Last Updated: August 7, 2018
Tower Innovative Learning Solutions, Inc. (d.b.a. eCornell) is a New York corporation with a principal place of business at 950 Danby Road, Ithaca, NY 14850. If you reside or are located in the European Union (“EU”) eCornell is the data controller of all Personally Identifiable Information (as defined below) collected by eCornell’s Sites.
The Information eCornell and Cornell Collect
eCornell and Cornell collect two kinds of information from you on our Sites:
Non-Personal Information: Our Sites recognize and record certain non-personal information, including the name of the domain and host from which you access the Internet (for example, aol.com or cornell.edu); the Internet protocol (IP) address of the computer you are using; the browser software you use and the operating system; the date and time you access the Site; and the Internet address of the web site from which you linked directly to this site.
Personally Identifiable Information: If you register for an eCornell program, including the program offered by the Bank of America Institute for Women’s Entrepreneurship at Cornell, you will be required to provide enrollment information that we process for your student account. Cornell and/or eCornell may collect Personally Identifiable Information that you provide when you register for an account, update or change information for your account, purchase our programs, request additional information, send us email messages, and/or participate in our programs or other services on our Sites. We may use the Personally Identifiable Information to respond to your inquiry, provide you access to the program you’ve purchased, and/or send you updates about your program.
eCornell and/or Cornell may collect personally identifiable information from you when you:
Request Info: When you request additional info from eCornell and/or Cornell, you will be required to provide us with Personally Identifiable Information such as your name and email address.
Purchase program access: If you purchase access to or otherwise enroll in an eCornell program, you will be required to provide us with Personally Identifiable Information such as your name and email address.
Participate in programs: When you participate in an online program, you may be asked to provide us with some information necessary to conduct such a course. This information may include, among other things, your name and email address, and basic information about your business.
If you participate in an online program, we may collect your student-generated content, such as assignments you submit to program instructors and comments you make in the program’s online forums. Cornell and eCornell may also collect course data, such as student responses to quizzes, exams, and surveys.
Communications with Cornell and eCornell: We may receive Personally Identifiable Information when you send us an email message or otherwise contact us.
How eCornell and Cornell Use the Information We Collect
Your data is used to fulfill your registration and provide you the services you requested. The data may also be used to provide you personalized content, deliver features to enable you to interact with others, and communicate about, improve, or troubleshoot the products or services being provided. We may also use the data to evaluate and conduct research about the program and its students, but will only do so in ways that preserve the anonymity of individual students.
We use the data we collect from you to:
- Fulfill your order
- Send you an order confirmation
- Send you requested program information
- Enable you to participate in program discussions and assignments
- Send product updates
- Respond to customer service requests
- Administer your account
- Deliver certificates of completion
- Evaluate the program and conduct aggregated research
As is true of most Web sites, we automatically gather information about your computer such as your IP address, browser type, referring/exit pages, and operating system.
We do not sell, trade, or rent your personal information to others. eCornell and Cornell may share certain of your registration information with one another, and may use it as a part of your enrollment in programs offered through eCornell. We may release account information when we believe, in good faith, that such release is reasonably necessary to (i) comply with law, (ii) enforce or apply the terms of any of our user agreements or (iii) protect the rights, property or safety of eCornell, Cornell, our users, or others. We may also release information to your employer, if your enrollment is through a corporate agreement and disclosure is needed to comply with the employer’s request for information, and to any third party administrator, if your enrollment is through this third party administrator and disclosure is needed to comply with the third party administrator’s request for information. Customer data is retained by eCornell and/or Cornell for as long as necessary to maintain business operations related to customer activities. In the event of bankruptcy or insolvency, all customer data would be destroyed. In the event of a merger, all customer data will be transferred to the new organization/entity.
Correcting, Updating and Deleting Your Personal Information
You are responsible for ensuring the accuracy of the personal information you provide to eCornell and Cornell. To review and update your personal information to ensure it is accurate, log on to eCornell’s student portal: https://portal.ecornell.com. You may use the Sites to update incorrect information yourself or email email@example.com to request updates to your personal information. If you reside in the EEA, you may request that we delete any Personally Identifiable Information which we are holding about you.
For EEA Residents
eCornell and/or Cornell may process personal data as either a Processor or as a Controller, as defined in the EU’s General Data Protection Regulation (GDPR), and each may transfer such data outside of the EEA. eCornell and Cornell adhere to the GDPR legal requirements, where applicable, for capturing consent of users for collection of data, securing covered data, and providing a right to be forgotten.
Residents within the EEA have the right to access certain of the personal information that eCornell /or Cornell maintain, and in some cases, may have the right to correct or amend information that is inaccurate or has been processed in violation of the GDPR and/or the Privacy Shield Principles, to the extent allowed by law. eCornell account holders may access and modify their personal information at any time through eCornell’s student portal: https://portal.ecornell.com. Residents within the EEA may request that we delete any Personally Identifiable Information which we hold about the user.
With respect to personal data received or transferred pursuant to the Privacy Shield Framework, eCornell is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, eCornell may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
If you, as an EEA resident, have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request. Under certain conditions, more fully described on the Privacy Shield website, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.
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If you and eCornell and/or Cornell don’t resolve any dispute by informal negotiation, any other effort to resolve the dispute will be conducted exclusively by binding arbitration. You are giving up the right to litigate (or participate in as a party or class member) all disputes in court before a judge or jury. Instead, all disputes will be resolved before a neutral arbitrator, whose decision will be final except for a limited right of appeal under the Federal Arbitration Act. Any court with jurisdiction over the parties may enforce the arbitrator’s award.
As an exception to the preceding paragraph, disputes between the State of New York and eCornell and/or Cornell shall be governed by and construed in accordance with the substantive and procedural laws of the State of New York, without regard to the conflict of laws and provisions of New York or any other state or jurisdiction. New York shall have exclusive jurisdiction in the event of any litigation.
Feedback, Questions, or Complaints
If you have privacy-related feedback, questions, or complaints you may contact eCornell at firstname.lastname@example.org.
If you reside within the EEA, our Privacy Team can assist with all queries regarding our processing of personal data at email@example.com.
If you reside within the EEA, you may file a complaint to a supervisory body for data protection matters or seek a remedy through local courts if you believe that your rights have been breached.
Cornell and eCornell Privacy Matters
You may view the general Cornell Privacy Notice at: http://www.cornell.edu/privacy-notice.cfm