Notice of Collection with EduConnect USA

INTRODUCTION

EduConnect USA and its affiliated partners  want you to know about the personal information we collect and the purposes for which we will use that information. This notice is given pursuant to the California Consumer Privacy Rights Act (CPRA) and applies solely to individuals who are California residents. 

DEFINITIONS

Let us begin by defining some terms that you will see in this notice of collection. 

  • We”, “our”, and “us” refers to EduConnect USA, its directors, officers, employees, agents, affiliates, subsidiaries, and parent companies where applicable.
  • You” and “your” refer to a natural person who is a California resident.
  • Personal Information” means 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. Personal information includes, but is not limited to, the following if it identifies, relates to, describes, is reasonably capable of being associated with, or could be reasonably linked, directly or indirectly, with a particular consumer or household.
  • Categories of Personal Information” are as follows:
    • Identifying Information is information such as 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.
    • Personal Information means 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. Personal information includes, but is not limited to, the following if it identifies, relates to, describes, is reasonably capable of being associated with, or could be reasonably linked, directly or indirectly, with a particular consumer or household.
    • Characteristic Information is information of protected classifications under California or federal law.
    • Commercial Information is information including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
    • Biometric Information is information that includes, but is not limited to, imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information.
    • Internet Activity Information is information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet website application, or advertisement.
    • Geolocation Information is information or data related to a geographical location, such as a device or Internet Protocol (IP) location.
    • Audio Visual Information is Audio, electronic, visual, thermal, olfactory, or similar information.
    • Employment Information is professional or employment-related information, such as employment history or status.
    • Education Information¬ is personally identifiable education information that is not publicly available.
    • Inference Information is inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
    • Sensitive Personal Information– means Personal information that reveals: A consumer’s social security, driver’s license, state identification card, or passport number, a consumer’s account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account. A consumer’s precise geolocation. A consumer’s racial or ethnic origin, religious or philosophical beliefs, or union membership. The contents of a consumer’s mail, email, and text messages unless the business is the intended recipient of the communication and a consumer’s genetic data. All other terms defined in the CPRA, or its implementing regulations have the same meanings when used in this notice.

 

 

COLLECTION OF PERSONAL INFORMATION

We collect personal information about consumers for the following operational and business purposes:

 

  • Operational – In order to provide services for us, students of our partner universities, employees, and other parties, including (but not limited to) maintaining and servicing accounts, providing customer service, processing and considering applications for enrollment at our partner universities, verifying student information, processing payments, engaging in advertising or marketing, performing analytics, or similar services. EduConnect USA collects information during registration to our programs, admissions at our partner universities, registration to our placement services and employment application processes.
  • Quality Assurance – Activities to achieve, verify, or maintain the quality or safety of products, services, or equipment, and to improve such products, services, or equipment provided to our customers.
  • Security – Activities to protect against malicious, deceptive, fraudulent, or illegal activity, detect security incidents, or hold the perpetrators of that activity responsible.
  • Debugging – Debugging to identify and repair errors that impair existing or intended functionality.
  • Audit – Applicable compliance audits.

 

Personal information does not include: 

 

  • Publicly available information from government records.
  • Deidentified or aggregated consumer information.
  • Information excluded from the CPRA’s scope, like:
    • Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

 

 

Storage of Information

EduConnect USA may retain your personal information for as long as it is necessary or relevant for the practices described in our Privacy Policy, including, but not limited to, legal obligations, resolving disputes, and enforcing our agreements, and for backup, archival, and other internal operational purposes. 

 

Below is a list of categories, examples, and collection data of personal information we collect about consumers: 

 

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              NO

 

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              NO

 

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              NO

 

D. Commercial information

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

YES              ✅ NO

 

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.

YES              ✅ 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              NO

 

G. Geolocation data

Physical location or movements

YES              ✅ NO

 

H. Sensory data

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

✅ YES              NO

 

I. Professional or employment-related information

Current or past job history or performance evaluations.

✅ YES              NO

 

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              NO

 

K. Inferences drawn from other personal information

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

✅ YES              NO

 

L. Sensitive Personal Information

A consumer’s social security, driver’s license, state identification card, or passport number, a consumer’s account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account. A consumer’s precise geolocation. A consumer’s racial or ethnic origin, religious or philosophical beliefs, or union membership. The contents of a consumer’s mail, email, and text messages unless the business is the intended recipient of the communication. A consumer’s genetic data. All other terms defined in the CPRA, or its implementing regulations have the same meanings when used in this notice.  

YES              ✅ NO (Information regarding race and ethnicity maybe collected for reporting purposes)

 

ADDITIONAL INFORMATION

For more information about the personal information, we collect and how we use it, or for additional information about rights that California residents have under the CPRA, please see our Privacy Policy.

 

If you have any questions or concerns regarding this notice or our privacy policy, you may contact us by emailing us at [email protected].

 

To exercise your rights under the CPRA, please visit the links below.
Limit the Use of My Sensitive Personal Information

Do Not Sell/Share My Personal Information