Last updated: January 1, 2020

KEYPATH Education, LLC (who we refer to, together with our affiliates, as “Keypath,” “us,” “we,” or “our,” depending on the context) respects your privacy, and takes the privacy and security of personal information seriously.

This Privacy Policy explains:

• What information we collect, how we collect that information, and how we use that information;
• When and with whom we may share information we collect; and
• Your choices and rights regarding your personal information.

This Privacy Policy applies to information we collect through the sites that link to this Privacy Policy (referred to collectively as the “Site”), as well as through any other contact you have with Keypath through or on behalf of St. Bonaventure University (our “Partner School”) in connection with the educational programs they offer with our assistance (referred to generally as a “Program” or the “Programs”) .

YOU SHOULD CAREFULLY READ THIS PRIVACY POLICY. By accessing, browsing, or otherwise using the Site, you are creating a binding contract between you and us, and you are acknowledging that you have read, understood, and agreed to be bound by this Privacy Policy. If you do not agree with the terms of this Privacy Policy and would prefer that we not collect, use, or share your information as we describe, you should not use the Site or otherwise provide us with any information.

COLLECTION AND USE OF PERSONAL INFORMATION

A. What We Mean By “Personal Information.”

“Personal Information” refers to information that can be used to personally identify you, a specific individual. Different states, countries, and laws define Personal Information (or similar terms, such as “personally identifiable information” and “personal data”) differently, but Personal Information generally includes information such as your name, mailing address, e-mail address, and phone number. It may also include the internet protocol (IP) address of your computer or mobile device if that IP address can be associated with other Personal Information and used to identify a particular person, or geo-location information, again if that information can be used to pinpoint a specific party.

B. Providing Personal Information Is Your Choice.

We will collect Personal Information from you only if you voluntarily provide it to us. For example, if you decide to contact us, such as through a “Contact Us,” “Request More Information,” or similar links on the Site, if you request information about our Partner Schools or about the Programs and other services we and they offer, if you apply for enrollment in a Program, or if you sign up to receive newsletters or other materials, you may provide us with your name, email address, and any other information you include with your submission. If you participate in a Program, we will obtain Personal Information from you so that we and our Partner School provide you with the services that you have signed up to receive.

If you choose not to provide certain Personal Information, that choice may make it difficult or impossible for you to access services through the Site. For example, you may not be able to enroll in or complete a Program. However, it is ultimately your choice whether you want to interact with us and the Partner School, enroll in Programs, and/or participate in online learning through the Partner School.

In addition, our site, like most websites, automatically collects certain information from site visitors, such as the IP address or other unique identifier of your computer or other device, and information about the browsing history and website interactions associated with that device. This device and online activity information may be considered Personal Information. However, we do not use this type of automatically-collected Personal Information to identify or to further interact with a particular person unless and until that user voluntarily provides other Personal Information in the manner outlined above. More information about how we use this information on an anonymous and/or aggregate basis is described below under “How We Collect and Use Non-Personally Identifiable Information.”

C. The Type of Personal Information We Collect and How We Use It.

1. Personal Information We and Our Partner Schools Collect Directly

The Personal Information you may be asked to provide to us and/or our Partner School, and how we and they may use that Personal Information, is described below. We present this information based on the categories of Personal Information collected, but please note that similar specific pieces of information may apply to multiple categories. For example, your name and email address may be included within each of the “Contact Information,” “Communication, Activity and Marketing Information,” and “Educational History Information” categories described below.

Category of Information	Why We Collect It	How We Use It
Contact Information Examples: Full name Email address Phone number Address/Location Contact preferences IP address Cookies data on browsing preferences and behavior and contact preferences The reason for your contact (i.e., the details of your inquiry or request)	We collect this information as necessary for us to enter into and/or perform a contract with you. For example, we may need this information to verify your identity. We also collect this information so that we can operate our business and provide services to you and others, as discussed further below.	To help us identify you. To provide you with information and services you have requested. This may include information that has been requested by a third party using “refer a friend” or similar referral forms. In addition, depending on our agreement with our Partner School, this may include information about other schools or online programs that may be of interest to you. To provide relevant information to you while browsing our website or upon your request, to assist you with enrollment in Programs or courses, and to facilitate flexible online learning. Subject to your right to opt out, to market to you by email or other electronic means.
Communication. Activity and Marketing Information Examples: Contact Information Email communications Text (SMS) communications Phone conversations/recordings Appointment requests, dates and statuses Advisor notes Public posts made by you Testimonials and opinions Images	We collect this information as necessary for us to enter into and/or perform a contract with you. For example, we may need to provide you with information about Programs you have enrolled in. We also collect this information so that we can operate our business and provide services to you and others, as discussed further below. Where legally necessary, we will obtain your consent to collect this information (such as to use your image in photos and videos).	To allow you to participate in interactive areas of the Site, such as participating in discussion forums or providing comments to others’ posts. To ensure the quality of our services and interactions with you. To provide you with information and services you have requested. Depending on our agreement with our Partner School, this may include information about other schools or online programs that may be of interest to you. To assist you with the enrollment in Programs and courses and to facilitate flexible online learning. Subject to your right to opt out, to market to you by email or other electronic means. To provide the public with information about our Partner School, Programs, and other products and services for purposes of marketing.
Personal/Demographic Information Examples: Contact Information Educational History Information Employment History Information Age/age range Internet access/IP address Currency Languages Nationality Gender Religious affiliation Racial/Ethnic background Veteran or military status	We collect this information as necessary for us to enter into and/or perform a contract with you. For example, we may need this information to verify your identity and application information. We also collect this information so that we can operate our business and provide services to you and others, as discussed further below.	To ensure the quality of our services and interactions with you. To respond to and/or address your requests and inquiries, and/or to provide requested information to you. To assist you with the enrollment in Programs and courses and to facilitate flexible online learning.
Educational History Information Examples: Contact Information Education level Degrees held, prior schools attended, transfer credits Reasons for study English proficiency test information Prior assessment information Transcripts	We collect this information as necessary for us to enter into and/or perform a contract with you. For example, we may need this information to verify your identity and application information and to process your application and enrollment. We also collect this information so that we can operate our business and provide services to you and others, as discussed further below.	To provide you with information about the Partner School, Program(s), and/or course(s) you may be interested in or that may be of interest based on your indicated preferences. To respond to your inquiries regarding our Partner School, Program(s), and/or course(s). To assist you with the enrollment in Programs and courses and to facilitate flexible online learning.
Employment History Information Examples: Contact Information Previous and current employer(s), job title, and employment status	We collect this information as necessary for us to enter into and/or perform a contract with you. For example, we may need this information to verify your identity and application information and to process your application and enrollment. We also collect this information so that we can operate our business and provide services to you and others, as discussed further below.	To provide you with information about the Partner School, Program(s), and/or course(s) you may be interested in or that may be of interest based on your indicated preferences. To respond to your inquiries regarding our Partner School, Program(s), and/or course(s). To assist you with the enrollment in Programs and courses and to facilitate flexible online learning.
Financial Aid-Related Information Examples: Financial plans for investment in Program(s) and/or course(s) (i.e., self-funding, student loan, employer loan, other) and payment method(s) Financial aid representative Financial aid application status	We collect this information as necessary for us to enter into and/or perform a contract with you. For example, we may need this information to verify your identity and application information and to process your application and enrollment. We also collect this information so that we can operate our business and provide services to you and others, as discussed further below.	To provide you with information about the Partner School, Program(s), and/or course(s) you may be interested in or that may be of interest based on your indicated preferences. To respond to your inquiries regarding our Partner School, Program(s), and/or course(s). To assist you with the enrollment in Programs and courses and to facilitate flexible online learning.
Partner School Program Information Examples: Contact Information Application Information Application status Reasons for study Risk factors for completing the Program(s) or course(s), such as academic, financial, personal, or technical issues Preferred Program(s) or course(s) Program and course eligibility and prerequisite information Planned enrollment dates and details Program(s) and course(s) admission and acceptance status The number of Program(s) and/or course(s) you enroll in Course registration details, dates, status, and outcome Official student enrollment details, dates, status and outcome(s) Evaluation, assessment, and participation details Degree path plans	We collect this information as necessary for us to enter into and/or perform a contract with you. For example, we may need this information to verify your identity and application information and to process your application and enrollment. We also collect this information so that we can operate our business and provide services to you and others, as discussed further below.	On behalf of the Partner School, to provide you with information and services you have requested from the Partner School. To assist you with the enrollment in Programs and courses and to facilitate flexible online learning. To respond to and/or address your requests and inquiries, and/or to provide requested information to you, including information that has been requested by a third party using “refer a friend” or similar referral forms.
Application Information Examples: Contact Information Personal/Demographic Information Educational History Information Employment History Information Financial Aid-Related Information Other identifiers (e.g., government-issued ID numbers) Special needs information (e.g., physical or mental disabilities) Letters of recommendation Criminal history/convictions	We collect this information as necessary for us to enter into and/or perform a contract with you. For example, we may need this information to verify your identity and application information and to process your application and enrollment. We also collect this information so that we can operate our business and provide services to you and others, as discussed further below.	To assist you with the application process and enrollment in Programs and courses and to facilitate flexible online learning.

2. Personal Information We Obtain From Third Parties

In addition to the Personal Information that we and our Partner School collect directly from you through your interaction with the Site and your participation in Programs and other services we and our Partner School Offer, we collect some Personal Information from third parties. We engage with third party data enrichment providers, who enhance Personal Information we collect and share with them (as discussed below) to provide us with additional information relating to demographics, lifestyle/interests, and household income. We use this information to better understand students and potential students, so that we can tailor our marketing messaging to specific persons, so that the information we provide is meaningful and helpful to both our Partner School and to the recipient.

3. Certain Generally-Applicable Uses of Personal Information

In addition, all of the Personal Information we collect directly and from third parties may be used for the following additional purposes, all of which are related to the operation of our business and our provision of services:

• Our and our Partner School’s internal record-keeping;
• To enable us or our Partner School to contact you by e-mail, text or phone for any of the above reasons;
• Where necessary as part of any restructuring of Keypath and its affiliates (the Keypath Group);
• For compliance with legal, regulatory, and other good governance obligations;
• To convert Personal Information into pseudonymous and/or anonymous data, and use it (normally on an aggregated statistical basis) for research and analysis;
• To gain insight that enables us and our Partner School to measure the effectiveness of our services;
• To learn about potential and current students so that we can improve the Programs and provide you and others with better services; and
• To evaluate potential and current students’ needs and resources applicable to the Programs, and to tailor our marketing messages to your and their specific interests, needs, and abilities.

When we use your Personal Information for our business purposes, those business purposes include working with our Partner School to make Programs available, responding to your, our students’ and potential students’ comments and complaints, marketing our and our Partner School’s products and services, improving and developing new products and services, and ensuring the productivity, functionality, and security of the Site.

D. How Long We Keep Personal Information.

We will keep your Personal Information as long as we have a business need to do so and/or as necessary to meet the purpose for which the information was collected and used, unless a longer period is required by law or by contract with our Partner School. For example, we will keep Personal Information for at least as long as you continue to be enrolled in any Program. And, if any Site allows you to create an account, we will keep the Personal Information associated with your account for as long as you maintain it. Business needs for which Personal Information may be retained include legal, tax, accounting, risk management, and other business purposes.

All applicant, enrollment, and student details will be kept for at least as long as we continue to provide services to the Partner School, unless we agree otherwise with the Partner School. Once we cease to have a relationship with our Partner School, our practice is to de-identify all Personal Information we have learned in the course of that relationship.

It is important to note that some information may be made public. For example, with your consent we may use your image and testimonials in promotional materials. Accordingly, your information will be able to be seen and republished for as long as the marketing materials continue to be posted online, or as long as the hard copies remain in existence. In addition, we or our Partner School may make available services that enable you to post information on the Site in public forums and on message boards. In these cases, once posted the information will be able to be seen and republished by others for as long as the web page remains active. Even if web pages are deleted, they may continue to be accessed if they are archived or cached. Therefore, you should think carefully before giving your consent to the use of your name, image, and comments in any materials and, if applicable, before posting anything in any public area of the Site.

How We Collect and Use Non-Personally Identifiable Information

A. What Is Non-Personally Identifiable Information?

Non-personally identifiable information refers to information that is not and cannot be used to identify a specific individual. This may include information about the statistical characteristics of the visitors to the Site or persons who enroll in Programs. While this information may define how you fit into a particular group of people, it is not unique to you, and it cannot be used (without other information) to specifically identify you. This section describes how we collect and use non-personally identifiable information.

B. The Non-Personally Identifiable Information We Collect and Why.

When you visit the Site or interact with us electronically (such as through email), we may automatically collect standard internet and website log information, and details of patterns about how the Site visitors behave. This information includes your internet service provider name, your operating system, your browser type and browser language, the IP address of your computer or other device (unless such IP address can be used to identify you), your access times, the website that referred you to the Site, the specific web pages you visit and the date and time of those visits, and links clicked as you visit the Site.

We use this information to evaluate the Site, to find out which parts of the Site are popular or that may need improvement, and to enhance your and others’ Site experiences. 

C. Cookies and Other Tracking Technologies.

The Site utilizes “cookies”, anonymous identifiers and other tracking technologies such as web beacons, which enable us to distinguish you from other users and provide you with information that is customized for you. For more information, see the “Cookie Policy” section of this Privacy Policy. 

D. Analytics Services.

The Site may use analytics tools and services to collect information about use of the Site, such as how often users visit the Site, what pages they visit when they do so, and what other sites they used prior to visiting the Site. We use the information we collect from the analytics services to maintain and improve the Site and our and our Partner School’s services. The analytics services we use include Google Analytics, Facebook Ads, and others. 

E. Anonymous Information.

Anonymous information refers to information that does not enable identification of an individual user, such as aggregated or demographic information. We may use anonymous information or disclose it to third party service providers to improve the Site and our and our Partner School’s services. We may also disclose anonymous information to third parties, including market research firms.

COOKIES POLICY

A. What Are Cookies?

Cookies are small amounts of data that are stored on your browser, device, or the page you are viewing when you visit a website. Some cookies are deleted once you close your browser or application (session cookies), while other cookies are retained even after you exit so that you can be recognized when you return (persistent cookies). Cookies do not typically contain any information that personally identifies a user, but Personal Information that we store about you may be linked to the information stored in and obtained from cookies.

B. How We Use Cookies.

We use both session and persistent cookies on the Site. The cookies we use are generally divided into the following categories:

• Mandatory cookies: These are cookies that are required for the operation of the Site, such as cookies that enable you to log into secure areas.
• Functional cookies: These are cookies that remember choices that you make when you visit the Site such as language options. They help to make your visit more personal and assist your navigation of the Site.
• Analytics/Marketing cookies: These are cookies that automatically collect information about your use of the Site, such as the pages you visit, and the links you followed. These help us recognize previous visitors to the Site, and understand how many people are using the Site and how they navigate through it. As mentioned above, we use analytics services to analyze user behavior, so these third parties will place these types of cookies on the Site.

C. Your Choices About Cookies.

Most web browsers automatically accept cookies, but you can usually change your settings to prevent that, such as by having your device warn you each time a cookie is being sent or choosing to turn off all cookies. On the Site, you will be able to disable all cookies other than mandatory cookies. This can be done through your web browser settings, and because each browser is different, you should look at your browser’s “Help” menu to learn how to modify your cookie settings. There are also online resources that may help you learn more how to opt out of targeted behavioral advertising from many major third party network advertisers.

If you do disable cookies from your browser you may not be able to access certain sections of the Site that use essential cookies, and this may make your experiences on the Site less efficient.

D. Do Not Track Requests

Currently, certain browsers, including Firefox, Google Chrome, Safari and Internet Explorer, offer a “do not track” (DNT) option. This option, using a technology known as a DNT header, sends a signal to websites visited by the user about the user’s DNT preference, if any, set on the browser. However, we do not currently commit to responding to browsers’ DNT signals. We cannot make this commitment because no common industry standard for DNT has been adopted by industry groups, technology companies, or regulators.

HOW WE MAY SHARE INFORMATION

A. Sharing Information with the Partner School.

We collect, use, and process your Personal Information on behalf of our Partner School, and accordingly, it will be shared with the Partner School for all purposes consistent with this Privacy Policy, including to process applications and enrollment materials and to fulfill our contractual relationship with the Partner School. In addition, we may also collect and share your Personal Information with the Partner School so that we can collaborate with them to develop, deploy, and deliver additional Programs and courses, and to facilitate flexible online learning.

Please note that we have no control over how the Partner School uses Personal Information and other information we share with them. Our Partner School has its own privacy policy, and their collection and use of your Personal Information is subject to their policy, which will be different from this Privacy Policy.

B. Sharing Information with Others.

We may share information with other third parties in the following circumstances:

• We may share your information, including Personal Information, so that we or others may provide you with periodic mailings, or may contact you regarding products, services, or events. Depending on our relationship with our Partner School and the preferences you have indicated, this may include sharing your Personal Information with other institutions so that we or they can contact you regarding other online programs. If you do not wish for us to share your information in this manner, please let us know by contacting us at info@keypathedu.com.
• We may employ other companies and people to perform tasks on our behalf and we may need to share Personal Information with them to provide services to you. For example, such parties may handle our data management and/or email distribution. Other parties are provided with Personal Information so that they can provide the data enrichment services discussed above. Unless we tell you differently, they do not have any right to use your Personal Information beyond what is necessary to assist us.
• We may share information, including Personal Information, with our corporate affiliates in the Keypath Group of companies for our and their legitimate business purposes, including the potential expansion and promotion of our and their product and service offerings, and other uses consistent with the purposes described in this Privacy Policy.
• We may share your Personal Information with your employer, if your employer is paying for your enrollment in a Program.
• We will share Personal Information with third parties for other purposes if we have your express “opt-in” consent to do so.
• We may disclose non-personal, aggregate, anonymous data in a de-identified format for any legitimate business purpose.
• We may disclose Personal Information at the request of law enforcement or government agencies or in response to subpoenas, court orders, or other legal process to establish, protect, or exercise our legal or other rights or to defend against a legal claim, or as otherwise required or allowed by law.
• We may disclose Personal Information if we believe that such action is appropriate to (a) protect the rights, property, or safety of a user of the Site or any other person, (b) investigate or prevent a violation by you of any contractual or other relationship with us or our Partner School, (c) investigate or prevent your actual or potential illegal, fraudulent, or harmful activity, or (d) detect, prevent, or otherwise address fraud, security, or technical issues.
• We may share information, including Personal Information, in connection with, during negotiations of, or as a part of the closing of any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

We will never sell your Personal Information.

SOCIAL SHARING FEATURES AND THIRD PARTY WEBSITES

The Site may offer social network and similar sharing features, such as Facebook, Twitter, Instagram, and YouTube buttons, which let you share information related to the Site, our Partner School, and/or the Program(s) you enroll in through your preferred social media platforms. In addition, the Site may include links to other third party websites. Those sites, and the third parties’ use of any data that may be collected by those sites, is not governed by this Privacy Policy. You should always review the privacy policies of any site you visit before submitting your Personal Information.

If you permit a connection between the Site and your social network page(s) or another third party site, we (and the other site operator) may be able to identify you, and associate the information we (and they) receive with information we (and they) already have about you. In addition, depending on how you use those features and your settings with the social network or other third party site, the information you share may be available to others, including your friends and/or the public. For more information about how your information may be shared through those social networks and other third party sites once it is provided to them, review the privacy policies of those social networks and other third party sites.

Our Security Measures

We use a variety of industry-standard security measures to maintain the safety of your Personal Information, including measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration and disclosure. We store the Personal Information you provide on secure (password- and firewall-protected) servers.

Unfortunately, no electronic data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we believe that we use reasonable measures to protect Personal Information, we cannot ensure or warrant the security of any information transmitted or otherwise provided to us or received from us.

If any portion of the Site allows you to create an account, it will be your responsibility for keeping your account and password confidential. We will never ask for your password (except, if applicable, when you create your account and log into the Site).

YOUR RIGHTS REGARDING Your Information

A. General Rights.

If you have any questions regarding this Privacy Policy or our use of your Personal Information, you can contact us by email at info@keypathedu.com. In addition, you can also contact us at any time at info@keypathedu.com to request that we make any edits to your Personal Information.

If, where applicable, you have an account on any Site, you can access and edit your account information online, by signing into your account and selecting the information you want to edit.

As noted above, we have standard retention practices with respect to the Personal Information we collect. If you would like to request any earlier removal of your Personal Information, please contact us at info@keypathedu.com. Please note that we may not be able to completely remove Personal Information from the Site or our systems in certain circumstances. This will be true if the data is not in a searchable format, if it is retained in backup systems or cached or archived pages, if we need it to prevent fraud or future abuse, or if we are required by law to keep it.

B. Your Rights Regarding Direct Marketing.

As noted above in this Privacy Policy, we may use your Personal Information to provide you with marketing and promotional information about our and our Partner School’s products and services. These promotions may be made by mail, email, telephone, instant messaging application, or text (SMS) message, or other methods that may become relevant or available. All promotional materials that are sent by use using electronic means will include a simple means for you to stop receiving further communications. For example, we may provide you with an “unsubscribe” link, or any email address to which you can send an opt-out request. In addition, if we need your consent for direct marketing communications under applicable law, and if you provide your consent, you will be able to change your mind at any time.

You can manage your consent preferences with respect to direct marketing activities by contacting us at info@keypathedu.com.

Please note that despite your email preferences, we may need to contact you regarding your enrollment at our Partner School, as required by law, or regarding legal matters. However, we will not send you marketing communications if you have opted out of receiving them.

C. Rights of California Residents

Please see our Privacy Notice for California Residents.

A NOTE ABOUT CHILDREN

The Site is not targeted to, and we have no interest in collecting information from, children, and we do not knowingly gather any Personal Information from children under the age of 13. If you are a parent or a legal guardian who believes that your minor child provided us with any Personal Information, please contact us at info@keypathedu.com.

CHANGES TO THIS PRIVACY POLICY

We may make changes to this Privacy Policy. Any modifications will be effective when the changes are posted to the Site. You can review the most current version of this Privacy Policy at any time by accessing the section of the Site labeled Privacy Policy, and you can determine when this Privacy Policy was last revised by referring to the “Last Updated” legend at the top of this Privacy Policy. You are expected to check this Privacy Policy from time to time to take notice of any changes. You understand and agree that your continued access to or use of the Site after any posted modification to this Privacy Policy indicates your acceptance of the modification, even if you did not take the time to read the modification.