to accept Cookies from our Service for any of the purposes described above, then you can instruct your browser, by changing its settings, to stop accepting Cookies or to prompt you before accepting a Cookie from the websites you visit. Consult your browser’s technical information. If you do not accept Cookies, however, you may not be able to use all portions of the Service or all functionality of the Service. If you have any questions about how to disable or modify Cookies, please let us know at the contact information provided below.
If you decide at any time that you no longer wish to have your SNS account (e.g., Facebook) linked to your Account, then you may de-link the SNS account in the “preferences” section in your account settings. You may also manage the sharing of certain Personal Data with us when you connect with us through an SNS, such as through Facebook Connect. Please refer to the privacy settings of the SNS to determine how you may adjust our permissions and manage the interactivity between the Services and your social media account or mobile device.
Changing or Deleting Your Personal Data
You may change any of your Personal Data in your Account by editing your profile within your Account or by sending an e-mail to us at [email protected]. You may request deletion of your Personal Data by us, and we will use commercially reasonable efforts to honor your request, but please note that we may be required to keep such information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements). When we delete any information, it will be deleted from the active database, but may remain in our archives. We may also retain your information for fraud or similar purposes.
You can stop all collection of information by the Application by uninstalling the Application. You may use the standard uninstall processes as may be available as part of your mobile device or via the mobile application marketplace or network.
8. Security of Your Personal Data
- For online payments and/or Automated Clearing House (ACH) payouts, we use the payment services of Stripe (https://stripe.com). We do not process, record or maintain your credit card or bank account information. For more information on how payments are handled, or to understand the data security and privacy afforded such information, please refer to https://stripe.com/us/privacy.
- Company is committed to protecting the security of your Personal Data. We use a variety of industry-standard security technologies and procedures to help protect your Personal Data from unauthorized access, use, or disclosure. We also require you to enter a password to access your Account information. Please do not disclose your Account password to unauthorized people. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while Company uses reasonable efforts to protect your Personal Data, Company cannot guarantee its absolute security.
9. How will we use your identification document and transcripts/academic records?
- Students in our degree programs are asked to verify their identity upon matriculation.
- We partner with IDology, a leading provider of identity verification solutions. Through IDology’s hosted ID verification process, students are asked to scan a government-issued photo ID. It then asks the student to take a live photo of themselves. From there, IDology verifies the authenticity of the scanned documents and performs a facial comparison of the ID to the live photo. Scanned ID card images are deleted following identity verification.
- Students in our degree programs are asked to submit official transcripts for each degree program completed from all institutions they previously attended and listed on their application. We need to receive a transcript for every completed degree earned. These transcripts are reviewed for authenticity and verified against the student's application record. If a discrepancy is found in any submitted documents, the Institute will contact the student to rectify the discrepancy.
- Academic transcripts are securely kept in a separate authenticated filestore. Data access is limited to a restricted list of administrators, and document viewing is logged. Official transcripts are retained as a permanent part of a student's record.
- Note: prior to partnering with IDology, degree program students were asked to upload an image of their ID to verify their identity. These documents were used solely for identity verification and were not shared or sold to any third party. Once the student's identity was verified, the scanned ID was deleted.
10. EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield
Pedago has self-certified to the EU-U.S. and Swiss-U.S. Privacy Shield frameworks set forth by the U.S Department of Commerce with respect to collection, use and retention of Customer Data. For more information, see our Privacy Shield Notice. We may process some personal data from individuals or companies via other compliance mechanisms, including data processing agreements based on the EU Standard Contractual Clauses. To learn more about the Privacy Shield program, refer to https://www.privacyshield.gov/welcome.
11. A Note to Users Outside of the United States
Individuals located in certain countries, including the European Economic Area, have certain statutory rights in relation to their personal data. Subject to any exemptions provided by law, you may have the right to request access to Information, as well as to seek to update, delete or correct this Information. You can usually do this using the settings and tools provided in your account, or by contacting us at [email protected].
To the extent that Pedago's processing of your Personal Data is subject to the General Data Protection Regulation, Pedago relies on its legitimate interests, described above, to process your data. Pedago may also process Other Information that constitutes your Personal Data for direct marketing purposes and you have a right to object to Pedago's use of your Personal Data for this purpose at any time.
12. Questions; Contacting Company; Reporting Violations
3000 K St NW Ste 275
Washington, DC 20007
13. Data Protection Authority
VeraSafe has been appointed as Pedago's representative in the European Union for data protection matters, pursuant to Article 27 of the General Data Protection Regulation of the European Union. VeraSafe can be contacted in addition to [email protected], only on matters related to the processing of personal data. To make such an inquiry, please contact VeraSafe using this contact form: https://www.verasafe.com/privacy-services/contact-article27-representative
Alternatively, VeraSafe can be contacted at:
VeraSafe Ireland Ltd
Unit 3D North Point House
North Point Business Park
New Mallow Road
VeraSafe Czech Republic s.r.o
Prague 1, 11002