Effective Date: January 1, 2020
Last Updated: May 24, 2018
- Information We Collect
- How We Use Information We Collect
- Our Legal Basis for Collecting Personal Data
- Information We Share
- Your Failure to Provide Personal Data
- Our Retention of Your Personal Data
- Your Choices and Accessing, Updating or Deleting Your Personal Data
- Our Opt-in/Out-out Policy
- Third Party Links
- International Transfer
- How We Protect Personal Data
- Direct Marketing and “Do Not Track” Signals
- How to Contact Us
Irrespective of which country you live in, you authorize us to transfer, store, and use your information in the United States, and any other country where we operate. In some of these countries, the privacy and data protection laws and rules regarding when government authorities may access data may vary from those in the country where you live. Learn more about our data transfer operations in the “International Transfer” section below. If you do not agree to the transfer, storage and use of your information in the United States, and any other country where we operate, please do not use the Sites or Services.
Information We Collect
We collect information, including personal data, to provide better services to all our Users. We use the term “Personal Data” to refer to any information that identifies or can be used to identify you. Common examples of personal data include: full name, home address, email address, digital identity, such as a login name or handle, information about your device, and certain metadata.
“Sensitive Personal Data” refers to a smaller subset of personal data which is considered more sensitive to the individual, such as race and ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, genetic or biometric information, physical or mental health information, medical insurance data, or sexual orientation. eCornell does not collect or use Sensitive Personal Data and asks that you do not provide Sensitive Personal Data to us.
We collect Personal Data in the following ways:
- Information You Give to Us
When you register for an eCornell program, you may choose to provide us with personal data about yourself, including your name, email, phone number, and user login name and password, by completing forms on our website, such as when you request information about our Services, register for an account, purchase one of our programs, or participate in our programs or other services on our Sites. In order to complete the purchase of a program, an online credit card transaction may be required. During this process, you may provide us with the first and last name of the payment card owner, credit card billing address, payment card number, payment card expiration date, card verification value (“CVV”), phone number and email.
When using our Services, you may provide us with messages sent between those individuals you have authorized to use our Services. In some instances, you may elect to provide us with location and address information. You may also provide us with Personal Data about yourself when you report a problem or have a question about our services.
The Sites offer interactive and social features that permit you to submit content and communicate with other users. You may provide personal data to us when you post information in these interactive and social features. Please note that your postings in these areas of the Sites may be publicly accessible or accessible to other users.
Please note that if you do not provide us with Personal Data, your ability to use certain aspects of our products and services may be limited.
2. Information We Obtain from Your Use of Our Services
We collect certain information automatically, such as your operating system version, browser type, and internet service provider. When you use our Site, we automatically collect and store this information in service logs. This includes: details of how you used our Site; Internet protocol address; and cookies that uniquely identify your browser. We may also collect and process information about your actual location. The information we collect automatically is statistical data and may or may not include Personal Data, but we may maintain it or associate it with Personal Data we collect in other ways or receive from third parties.
3. Workplace and School Provided Information
Others engaging our services for your use, such as your employer or your school, provide us with personal data and your eligibility to use the Services that they purchase for use by their workers or students. The information provided by your employer or school may include your name and phone number.
4. Cookies and Similar Technologies
We and our partners use various technologies to collect and store information when you visit one of our services, and this may include using cookies or similar technologies to identify your browser or device. We also use these technologies to collect and store information when you interact with services from our partners, such as advertising services. Our third party advertising and analytics partners include Google, Pardot, Salesforce, and similar third party advertising or analytics partners.
The technologies we use for this automatic data collection may include:
- Web Beacons. Pages of our services or our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an e-mail and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
- Clickstream Data. Clickstream data is information collected by our computers when you request Web pages from the Sites. Clickstream data may include information such as the page served, the time spent viewing the page, source of the request, type of browser making the request, the preceding page viewed and similar information. Clickstream data permits us to analyze how visitors arrive at the Sites, what type of content is popular, what type of visitors in the aggregate are interested in particular kinds of content on the Sites.
How We Use Information We Collect
We use your personal data in ways that are compatible with the purposes for which it was collected or authorized by you, including for the following purposes:
- To inform you about services available from eCornell;
- To authorize access to our Sites and Services;
- To provide you with Services and Products;
- To offer and administer programs;
- To administer content, promotion, sweepstakes, surveys, voting polls or other Site features;
- To communicate about, and administer your participation in, special programs, surveys, contests, online campaigns, online programs, sweepstakes, and other offers or promotions, and to deliver pertinent emails;
- To improve our customer service;
- To respond to and support users regarding their use of the Sites and Services;
- To comply with all applicable legal requirements.
We use the information we collect from our Sites to provide, maintain, and improve them, to develop new services, and to protect our Company and our users.
We use information collected from cookies and other technologies, to improve your user experience and the overall quality of our services. We may use your personal information to see which web pages you visit at our Site, which web site you visited before coming to our Site, and where you go after you leave our Site. We can then develop statistics that help us understand how our visitors use our Site and how to improve it. We may also use the information we obtain about you in other ways for which we provide specific notice at the time of collection.
Our Legal Basis for Collecting Personal Data
Whenever we collect Personal Data from you, we may do so on the following legal bases:
- Your consent to such collection and use;
- Out of necessity for the performance of an agreement between us and you, such as your agreement to use our Services or your request for Products;
- Our legitimate business interest, including but not limited to the following circumstances where collecting or using Personal Data is necessary for:
- Intra-organization transfers for client data for administrative purposes;
- Product development and enhancement, where the processing enables eCornell to enhance, modify, personalize, or otherwise improve our services and communications for the benefit of our users, and to better understand how people interact with our Sites;
- Communications and marketing, including processing data for direct marketing purposes, and subject to your opt-in for these purposes, and to determine the effectiveness of our promotional campaigns and advertising;
- Fraud detection and prevention;
- Enhancement of our cybersecurity, including improving the security of our network and information systems; and
- General business operations and diligence;
Provided that, in each circumstance, we will weigh the necessity of our processing for the purpose against your privacy and confidentiality interests, including taking into account your reasonable expectations, the impact of processing, and any safeguards which are or could be put in place. In all circumstances, we will limit such processing for our legitimate business interest to what is necessary for its purposes.
Information We Share
We do not share personal information with companies, organizations and individuals outside of the Organization unless one of the following circumstances applies:
- With your consent. We will share personal data with companies, organizations or individuals outside of eCornell when we have your consent to do so.
- Enterprise accounts. Your employer or school may offer you access to our Services. We will share personal data with your employer or school. Your employer or school can review and manage your use of such enterprise Services. For example, we may share your registration information with Cornell University, which will use it as part of your enrollment in programs offered through eCornell. We may also release your 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.
- For Legal Reasons. We will share Personal Data with companies, organizations or individuals outside of eCornell if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to:
- meet any applicable law, regulation, legal process or enforceable governmental request.
- detect, prevent, or otherwise address fraud, security or technical issues.
- protect against harm to the rights, property or safety of eCornell, our Users or the public as required or permitted by law.
- We attempt to notify Users about legal demands for their personal data when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand.
- Business Transfers. If we establish a new related entity, are acquired by or merged with another organization, or if substantially all of our assets are transferred to another organization, Personal Data about our users is often a transferred business asset. In the event that eCornell itself or substantially all of our assets are acquired, Personal Data about our users may be one of the transferred assets.
- Aggregate Site Use Information. We may share aggregate and anonymized/pseudonymized Personal Data to third parties in order to promote or describe use of the Sites, for research, marketing, advertising, or similar purposes.
Your Failure to Provide Personal Data
Your provision of Personal Data is required in order to use certain parts of our services and our programs. If you fail to provide such Personal Data, you may not be able to access and use our Services and/or our programs, or parts of our Services and/or our programs.
Our Retention of Your Personal Data
We may retain your Personal Data for a period of time consistent with the original purpose for collection. For example, we keep your Personal Data for no longer than reasonably necessary for your use of our programs and Services and for a reasonable period of time afterward. We also may retain your Personal Data during the period of time needed for us to pursue our legitimate business interests, conduct audits, comply with our legal obligations, resolve disputes and enforce our agreements.
Your Choices and Accessing, Updating or Deleting Your Personal Data
Whenever you use our services, we aim to provide you with choices about how we use your personal data. We also aim to provide you with access to your Personal Data. If that information is wrong, we strive to give you ways to update it quickly or to delete it – unless we have to keep that information for legitimate business or legal purposes. Subject to applicable law, you may obtain a copy of personal information we maintain about you or you may update or correct inaccuracies in that information through your eCornell account at www.ecornell.com, or by contacting us. To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to the information. In addition, if you believe that personal information we maintain about you is inaccurate, subject to applicable law, you may have the right to request that we correct or amend the information by contacting us as indicated in the How to Contact Us section below.
- European Users’ Rights With Respect to Personal Data
Some data protection laws, including the European Union’s General Data Protection Regulation (“GDPR”), provide you with certain rights in connection with Personal Data you have shared with us. If you are resident in the European Economic Area, you may have the following rights:
- The right of access. You have the right to request a copy of your Personal Data which we hold about you.
- The right of correction: You have the right to request correction or changes of your Personal Data if it is found to be inaccurate or out of date.
- The right to be forgotten: You have the right to request us, at any time, to delete your Personal Data from our servers and to erase your Personal Data when it is no longer necessary for us to retain such data. Note, however, that deletion of your Personal Data will likely impact your ability to use our services.
- The right to object (opt-out): You have the right to opt-out of certain uses of your Personal Data, such as direct marketing, at any time.
- The right to data portability: You have the right to a “portable” copy of your Personal Data that you have submitted to us. Generally, this means your right to request that we move, copy or transmit your Personal Data stored on our servers / IT environment to another service provider’s servers / IT environment.
- The right to refuse to be subjected to automated decision making, including profiling: You have the right not to be subject to a decision and insist on human intervention if the decision is based on automated processing and produces a legal effect or a similarly significant effect on you.
- The right to lodge a complaint with a supervisory authority.
You may also contact us using the contact information below, and we will consider your request in accordance with applicable laws.
You may also have the right to make a GDPR complaint to the relevant Supervisory Authority. A list of Supervisory Authorities is available here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm. If you need further assistance regarding your rights, please contact us using the contact information provided below and we will consider your request in accordance with applicable law. In some cases our ability to uphold these rights for you may depend upon our obligations to process personal information for security, safety, fraud prevention reasons, compliance with regulatory or legal requirements, or because processing is necessary to deliver the services you have requested. Where this is the case, we will inform you of specific details in response to your request.
- Changing or Deleting Your Information
You may update or correct information about yourself by making changes to your profile, or emailing us at email@example.com. If you completely delete all such information, then your account may become deactivated. We may retain an archived copy of your records as required by law, to comply with our legal obligations, to resolve disputes, to enforce our agreements or for other legitimate business purposes.
We may contact you to request that you update your Personal Data on a regular basis to ensure its integrity for the purposes of ongoing data management.
- Our Opt-in/Opt-out Policy
We currently provide the following opt-out opportunities:
- At any time, you can follow a link provided in offers, newsletters or other email messages (except for e-commerce confirmation or service notice emails) received from us to unsubscribe from the service.
Third Party Links
The Sites may contain links to webpages operated by parties other than eCornell. We do not control such websites and are not responsible for their contents or the privacy policies or other practices of such websites. Our inclusion of links to such websites does not imply any endorsement of the material on such websites or any association with their operators. Further, it is up to the User to take precautions to ensure that whatever links the User selects or software the User downloads (whether from this Site or other websites) is free of such items as viruses, worms, trojan horses, defects and other items of a destructive nature. These websites and services may have their own privacy policies, which the User will be subject to upon linking to the third party’s website. eCornell strongly recommends that each User review the third party’s terms and policies.
We are committed to complying with applicable laws, regulations and mandatory government standards regarding the protection of Personal Data.
If we transfer your Personal Data out of your jurisdiction, we will implement suitable safeguards and rely on legally-provided mechanisms to lawfully transfer data across borders to ensure that your Personal Data is protected. We are certified to the EU-US Privacy Shield and it is our policy to, where required by applicable laws, execute a Data Privacy & Data Security Addendum with all third parties with whom we may share Personal Data.
- EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield
eCornell complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries (including Iceland, Liechtenstein, and Norway) and Switzerland transferred to the United States.
With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, eCornell is subject to the regulatory and enforcement powers of the U.S. Federal Trade Commission.
EU and Swiss individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States. Upon request, we will provide you with access to the personal information that we hold about you. You may also may correct, amend, or delete the personal information we hold about you. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States under Privacy Shield, should direct their query to firstname.lastname@example.org. If requested to remove data, we will respond within a reasonable timeframe.
We will provide an individual opt-out choice, or opt-in for sensitive data, before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please submit a written request to email@example.com.
In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
eCornell commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States. European Union and Swiss individuals with inquiries or complaints should first contact ECornell by email at firstname.lastname@example.org or via post at:
950 Danby Road, Suite 150
Ithaca, New York 14850
How We Protect Personal Data
eCornell maintains administrative, technical and physical safeguards designed to protect the User’s Personal Data and information against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. We implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk, taking into account technological reality, cost, the scope, context and purposes of processing weighted against the severity and likelihood that the processing could threaten individual rights and freedoms. For example, we use commercially reasonable security measures such as encryption, firewalls, and Secure Socket Layer software (SSL) or hypertext transfer protocol secure (HTTPS) to protect Personal Data.
If eCornell collects account information for payment or credit, eCornell will use the information only to complete the task for which the account information was offered.
The Site is not intended for use by children. We do not intentionally gather Personal Data about visitors who are under the age of 16. If a child has provided us with Personal Data, a parent or guardian of that child may contact us to have the information deleted from our records. If you believe that we might have any information from a child under age 16 in the applicable jurisdiction, please contact us at email@example.com. If we learn that we have inadvertently collected the personal information of a child under 16, or equivalent minimum age depending on jurisdiction, we will take steps to delete the information as soon as possible.
Direct Marketing and “Do Not Track” Signals
eCornell does not track its users over time and across third party websites to provide targeted advertising and therefore does not respond to Do Not Track (DNT) signals. However, some third party sites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. If you are visiting such sites, your browser may include controls to block and delete cookies, web beacons and similar technologies, to allow you to opt out of data collection through those technologies.
California residents are entitled to contact us to request information about whether we have disclosed personal information to third parties for the third parties’ direct marketing purposes. We do not disclose personal information to third parties for the third parties’ direct marketing purposes. California users may request further information about our compliance with this law by e-mailing us at the address listed in the “How to Contact Us” section.
- January 1, 2020
- May 24, 2018
How to Contact Us
Send e-mail to: firstname.lastname@example.org
Send mail to our address:
950 Danby Rd.
Ithaca, NY 14850