Privacy policy2021-10-06T15:52:30-06:00

Last Updated: June 25, 2021

OCL Financial Services LLC, along with our parent company Adtalem Global Education, Inc., and our related entities, subsidiaries, and affiliates (collectively “OnCourse Learning” or “we” or “us”) is a leading provider of licensure, continuing education, and compliance training courses.

This Privacy Policy describes the types of personal information we may collect about you, how we collect, use, process, and disclose your personal information and the choices you can make about how we collect, use, process, and disclose your personal information.  This Privacy Policy applies to personal information collected through our websites, mobile applications, and other services we offer, and anywhere else the Policy is posted (collectively, our “Services).

Our privacy practices may vary among the countries or territories in which we operate to reflect local practices and legal requirements. You can review certain region-specific information by reviewing the relevant regional Addendum at the end of this Notice.

If you reside or are located in the European Economic Area (“EEA”), the United Kingdom (“UK”), or Switzerland, OnCourse Learning is the data controller of all personal information collected via the Services.

Personal Information We Collect

We collect personal information to provide and improve the Services we offer and to communicate with you about our Service offerings. We collect personal information in the following ways:

  • Information you provide to us: We collect personal information you provide to us as part of the Services, such as when you request informational materials, register for an event, create an account, request product or service information through an email contact form, subscribe to email alerts regarding OnCourse Learning events or company news, enroll in our programs or courses, participate in a promotion or survey, utilize our online or offline resources, or otherwise interact with us either online or offline. Examples of the type of information you may provide to us are:
    • Personal information, such as your name, mailing address, email and phone number, zip code
    • Account or course login credentials
    • Payment information (including payment card details or online payment services number and invoicing address) and financial information (such as bank account numbers
  • Information that you provide in course discussion boards, community forums, in directories, on social media, or in response to promotions and surveys, such as photos, comments, and reviews
    • Other personal information that may be provided to us to use or obtain our services
  • Information collected automatically: We automatically collect and store certain types of information about your use of the Services, such as information collected through the use of cookies, pixels and other tracking technologies.Examples of the type of information we may collect automatically includes:
    • IP address of the device you are using
    • Device data, such as technical data about the device used to access the Site and/or the Apps (such as unique device ID, device type, model, name or ID, operating system version, application types and versions, plug-ins and time zone and geolocation information) if you use certain features or applications
    • Browser type and language
    • Internet service provider
    • Access times and referring website addresses
    • Content interaction information, such as files or content viewed, time spent viewing content, and download information
  • Information from other sources: We may receive information from other sources, such as service providers, testing centers, social media, third-party platforms and forums, and business partners. Examples of the type of information we may receive from other sources are:
    • Personal information, such as your name, personal and professional mailing address, email and phone number, and professional and educational history
    • Profile information, comments, content, and other data posted on or provided to social media pages or elsewhere on the Internet (such as public locations)
    • Interests, demographic data, and internet browsing behavior

Some of the information we collect may, when combined with other information, be personal information that could be used to identify you. Such information is treated as personal information.

You are responsible for ensuring the accuracy of personal information you provide to us. Inaccurate information may affect your ability to use the Services, the information you receive when using the Services, and our ability to contact you.

Where we need to collect personal information by law, or under the terms of a contract we have with you or in order to provide you with information you have requested, and you do not provide this personal information when requested, we may be prevented from complying with our legal obligations or we may not be able to perform all or part of the contract we are entering into with you or provide you with the information requested. For example, we require (a) certain information in order to enroll you in a course, (b) your contact details in order to send you any information you have requested.

How We Use the Personal Information Collected

We use, store, and process the personal information we collect to provide and improve the Services, to support our business functions, as well as to personalize, provide, measure and improve our advertising and marketing. We may use personal information to form a view on what we believe may be of interest to you. This is how we decide which content, product, and service offerings may be relevant for you and direct you to particular areas of this website that we think will be most relevant for you.

Some examples of how we use personal information include:

  • To provide you with information, products, or services that you request from us such as details about our programs, enrollment, ongoing education, and career services (necessary for the performance of our contract with you or otherwise in our legitimate interests to provide you with the relevant information, products, or services)
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection (necessary for the performance of our contract with you)
  • To process payment or facilitate delivery of services requested (necessary for the performance of our contract with you)
  • To provide you with support and respond to your inquiries, such as to investigate and address your concerns, and monitor and improve our responses (our legitimate interests in providing you with support, responding to your inquiries, and developing and improving our service)
  • To provide, personalize, measure, and improve our website experience and to deliver content and product and service offerings based on your advertising customization preferences (our legitimate interests in operating our website and keeping it updated and relevant)
  • To send you information about our products, services, promotions, and to administer promotional activities, such as surveys, sweepstakes, contests, and referrals, either with your consent (where applicable law requires us to obtain your consent for marketing to you) or for our legitimate interests in promoting our products and services and business
  • To help maintain and improve the safety, security, and integrity of our facilities, website(s), networks, information systems, and applications, including for fraud detection purposes (our legitimate interests in maintaining network security and detecting and preventing fraud)
  • For testing, research, analysis, and product development, such as to develop and improve our websites, products and services, databases and other technology assets, and offerings (our legitimate interests in developing our business and product lines)
  • Device Data may be used as part of our security controls to uniquely identify the device and authenticate the user when accessing the Site and/or the Apps (our legitimate interests in ensuring users are authenticated when accessing our Site and/or the Apps and preventing fraudulent or abusive activity)
  • To support our general business operations (our legitimate interests in running and operating our business in a proper manner)
  • As described to you when collecting your personal information to fulfill any other purpose for which you provide it

How We Protect Personal Information

To help protect the privacy and security of your personal information we use reasonable security measures, including administrative, technical, and physical safeguards designed to protect against loss, accidental, unlawful, or unauthorized access, use, loss, access, disclosure, alteration or destruction of your personal information.

While we do our best to protect your personal information, please be aware that no security measures are perfect or impenetrable. If you know or have reason to believe that your personal information has been lost, stolen, misappropriated, or otherwise compromised, please see the Contact Us section below for information about how to contact us.

Disclosing Personal Information

We may disclose your personal information to other businesses or entities where it is required for the performance of our contract with you, where it is required by law, or where we have another legitimate interest in doing so, including:

  • To our parent organization, other related entities, subsidiaries, or affiliates for use in the manner described in this Privacy Policy
  • To service providers that perform services on our behalf, such as credit card payment processors, event planners and coordinators, data management and storage providers, marketers and advertisers, analytics and research companies, and professional advisors
  • If required to do so by law, regulation, or legal process (such as a court order or subpoena)
  • In response to requests by government agencies, such as law enforcement authorities or regulators
  • When we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity
  • To combat fraud or criminal activity, and to protect our rights, users, and business partners, or as part of legal proceedings
  • To another entity in connection with a merger, transfer of data assets, reorganization, divestiture, financing, dissolution, or similar corporate event involving all or part of our business
  • Otherwise at your request or with your consent

Cookies, Similar Technologies, Your Choices & Opt-Outs

We, as well as third parties that provide content or other functionality for our Services, may use cookies, pixel tags, local storage, and other technologies to automatically collect information through the Services. These tracking technologies are small data files downloaded to or stored on your computer, tablet, mobile phone or other internet-enabled device that enable us to record certain pieces of information whenever you visit or interact with our email communications, website, applications, tools and other online services. These technologies allow us to understand who has interacted with us, help us to operate our Services more efficiently, personalize your experience on our website, improve our content and offerings, engage in analytics, and show you advertisements in which you may be interested.

  • Cookies. Cookies are small text files downloaded on your browser that store your preferences. Most browsers allow you to block and delete cookies. However, if you do that, the website may not work properly.
  • Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded on the website that collects information about users’ engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page.
  • Behavioral-based advertising.  A third party may use technology, such as a cookie on your browser or a web beacon, to identify you so that they can provide advertising about products and services tailored to your interests.  If you would like to opt-out of third-party behavioral advertising that collects information on your use, you can do so by visiting the Network Advertising Initiative and the Digital Advertising Alliance. Alternatively, you may opt out of this advertising by visiting the TrustArc Preference Manager or Your Online Choices if located in the European Union. Please note, you will continue to receive generic ads.
  • Analytics. We also use Google Analytics and Google Analytics Demographics and Interest Reporting to collect information regarding visitor behavior and visitor demographics for some of our Services and to develop content. This analytics data is not tied to any personal information. Click here for more information about Google Analytics. You can opt-out of Google’s collection and processing of data generated by your use of the Services by visiting Google Tools.
  • Third party vendors, including Google, show our ads on the Internet and use cookies to serve ads based on a user’s prior visits to this website. We also use data analytics to serve ads based on a user’s prior visits to this website. Click here for more information about Google Ads.
  • Social Media. This website may include social media features, such as Twitter, Facebook, Instagram, LinkedIn or other widgets. These social media companies may recognize you and collect information about your visit to our website, and they may set a cookie or employ other tracking technologies. Your interactions with those features are governed by the privacy policies of those companies.

Some web browsers and devices permit you to broadcast a preference that you not be “tracked” online. At this time, we do not modify your experience based upon whether such a signal is broadcast.

Data Transfers

We may transfer the personal information we collect about you to countries other than the country in which the information was originally collected. Those countries may not have the same data protection laws as the country in which you initially provided the information.

When we transfer your personal information to other countries, we will protect that information as described in this Privacy Notice and in accordance with applicable law. We use contractual protections for the transfer of personal information among various jurisdictions (including, for example, the European Commission’s standard contractual clauses).

Retention

We keep personal information for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting or reporting requirements and our legitimate interests in maintaining such personal information in our records. We will consider the amount, nature, and sensitivity of the personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and applicable legal requirements.

Third-party Websites

This website may contain links to other websites. Some of those websites may be operated by Us, and some may be operated by third parties. We provide the links for your convenience, but we do not review, control, or monitor the privacy practices of websites operated by others. We are not responsible for the performance of websites operated by third parties or for your business dealings with them. Therefore, whenever you leave this website, we recommend that you review each website’s privacy practices and make your own conclusions regarding the adequacy of these practices.

Parents / Guardians

Our Services are not directed to children under the age of 16 and we do not knowingly collect any personal information from children under the age of 16. If we become aware that we have unknowingly collected personal information from a child under the age of 16, and do not have parent or guardian consent on file, we will endeavor to delete such personal information from our records. If you believe we are incorrectly processing the personal information of a child under the age of 16, we recommend you contact us as provided in the final section of this policy.

Nondiscrimination

We may not discriminate against you because of your exercise of any of the foregoing privacy rights, or any other rights under the California Consumer Privacy Act.

Changes to this Privacy Policy

This Privacy Policy may be updated periodically, and without prior notice to you, to reflect changes in our privacy practices. We will post a prominent notice on our websites to notify you of any significant changes to our Privacy Notice and we will attempt to let you know via email or other communication. We will indicate at the top of the notice when it was most recently updated. We encourage you to periodically review this page for the latest information on our privacy practices. As long as you continue to use the Services, you agree to this Privacy Policy and any updates we make to it.

Contact Us

OnCourse Learning Financial Services LLC
20225 Water Tower Blvd., Brookfield, WI  53045, USA.

Email Us: OCLPrivacy@oncourselearning.com

Requests to Exercise Your Rights

You have the right to complain to a data protection authority about our collection and use of Personal Information about you. For more information, please contact your local data protection authority. Contact details for data protection authorities in the European Economic Area, Switzerland and certain non-European countries (including the US and Canada) are available at ec.europa.eu/newsroom/article29/items

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

You may request to exercise any of the rights in this Privacy Notice by email at OCLPrivacy@oncourselearning.com.

California Notice at Collection & Privacy Notice

Last Updated: June 25, 2021

This part of our Privacy Policy applies to consumers who reside in the State of California.

This OnCourse Learning California Privacy Policy (“California Privacy Notice”) should be read in conjunction with the main OnCourse Learning Privacy Policy. This California Privacy Notice applies to information collected on this website and anywhere the Notice is posted (collectively, our “Services”). We have adopted this California Privacy Notice pursuant to the California Consumer Privacy Act of 2018 (“CCPA”) and it applies only to residents of the State of California (“you”).

Scope
Some personal information we collect from you may not be covered by this California Privacy Notice because certain personal information collection and processing activities are exempt from the CCPA. Therefore, this California Privacy Notice and the California privacy rights set out below may not apply to you or to all of your personal information.

Notice at Collection
We may collect the following categories of personal information about you:

  • Identifiers, such as, name, postal address(es), email address, phone numbers, date of birth, online identifier and IP address
  • California Customer Records, such as name, postal address, phone numbers, education information, employment information, employment history, financial information
  • Commercial Information, such as, products or services purchased, other purchasing or consuming tendencies
  • Internet or Other Electronic Network Activity, such as, browsing history, search history, website or advertisement interaction
  • Geolocation Data, such as, IP address, physical location
  • Audio, Video and Other Electronic Data, such as, audio, visual, or electronic information, including photos, call recordings, and CCTV footage
  • Professional or Employment-related Information, such as, current or past job history
  • Education Information, such as education records directly related to students maintained by us or a third-party acting on our behalf, such as, grades, transcripts, class lists, student schedules, student identification codes, and disciplinary records
  • Inferences drawn from online activities and the other data listed in this section, such as, a profile reflecting preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes
  • Other Personal Information, such as the results of a drug and alcohol screen and criminal convictions and offences data

We may use your personal information for the following purposes:

  • To provide you with information, products, or services that you request from us such as details about our programs, enrollment, ongoing education, and career services
  • To administer applications, enrollment, registration, financial services, and alumni programs
  • To fulfill any other purpose for which you provide it
  • To carry out our obligations and enforce our rights arising from any contracts entered between you and us
  • To process payment or facilitate delivery of services requested
  • To provide you with support and respond to your inquiries, such as to investigate and address your concerns, and monitor and improve our responses
  • To provide, personalize, measure, and improve our website experience and to deliver content and product and service offerings based on your advertising customization preferences
  • To send you information about our products, services, and promotions
  • To administer promotional activities, such as surveys, sweepstakes, contests, and referrals
  • To help maintain and improve the safety, security, and integrity of our campuses, facilities, website(s), and applications
  • For testing, research, analysis, and product development, such as to develop and improve our websites, products and services, databases and other technology assets, and offerings
  • To support our general business operations
  • As described to you when collecting your personal information or to fulfill any other purpose for which you provide it

To opt-out of the sale of your personal information, please send “Do Not Sell My Personal Information” to OCLPrivacy@oncourselearning.com.

Request to Know
California residents have the right to request, subject to certain exemptions, that we disclose certain information to them about our collection and use of their personal information over the past 12 months. As a California resident, you have the right to request the following without charge:

  • Categories of personal information collected about you;
  • Categories of sources for the personal information we collected about you;
  • Business and/or commercial purposes for collecting and selling that personal information;
  • Categories of third parties/with whom we have disclosed or shared that personal information;
  • Specific pieces of personal information we have collected about you;
  • Categories of personal information that we have disclosed or shared with a third party for a business purpose; and
  • Categories of third parties to whom the residents’ Personal Information was sold.

California residents may make up to two requests to know within a 12-month period. If you would like to exercise your rights, email us at OCLPrivacy@oncourselearning.com.

Sales of Personal Information
We disclose the following categories of personal information with third-party cookie and other ad-tech providers, who may further disclose your information throughout the digital advertising ecosystem. Such disclosures may be considered a sale for purposes of the CCPA.

  • Identifiers
  • California Customer Records
  • Internet or other electronic activity information
  • Geolocation data
  • Inferences drawn from personal information such as preferences, characteristics and behaviors.

Request to Delete
A California resident has the right to request deletion of the personal information we have collected about them and we will delete such personal information, except where an exemption applies. You may email us at OCLPrivacy@oncourselearning.com to request that we delete your personal information.

Incentives
Under CCPA, a business may offer financial incentives for the collection, sale or deletion of California residents’ personal information, provided it is not unjust, unreasonable, coercive or usurious, and is made available in compliance with applicable transparency, informed consent, and opt-out requirements. We may run sweepstakes or contests from time to time. Each contest or sweepstakes has its own terms and conditions that describe how an eligible consumer can opt-in, as well as withdraw from the contest or sweepstakes. In order to enter a sweepstakes or contest, you may be required to provide us (or our service provider) with certain personal information, such as your name and contact information. If you submit your entry in accordance with the applicable promotion’s rules, you will be entered into the promotion and will get a chance to win a prize. These promotions may be deemed a “financial incentive” under California law. We will not discriminate against you if you exercise your rights under CCPA. However, if you ask us to delete your information, you may not be able to participate in the sweepstakes or contest for which the deleted information was required to administer the promotion.

Parents / Guardians
Our Services are not directed to children under the age of 16. If we become aware that we have unknowingly collected personal information from a child under the age of 16, and do not have parent or guardian consent on file, we will delete such personal information from our records. If you believe we are incorrectly processing the personal information of a child under the age of 16, we recommend you contact us as provided in the final section of this policy.

Right to Non-Discrimination
You have the right not to receive discriminatory treatment for exercising any of the rights described above.

Verification
We will need to verify your identify before processing your request. In order to verify your identity, we will generally either require you to login to your account or we must be able to match certain information you provide us to the information we maintain about you. Certain requests may require us to obtain additional personal information from you. In certain circumstances, we may decline a request to exercise the right to know and/or right to deletion, particularly where we are unable to verify your identity or locate your information in our systems, or as permitted by law.

California “Shine the Light”
In addition to the rights described above, California’s “Shine the Light” law permits California residents to request certain information regarding our disclosure, if any, of certain categories of personal information to third parties for their direct marketing purposes during the immediately preceding calendar year. To make such a request, please send an email to OCLPrivacy@oncourselearning.com. This request may be made no more than once per calendar year.

Changes to this Privacy Notice
This California Privacy Notice may be updated periodically. If we make material changes, we will attempt to let you know via email or other communication. We encourage you to periodically review this page for the latest information on our privacy practices. As long as you continue to use the Services, you agree to this California Privacy Notice and any updates we make to it. We will not, however, use your personal information in a manner that is materially different than what we disclosed to you at the time the personal information was collected without your consent.

How to Contact Us
If you have any questions or concerns about this California Privacy Notice, contact us at:

OnCourse Learning Financial Services LLC
20225 Water Tower Blvd., Brookfield, WI  53045, USA.
OCLPrivacy@oncourselearning.com

Notice for Nevada Residents

If you are a Nevada resident, you can opt-out sales of certain covered information that a website operator has collected or will collect about you. You can opt-out by contacting us at OCLPrivacy@oncourselearning.com.

EEA & UK Data Subject Privacy Rights

If you are an individual located in the EEA or UK, you have the following rights:

  • The right to request access to your personal information,
  • The right to edit, correct, and update your personal information,
  • The right to request erasure of your personal information,
  • The right to restrict processing of your personal information,
  • The right to object to the processing of your personal information,
  • The right to data portability, and/or
  • The right to withdraw your consent, to the extent that we have collected your personal information based on your affirmative informed consent.

We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances and as identified above:

  • Where it is necessary for our legitimate interests. This can include processing your personal information for the purposes of providing and enhancing the provision of our Services, as well as advertising our products, credentials, designations, services, and information to you.
  • Where we need to perform the contract we have entered into or are about to enter with you.
  • Where we need to comply with legal obligations, resolve disputes, and enforce our contractual agreements.
  • Where we have your express opt-in consent.

If you wish to contact us in connection with the exercise of your rights listed above, contact us at OCLPrivacy@oncourselearning.com. Unless we notify you at the time of your request, we will not charge any fee in connection with the exercise of your rights. You also have the right to complain to or seek advice from a supervisory authority for data protection issues and/or bring a claim against us in any court of competent jurisdiction.