Effective Date: [August 4, 2020]
DigiPen (USA), LLC, dba DigiPen Institute of Technology (“DigiPen”) respects the privacy of people who visit our web site, www.digipen.edu, and other DigiPen sites (individually and collectively referred to herein as the “Site”).
Information Collection, Sharing, and Use
We also collect personal information that you voluntarily supply us with. DigiPen may disclose personal information to third parties (including without limitation, governmental agencies) if required to do so by law or based on the good faith belief that such action is necessary to: (i) conform to the edicts of the law or comply with legal process; (ii) protect and defend the rights or property of DigiPen or its agents or contractors; or (iii) act in urgent circumstances to protect the personal safety of users of DigiPen, the Site, or the public.
DigiPen engages the following types of vendors to perform functions on our behalf, such as:
- Companies that enable us to track your tuition, housing, and other related payments.
- Billing and collection providers, such as payment processors that assist us in assessing your payment status
- Platforms that host our chat functions on our Site and help us gauge online activity on our Site
- Entities that assist with website design, hosting, and maintenance, data and software storage, and network operation
- Analytics services that help us analyze traffic to and on our website and assist with identifying and communicating with potential customers
Your Access to and Control Over Information
You may opt out of marketing communications from us at any time by contacting us via the email address or phone number given below or by following “unsubscribe” steps for email, as appropriate. If you are an applicant or current DigiPen student, please refer to the student information system to update your contact information.
You are solely responsible for maintaining the secrecy of your passwords or any account information. Please be careful and responsible whenever you are online. While we strive to protect your personal information, DigiPen does not ensure or warrant the security of any information you transmit to us, and you do so at your own risk.
Third-Party Sites and Links
The Site is not intended for or directed to children under the age of 13. Any person who provides their information to DigiPen through the Site represents to DigiPen that they are 13 years of age or older.
Information for Individuals Located in the EEA, Switzerland, and the United Kingdom
If you are a resident of the European Economic Area (“EEA”) (which includes the member states of the European Union (“EU”) plus Iceland, Liechtenstein, and Norway), Switzerland or the United Kingdom, the following information applies to personal information that we collect via cookies on the Site:
- Purposes of processing and legal basis for processing: As explained above, we process personal information in various ways depending upon your use of our Site. We process personal information on the following legal bases: (1) with your consent; (2) as necessary to perform our agreement to provide our Site; and (3) as necessary for our legitimate interests in providing our Site where those interests do not override your fundamental rights and freedoms related to data privacy.
- Rights: You are entitled to certain rights. In order to verify your identify, we may require you to provide us with information prior to accessing any records containing information about you. These rights include the ability to:
- Withdraw consent at any time if we have collected personal information with your consent.
- Request access to information held about you.
- Request that we correct the personal information we hold about you if it is inaccurate or incomplete.
- Ask for data to be erased if the data is no longer necessary for the purpose for which it was collected, you withdraw consent and no other legal basis for processing exists, or you believe your fundamental rights to data privacy and protection outweigh our legitimate interest in continuing the process.
- Request that we provide your personal information to you in a format that can be transferred to another entity.
- Request that, in certain circumstances, we limit our processing of your personal information if you are contesting the accuracy of your personal information; asserting that our processing is unlawful; asserting that we need to keep the information for reasons related to the establishment, exercise, or defense of legal claims, or you object to our processing.
- Object to our processing if we are processing your personal information based on legitimate interests, using your personal information for direct marketing (including profiling), or processing your personal information for purposes of scientific or historical research and statistics.
- In certain circumstances, not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects on you.
- Lodge a complaint about our data collection and processing actions with the supervisory authority concerned. Contact details for data protection authorities are available here.
- Transfers: Personal information we collect may be transferred to, and stored and processed in, the United States or any other country in which we or our affiliates or subcontractors maintain facilities. We ensure that transfers of personal information to a third country or an international organization are subject to appropriate safeguards as described in Article 46 of the GDPR.
California Privacy Rights
California Shine the Light
Residents of the State of California have the right to request information from DigiPen regarding other companies to whom the company has disclosed certain categories of information during the preceding year for those companies’ direct marketing purposes. If you are a California resident and would like to make such a request, please email privacy[at]digipen[dot]edu
California Consumer Privacy Act
The California Consumer Privacy Act (“CCPA”) provides California residents with rights to receive certain disclosures regarding the collection, use, and sharing of “Personal Information,” as well as rights to know/access, delete, and limit sharing of Personal Information. The CCPA defines “Personal Information” as “information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.” Certain information we collect may be exempt from the CCPA because it is considered public information (i.e., it is made available by a government entity) or covered by a specific federal privacy law, such as the Gramm–Leach–Bliley Act, the Health Insurance Portability and Accountability Act, or the Fair Credit Reporting Act.
To the extent that we collect Personal Information that is subject to the CCPA, that information, our practices, and your rights are described below.
Right to Notice at Collection Regarding the Categories of Personal Information Collected
You have the right to receive notice of the categories of Personal Information we collect, and the purposes for which those categories of Personal Information will be used. This notice should be provided at or before the time of collection. The categories we use to describe the information are those enumerated in the CCPA.
We collect your name, phone number, and email address and contact address when you create an account, complete a transaction, or apply for admission into one of our programs. If you choose to create an account, you will also be asked to create a username, which may sometimes be your email address, and we will assign one or more unique identifiers to your profile. We use this information to provide the Site and our services and products, process your application to our programs, respond to your requests, and send information and advertisements to you.
We collect your social media handle and basic account information when you interact with the Site through social media.
We collect a unique numerical identifier, assigned to you by a first-party cookie, automatically when you use the Site in order to identify you, provide the Site, keep you logged in to the Site, prevent fraud, and provide you with targeted information and offers.
We collect payment information when you provide it to us, which may include your credit card number when you complete a transaction. You have the option to store this information to your account. We use this information to streamline and facilitate payments and transactions.
We collect your IP address automatically when you use the Site. We use this information to identify you, gauge online activity on our website, measure the effectiveness of online services, applications, and tools, and serve targeted advertisements based on your online activities.
We collect your Device ID automatically when you use the Site. We use this information to monitor your use and the effectiveness of the Site, to identify you, and to provide you with targeted information and offers.
We collect your Social Security number if you submit financial aid documents to us. We use this information to process any financial aid documents and facilitate the process of providing you with such financial aid.
We collect medical information and health information about you if you use certain medical or social services provided by us. We use this information to provide such services to you, including mental health counseling or Disability Support Services.
Protected Classifications: We also collect your age, date of birth, race, and ethnic origin when we process your application for admission into our programs or financial aid documents. We may collect your disability status if you use our Disability Support Services in order to provide you with such services.
Commercial Information: When you engage in transactions with us, we create records of goods or services purchased or considered, as well as purchasing or consuming histories. We use this information to measure the effectiveness of the Site and to provide you with targeted information and advertisements.
Internet or Other Electronic Network Activity Information: We collect information about your browsing history, search history, information regarding your interaction with websites, and applications or advertisements automatically when you utilize the Site. We use this information to gauge online activity on our website, measure the effectiveness of online services, applications, and tools, and to serve targeted advertisements based on your online activities.
Geolocation Data: As described above, we collect your IP address automatically when you use the Site. We may be able to determine your general location based on the IP address.
Audio, electronic, visual, thermal, olfactory, or similar information: If you contact us via phone, we may record the call. We will notify you if a call is being recorded at the beginning of the call. If you enroll in our programs, we collect your photographic or video image to provide you with a student badge.
Professional or employment-related information: If you submit a résumé as part of an application, we collect information about your current employer and your employment history. We use this information to process your application into our programs and conduct background and other screening activities. If you are a student, we use this information to connect you to employers that may be interested in hiring our students.
Education information: We collect information about the institutions you have attended and the level of education you have attained. We use this information to process your application into our programs or for employment and to conduct background and other screening activities. If you enroll or apply to our programs, we may also collect information such as your dates of application, admission, enrollment, and earliest campus visit; student type (e.g., first time, transfer, continuing, international, etc.); high school CEEB code; and if applicable, your athlete status. We will use this information, as well as certain personal identifiers noted above, to provide our educational programs. We may also analyze such information to assist us with identifying with prospective students.
Inferences drawn to create a profile about a consumer reflecting the consumer’s preferences or characteristics: We may analyze your actual or likely preferences through a series of computer processes. On some occasions, we may add our observations to your internal profile. We use this information to gauge and develop our marketing activities, measure the appeal and effectiveness of the Site, applications, and tools, and to provide you with targeted information, advertisements, and offers.
We may use any of the categories of information listed above for other business or operational purposes compatible with the context in which the Personal Information was collected.
We also sell some information to third parties, as described below. To opt-out of the sale of your information, visit our “Do Not Sell My Information” web page.
Right to Know About Personal Information Collected, Disclosed, or Sold
Right to Know/Access Information
You have the right to request access to Personal Information collected about you and information regarding the source of that information, the purposes for which we collect it, and the third parties and service providers with whom we share it. You may submit such a request as described below. To protect our customers’ Personal Information, we are required to verify your identify before we can act on your request.
Right to Request Deletion of Information
You have the right to request in certain circumstances that we delete any Personal Information that we have collected directly from you. You may submit such a request as described below. To protect our customers’ Personal Information, we are required to verify your identify before we can act on your request. We may have a reason under the law why we do not have to comply with your request, or why we may comply with it in a more limited way than you anticipated. If we do, we will explain that to you in our response.
How to Submit a Request
You may submit a request to exercise your rights to know/access or delete your Personal Information through any one of three means:
In order to process your request to know/access or delete Personal Information we collect, disclose, or sell, we must verify your request. We do this by asking you to:
You may authorize another individual or a business registered with the California Secretary of State, called an authorized agent, to make requests on your behalf. We require that you and the individual complete notarized affidavits in order to verify the identity of the authorized agent and confirm that you have authorized them to act on your behalf. Parents of minor children may submit a birth of the child certificate in lieu of an affidavit, in order to make requests on the child’s behalf. Please see our required affidavits here.
Right to Opt Out of Sale of Personal Information to Third Parties
We sell information to third parties. You have the right to opt out of any sale of your Personal Information by DigiPen to third parties. To “sell” information means to disclose it to a company for monetary or other benefit. A company may be considered a third party either because the purpose of sharing is not an enumerated business purpose under California law, or because our contract does not restrict them from using Personal Information for other purposes.
We sell the following information:
- Personal Identifiers:
- We provide your IP address and Device ID to our advertising and analytics partners.
- Inferences drawn to create a profile about a consumer reflecting the consumer’s preferences or characteristics: We provide our observations about you to our advertising partners.
To exercise your right to opt out of the sale of your personal information, please visit our “Do Not Sell My Information” web page or call us at 1-866-478-5236.
Please note that your right to opt out does not apply to our sharing of Personal Information with service providers, who are parties we engage to perform a function on our behalf and are contractually obligated to use the Personal Information only for that function.
What are cookies?
Cookies are text files containing small amounts of information which are downloaded to your computer or mobile device when you visit a website or mobile application. Cookies are then sent back to the originating site on each subsequent visit, or to another site that recognizes the cookies.
How to Manage Your Cookie Preferences
There is no accepted standard on how to respond to Do Not Track signals, and DigiPen does not respond to such signals. Rather, you may visit the Digital Advertising Alliance (DAA) or the Network Advertising Initiative (NAI) to receive more information about the collection and use of information about your online activities for online behavioral advertising or to learn how to opt out of having your data used for online behavioral advertising. European users can also visit the European Interactive Digital Advertising Alliance to learn how to opt out of having their data used for online behavioral advertising.
Please note that if you choose to block cookies, you may impair our Sites or prevent certain elements of our Sites from functioning. Also, if you delete your cookies in the future you will need to opt again and if you use multiple web browsers, you may need to opt again.
Please note that even if you opt out using the mechanisms above, you may still receive advertisements when using DigiPen’s Sites.
Types of Cookies and Technologies Used
DigiPen uses a number of first-party cookies, most of which expire when the user’s browser is closed. Generally, these cookies help to store user information (i.e. language preferences) or ensure that users are aware of specific events related to their campus.
|Analytics||How Google uses information from sites or apps that use our services|
Questions or Comments
If you have any questions or comments about this policy, please contact us at privacy[at]digipen[dot]edu.