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This Privacy Policy applies to Personal Information we collect from users of our Sites, Apps, Wi-Fi hotspots, and other online services, as well the Personal Information we collect about individuals, including current and prospective students, alumni, learners, visitors to our campuses, and others with whom we interact (e.g., Business-to-Business Representatives, as defined below), whether online, via phone, or offline in the course of providing our courses, programs, and services (collectively, our “Services”).

If you are an employee, contractor, or job applicant, then this Privacy Policy only applies to you when you are using our Services outside of those roles. If you are acting within your capacity as a current or former employee, contractor, or job applicant, then our collection and use of Personal Information is governed by our respective Employee Privacy, Contractor Privacy, or Applicant Privacy notices. If you are a former California employee, please contact us at office.complianceuopx@phoenix.edu for a copy of our Employee Privacy notice.

Certain Services may be subject to additional privacy policies or privacy disclosures relating to the Services provided on the Site(s), including our Biometric Data��policy (collectively, “Additional Policies”). In the event of a conflict between any Additional Policies and this Privacy Policy, the Additional Policies will take precedence.

Student Educational Records. If you become a student, your educational information that is part of your educational record with us is subject to the U.S. Federal Family Educational Rights and Privacy Act (“F����ʴ�”), state laws, and the University’s policies (collectively, “Student Educational Records Requirements”). In the event of any conflict between Student Educational Records Requirements and this Privacy Policy, the Student Educational Records Requirements will take precedence. Students have the right to limit access to their Student Educational Records and to request a copy of such records, as set forth in the University’s FERPA policy.��You may also contact us via one of the below methods:

Mail

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Attn: Registrar’s Office
4035 S. Riverpoint Parkway
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Phone

Admissions and Records Service Center: 800-866-3919.

As used in this Privacy Policy, the following terms have the following meanings:

“Anonymized” means information that has been de-identified so that it no longer reasonably identifies, relates to, describes, and is no longer reasonably capable of being associated with, or linked, directly or indirectly, to an individual. Anonymized information is no longer Personal Information.

“Apps” means software which may be utilized on our Sites and downloaded to or accessed through our Services.

“Business-to-Business Representatives” means agents or representatives of other companies or associations who may be contacted as part of or in relation to our Services.

“Education Partners“ means other companies or institutions who may participate in various University initiatives (e.g., companies making University courses, programs, or other product/service offerings available to their customers, employees, potential employers, institutions conducting academic research or providing academic reporting, etc.).

“Service Providers” means entities that the University contracts with to provide services on our behalf.

“Site” means any website owned or operated by the University, which links to or displays this Privacy Policy.

“Social Network” or “Social Networking” means various Internet communication technologies provided on the Services as well as on third-party social networking websites such as LinkedIn, Facebook, Twitter, etc., that facilitate conversation and interaction between people online and includes, but is not limited to, blogs, discussion forums, wikis, chat sessions, news groups, etc.

“Social Network Content” (or “SNC”) means user-generated content you consent to share via a Social Network and includes, but is not limited to, Personal Information, digital sounds, and pictures that you upload to a Social Network. It also includes your Personal Information that may be displayed on other users’ Social Network pages.��

We collect information about you directly from you, from third parties, and automatically through your use of our Services or interactions with us. We may combine the information we collect from these various sources.

Directly Collected Information.��We collect Personal Information that you provide to us voluntarily (online or offline), including when you: respond to an advertisement; participate in a survey or a drawing; request information; apply for admission to the University; go to receive a photo ID for one of the University campuses; register for classes; apply for financial aid; order educational or other products and Services; set up a Social Network or other Site profile; use our Services or one of our Apps (e.g., for career resources, learning assessments, or other interactive tools); use the chat, SMS, or email functionality on our Site to contact us; or otherwise interact with us online or offline. The exact nature of the Personal Information may vary depending on the type of response or service requested, but could include name, contact details, date of birth, education history, financial information, employment status, photos, interests, demographic information, and other information.

Automatically Collected Information.��The Services may have and use cookies, pixels, third-party tags, scripts, log files, and other means to automatically collect information about the use of our Services and services, including (but not limited to): device information such as your hardware model, operating system, IP address, and unique device identifiers; collection date; publisher name; connection speed; day of week and time of day; language settings; country, state, city (relating to IP address, if available); domain (e.g., .com, .net, .mil, .org, .edu, etc.); web pages viewed; and email clicks or other actions taken. See the “Cookies and Similar Technologies” section below for more information. This information that we collect automatically may be linked with Personal Information to accomplish the purposes described in this Privacy Policy. In addition, we may use CCTV and other security monitoring to secure our premises, which may lead to the collection of Personal Information about visitors to our campuses. Further, when you call us, or communicate with us through our Site by using our chat, SMS, or email functionality, we may record such calls and communications for quality and training purposes.

Information Collected from Other Sources. We may also obtain Personal Information from Education Partners, Service Providers, and publicly available sources, which may be combined with other Personal Information we have collected. For example, we may receive Personal Information about you from educational institutions which you have attended; financial institutions (e.g., related to student loans); government entities (e.g., related to education grants); employers (e.g., related to education or career initiatives); third-party platforms or accounts that you connect to or integrate with one or more of our Services; Service Providers that we work with to verify, update, or append data to the information that we have otherwise collected about you and to identify prospective students or other individuals who may be interested in our Services.

Categories of Personal Information Collected

While the Personal Information we collect varies (as explained above) depending upon the nature of the Services provided or used and our interactions with individuals, generally, we may collect the following categories of Personal Information:

• Name, contact information, and other identifiers: real name, alias, postal address, telephone number(s), unique personal identifier, online identifier, email address, account name, signature, or other similar identifiers
• Commercial information: records of personal property; products or services purchased, obtained, or considered; or other purchasing or consuming histories or tendencies
• Financial information: bank account number, credit card number, debit card number, or other financial information
• Medical information, disability, and health insurance information:��to support specific programmatic or regulatory requirements or service requests
• Demographic information: characteristics such as race, ethnicity, gender, age, religion, national origin, citizenship status, and marital status
• Education information: information regarding past and present education, including institutions attended, years of attendance, courses of study, attendance records, grades, awards earned, degree(s) obtained, discipline records, financial aid awards and payment history, as well as assignments and other student-generated work or contributions to online discussions. The information collected from a student or potential student may include both directory and non-directory information as those terms are defined in FERPA and the University’s FERPA policy.
• Government identification: Social Security, driver’s license, state ID card, and passport number
• Internet or other electronic network activity information: internet protocol (IP) address including, but not limited to, browsing history; search history; and information regarding a consumer’s interaction with an Internet website, application, or advertisement
• Audio, video, and other electronic data: photos, call recordings, and CCTV footage
• Employment history: professional or employment-related information
• Inferences drawn from any of above categories of Personal Information: inferences used to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, and abilities
• Biometric data: facial scans, faceprints, and facial geometry

We may use the Personal Information we collect for the following purposes:

• Administering applications, enrollment, registration, and financial services:��to review and process applications and registrations; to verify the information you provide us, determine your admissibility, register you for selected educational programs, and contact you relating to your��University status; to provide financial services related to tuition payments and financial aid applications; to maintain student records; and for other related purposes.
• Providing support and services: to provide our Services; to communicate with you about your access to and use of such Services; to respond to your inquiries; to provide troubleshooting, fulfill your orders and requests, process your payments, and provide technical support; for other customer service and support purposes; and to facilitate communications and collaboration with you and others in our University community, including through our Education Partners, Service Providers, and our social networking, community, and collaboration features.��In the event you use the chat functionality on our Site, you may either chat with a live agent or a chatbot.��
• Personalizing content and experiences: to tailor content we send or display on the Services in order to offer location customization, personalized help and instructions and to otherwise personalize your experiences; to reach you with more relevant ads and to measure ad campaigns
• Marketing and promotional purposes: to administer promotions and contests; to promote our University and the Services we offer; to send you newsletters, offers, or other information regarding products or services we think may interest you
• Analyzing and improving our services and operations: to better understand how users access and use the Services we offer; for other research and analytical purposes, such as to evaluate and improve our Services and business operations and to develop additional programs, services, and features; and to improve student retention, our Services, and user experiences
• Securing and protecting our assets and rights and preventing misconduct: to protect our business operations, secure our network and information technology assets and services; to prevent and detect fraud, unauthorized access or activities, cheating, plagiarism, and other misconduct; and, where we believe necessary, to investigate, prevent, or take action regarding suspected violations of our student policies, Terms of Use, or this Privacy Policy, as well as fraud, illegal activities, cheating, plagiarism, misconduct, and other situations involving potential threats to the rights or safety of any person
• Complying with legal obligations: to comply with the law or legal proceedings. For example, we may disclose information in response to subpoenas, court orders, and other lawful requests by regulators and law enforcement, including responding to national security or law enforcement disclosure requirements
• Supporting our general business operations: to support the administration of our general business, accounting, record keeping, and legal functions, including to analyze operational and business results and risks, to collect outstanding amounts owed, and to maintain business and Student Educational Records

Anonymized information. We may also de-identify information to create Anonymized data sets and reports in order to assess, improve, and develop our business, products, and Services; prepare benchmarking reports; and for other research and analytics purposes.

We may disclose the Personal Information we collect as follows:

• Service Providers. We may share your Personal Information with third-party Service Providers who use this information to perform services for us, including payment processors, content providers, chat providers, hosting providers, auditors, advisors, consultants, account collection agencies, advertising and marketing partners, and customer service and support providers.
• Education Partners. We may share your Personal Information with our Education Partners who we work with to make available certain educational services, programs, courses, career initiatives, and/or other offerings or who may be doing academic or other institutional research.
• Business Transfers. We may disclose or transfer your Personal Information as part of any actual or contemplated merger, sale, transfer of our assets, acquisition, financing, or restructuring of all or part of our business, bankruptcy, or similar event, including related to due diligence conducted prior to such event, where permitted by law.
• Legally Required. We may disclose your Personal Information as required under applicable law or in response to legal process (e.g., in response to a subpoena or court order).
• FERPA Permitted. We may disclose your Personal Information as permitted under FERPA.
• Protect our Rights. We may disclose your Personal Information where we believe it necessary to respond to claims asserted against us or to comply with legal process; to enforce or administer our agreements and terms; for fraud prevention, risk assessment, investigation, and protection of the rights, property, or safety of the University, our clients, customers, and others.

We operate and may process information in multiple jurisdictions, both in and outside the United States, such that some Education Partners and Service Providers may be located or process information outside of the jurisdiction in which you reside. In such cases, your Personal Information may be collected, used, disclosed, stored, and processed in these other jurisdictions for the purposes described in this policy. The data protection and other laws of the United States and other countries might differ from your jurisdiction. In addition, your Personal Information may be subject to the laws of those other jurisdictions, including lawful requirements to disclose Personal Information to government authorities.

We use cookies, pixels, tags, local storage objects (also called Flash cookies), web beacons, and other technologies (which may be provided by third parties) on our Services to enable certain functionality on our Services; for security and fraud detection and prevention; to collect usage information about our Services and the emails that we send; and to personalize content and provide more relevant ads and information. We may combine the information we collect via these technologies with other information that we collect, including Personal Information.��

Cookies. Cookies are alphanumeric identifiers that are transferred to your computer through your web browser for record-keeping purposes. Some cookies enable you to log in to our Services or save certain settings and preferences, while others allow us to identify usage and activities on our Services, personalize content on our Services, or deliver more relevant ads on third-party websites. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help tab on the toolbar of most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. If you disable cookies, however, certain features may not be available or function properly.�� For more information or to update your preferences for certain third-party tags and cookies on our Sites, please see our .

Pixel tags and embedded script (also called clear GIFs and web beacons). Pixel tags are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, pixel tags are embedded invisibly on web pages. We may use these in connection with our Services to, among other things, identify the activities of users of our Services, improve ads, personalize and manage content, and gather usage information about our Services. We may also use these in HTML emails to help us analyze email response rates, identify when our emails are viewed, and determine whether our emails are forwarded. For more information or to update your preferences for certain third-party tags and cookies on our Sites, please see our .

Local Storage Objects (LSOs). LSOs are data files that are stored locally in your browser by the websites you visit. LSOs can be used in a similar manner as cookies for a variety of purposes, such as keeping track of information you provided and remembering your preferences. Our Services may include video and content that rely on Adobe Flash Player, which uses LSOs (also called Flash cookies). If you have Adobe Flash Player installed on your computer, it can be set to reject or delete LSOs. This option is in the System Preferences on Mac OS X, in the Flash Player Control Panel on Windows®, or with the Flash Player management tools available on the Adobe website. Other types of LSOs include HTML5 Local Storage and similar technologies.

Do-Not-Track Signals. Do-Not-Track (DNT) is a browser-based signal that, when set, signifies your desire not to be tracked online. Our Services may not respond to all web browser based DNT signals. Some browsers and browser extensions support the��(“GPC”) that can send a signal to the websites you visit indicating your choice to opt out from certain types of data processing, including data sales. We have implemented tools such that when we detect such a signal, we will make reasonable efforts to respect your choices indicated by the GPC setting. In addition, you may disable certain cookies and opt out of interest-based advertising as explained in the “Individual Rights and Choices” section below.

We may work with Service Providers (including, but not limited to, Adobe, Google, LinkedIn, and Facebook) to display advertising on our Sites or to manage our advertising on other websites. These third-party networks and platforms use cookies, pixel tags, and other technologies to collect information about your activities on our Services and other websites over time to provide you targeted advertising based upon your interests. Some ads are targeted to your interests and preferences, based on your browsing history and other information. Your browsing history may be followed in these cookies even if ads are not being displayed.��We may also use device information, particularly in mobile advertising, to help deliver our advertising and measure ad campaign effectiveness. You may update your preferences for third-party tags and cookies on our Sites using our .

In this section, we describe your rights and choices regarding our use and disclosure of your Personal Information.

Marketing Communications. You may opt out of receiving marketing communications from us. Additionally, you may unsubscribe from our marketing notifications from the footer of any marketing email we send or inform us of your decision to opt out while on a call with us. Opt-out requests will only remove you from our marketing list, not from the list of any other third parties.

If you do not wish to receive text messages, you may opt out by responding��STOP��to cancel future text messages.��To get help, text��HELP.��You may also request additional assistance by contacting��TextMsgSupport@phoenix.edu��or by calling 866-766-0766.

Social Networking Content. You may change various user settings related to sharing your Personal Information contained in any user profile you set up as part of Social Network activities furnished by us, subject to contractual, academic, legal, or technical restrictions and reasonable notice. Note that your withdrawal from Social Network activities might prevent us from providing you with certain products or services.

Cookies and Similar Technologies. Using our����you can opt out of or change your preferences for most third-party cookies and tags on our Sites, except those that are “necessary” to the proper functioning of our Sites or particular features available to you on our Sites. In addition, you may block or disable cookies for the device and browser you are using through your browser settings; however, if you do so, certain features on our Sites may not be available or function properly.

We do not knowingly collect Personal Information from children under the age of 13.�� If we learn that we have collected or have received Personal Information from a child under 13 without appropriate parental consent, we will delete that information. If you believe we might have collected any information from a child under 13 without consent, please contact us via one of the methods in the “Contact Us” section below.

We have implemented security measures to protect against the loss, misuse, and alteration of the Personal Information under our control. However, no data transmission over the Internet can be guaranteed to be completely secure. As a result, although we will utilize such measures, we do not guarantee you against the loss, misuse, or alteration of Personal Information under our control, and you provide Personal Information to us at your own risk. You should always take care how you handle and disclose your Personal Information and should avoid sending Personal Information through insecure email, Social Networks, or other Internet channels.

We may monitor, record, and retain all incoming and outgoing communications for training of our representatives, for quality assurance purposes, as necessary for our records retention policy, and as required for legal purposes. This includes the monitoring and recording of communications and interactions between you and the chat functionality made available through our Sites. To the extent such communications are retained, they are retained in accordance with our records retention policy.����

Some of our Services may contain links to websites or access to services provided by third parties who operate websites or provide services on their own behalf or on behalf of multiple entities. These third parties may collect your Personal Information and may apply their own policies on how your Personal Information is used. Please make sure to read the policies of any websites or services you visit on the Internet carefully. We are not responsible for the privacy practices or the content of any websites or services that are not operated by or exclusively for us, and the collection, use, and disclosure of Personal Information about you will be subject to the policies applicable on those websites.

We may update this Privacy Policy or revise it from time to time. Your continued provision of Personal Information or use of our Services following any changes to this Privacy Policy constitutes your acceptance of such changes. If we make a material change to this Privacy Policy, we will attempt to notify you in advance of such change via a notice on our Site and/or, when appropriate, via email to you.

Should you have any questions about our privacy practices, please contact us at��Office.ComplianceUOPX@phoenix.edu��or by mail:

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Ethics, Compliance, and Data Privacy
4035 S. Riverpoint Parkway
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