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PRIVACY POLICY 

Effective Date: Mar 30, 2017.
To view and print our entire Privacy Policy, click here.  To view and print our entire Terms of Use, click here.  To receive copies of both documents by email, click here.

Introduction
Welcome! You have arrived at a site that is owned and/or operated by the University of Santa Monica (“USM or “we,” “our” or “us”).  This “Privacy Policy” governs your use of our USMOnline website, available at www.USMOnline.org (including, without limitation, both mobile and online versions of our site), and also applies to your use of interactive features, widgets, applications, content or downloads that we make available through the site and post this Privacy Policy (collectively referred to herein as the “Site”) regardless of how you access or use them, whether via personal computers, mobile devices or otherwise but does not apply to data we receive from third parties unless we combine such data with Personal Information (defined below) that we have ourselves collected under this Privacy PolicyOur statements under this Privacy Policy only cover information collected at the Site directly by us, and not by third parties that may interact with our Site.  This Privacy Policy does not apply to our data collection activities offline or otherwise outside of our Site (unless otherwise stated below).  To the extent we provide you notice on our Site of different or additional privacy policies or practices (e.g., at the point of our collection), those additional terms shall govern such data collection and use.
In addition, please review the Site’s Terms of Use, which governs your use of the Site.  By using our Site, you consent to our Privacy Policy and Terms of Use and our collection, use and sharing of your information and data, and other activities, as described below.

Linkable Table of Contents
It is important that you read and understand the entire Privacy Policy before using the Site.  To ease review, each section below contains a brief introductory summary and a link to the full explanation.  You can click on the headings and the “More” buttons to be taken to the full explanation.  Any capitalized terms that appear in but are not otherwise defined in the introduction are intended to have the meanings given to them elsewhere in the Privacy Policy.

1. What Information Does the Site Collect?

(a) Information You Provide To Us

You may give us Personal Information and Demographic Information, such as when you register or contact us.

(b) Information We Collect and Store As You Access and Use the Site

Tracking Technologies collect Usage Information based on your Device Identifier.

(c) Information Third Parties Provide About You

We may obtain information about you from third parties.

(d) Information You Provide About a Third Party

You may give us information about others, such as when you send a friend a message through the Site.

2. How Do We Use the Information Collected?

We use your Personal Information, Demographic Information and Usage Information for a variety of purposes.

3. How and When Do We Disclose Information To Third Parties?

We may provide your information to third parties under various circumstances. These may include:

(a) When You Request Information From or Provide Information to Third Parties

If you request information from third parties, request that we send information to third parties or interact with third party sites, content, ads or tools (including Facebook and other third party share functionality) we may share your information with such parties and/or they may collect your information directly.

(b) Third Parties Providing Services on Our Behalf

Our vendors may collect your information or we may share it with them. This includes third party content and course providers and/or operators.

(c) Administrative and Legal Reasons

There are a variety of administrative and legal reasons for which we may share your information

(d) Affiliates and Business Transfer

We may share your information with our affiliates or in the event of a sale, merger or similar transaction.

(e) Co-branded Areas

Co-branded areas may include information collection by us and third parties. Such third parties’ privacy policies, not ours, govern their practices.

(f) Sweepstakes, Contests and Promotions

Promotions entrants may be required to consent to certain information sharing.

4. What About Information I Disclose Publicly?

(a) User Generated Content and Public Information

Posting content in public areas makes it available to others.

(b) Name and Likeness

You grant us the right to use your name and likeness in connection with your posting and activities.

(c) Profiles

Learn about profiles for participation in our community.

5. Do Third Party Content and Links to Third Party Sites Appear on the Site?

We are not responsible for your interaction with third party content or locations.

6. Do Third Party Applications Appear on the Site?

We are not responsible for your interaction with third party applications.

7. How Do I Change My Information and Communications Preferences?

You may change certain account information and preferences.

8. What About Transfer of Information to the United States?

Data may be transferred to the United States.

9. What Should Parents Know About Children?

We do not intend to collect Personal Information from children. If you think we have, let us know.

10. What About Security?

No data security is absolute, but we take reasonable technical, physical and administrative steps to secure data appropriately.

11. What About Changes to the Privacy Policy?

We may change this Privacy Policy, as explained here.

12. Who Can I Contact?

You can contact us for more information about the manner in which we collect, use, disclose and otherwise manage your Personal Information. More

The Full Detailed Privacy Policy

1.         What Information Does the Site Collect?

Information You Provide To Us

Personal Information and Demographic Information.  On the Site, we may ask you to provide us with certain categories of information such as: (1) personally identifiable information, which is information that identifies you personally, such as your first and last name, home address, e-mail address, and credit card number (“Personal Information”); and (2) demographic information, such as information about your gender, occupation, and education level (“Demographic Information”).  We may collect this information through various forms and in various places on the Site, including account registration forms, contact us forms, or when you otherwise interact with the Site.  If we combine Demographic Information with the Personal Information we collect directly from you on the Site, we will treat the combined data as Personal Information under this Privacy Policy.
(b)        Information We Collect and Store As You Access And Use The Site In addition to any Personal Information or other information that you choose to submit to us via our Site, we and our third-party service providers may use a variety of technologies that automatically (or passively) store or collect certain information whenever you visit or interact with the Site (“Usage Information”).  This Usage Information may be stored or accessed using a variety of technologies that may be downloaded to your personal computer, laptop, tablet or mobile phone (a “Device”) whenever you visit or interact with our Site.  Usage Information may be non‑identifying or may be associated with you.  Whenever we associate Usage Information with your Personal Information, we will treat it as Personal Information.
This Usage Information may include:

  • your IP address or other unique identifier (“Device Identifier”).  A Device Identifier is a number that is automatically assigned to your Device used to access the Site, and our computers identify your Device by its Device Identifier;
  • your Device functionality (including browser, operating system, hardware, mobile network information);
  • the URL that referred you to our Site;
  • the areas within our Site that you visit and your activities there, including remembering you and your preferences;
  • your Device location;
  • your Device characteristics; and
  • certain other Device data, including the time of day, among other information.

We may use various developed methods and technologies to store or collect Usage Information (“Tracking Technologies”).  Tracking Technologies may set, change, alter or modify settings or configurations on your Device.  A few of the Tracking Technologies include, without limitation, the following (and subsequent technology and methods later developed):
Cookies.  A cookie is a data file placed on a Device when it is used to visit the Site.  A Flash cookie (or locally shared object) is a data file placed on a Device via the Adobe Flash plug-in that may be built-in to or downloaded by you to your Device. HTML5 cookies can be programmed through HTML5 local storage.  Unlike Flash cookies, HTML5 cookies do not require a plug-in.  Regular cookies may generally be disabled or removed by tools that are available as part of most commercial browsers, and in some but not all instances can be blocked in the future by selecting certain settings.  Each browser you use will need to be set separately and different browsers offer different functionality and options in this regard.  Also, these tools may not be effective with regard to Flash cookies or HTML5 cookies.  For information on disabling Flash cookies go to Adobe’s website www.adobe.com.  Please be aware that if you disable or remove cookies, Flash cookies, or HTML5 cookies on your Device, some parts of our Site may not function properly, and that when you revisit our Site your ability to limit cookies is subject to your browser settings and limitations.
Web Beacons.  Small graphic images or other web programming code called web beacons (also known as “1x1 GIFs” or “clear GIFs”) may be included in our Site’s pages and messages.  Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a page or e-mail can act as a web beacon.  Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to the Site, to monitor how users navigate the Site, to count how many e-mails that were sent were actually opened or to count how many particular articles or links were actually viewed.
Embedded Scripts.  An embedded script is programming code that is designed to collect information about your interactions with the Site, such as the links you click on.  The code is temporarily downloaded onto your Device from our web server or a third party service provider, is active only while you are connected to the Site, and is deactivated or deleted thereafter.
ETag, or entity tag.  A feature of the cache in browsers.  It is an opaque identifier assigned by a web server to a specific version of a resource found at a URL.  If the resource content at that URL ever changes, a new and different ETag is assigned.  Used in this manner ETags are a form of Device Identifier.  ETag tracking may generate unique tracking values even where the consumer blocks HTTP, Flash, and/or HTML5 cookies.
We may use Tracking Technologies for a variety of purposes, including:
Strictly Necessary.  We may use cookies or other Tracking Technologies that we consider are strictly necessary to allow you to use and access our Site, including cookies required to prevent fraudulent activity, improve security or allow you to make use of shopping‑cart functionality.
Performance‑Related.  We may use cookies or other Tracking Technologies that are useful in order to assess the performance of the Site, including as part of our analytic practices or otherwise to improve the content, products or services offered through the Site.
Functionality‑Related.  We may use cookies or other Tracking Technologies that are required to offer you enhanced functionality when accessing the Site, including identifying you when you sign‑in to our Site or keeping track of our specified preferences, including in terms of the presentation of content on our Site.
Content‑Related.  We may use Tracking Technologies to deliver content relevant to your interests on our Site based on how you interact with our content.  This includes using Tracking Technologies to understand the usefulness to you of the content that has been delivered to you.
There may be other Tracking Technologies now and later devised and used by us in connection with the Site.  Further, third parties may use Tracking Technologies with our Site.  We may not control those Tracking Technologies and we are not responsible for them.  However, you consent to potentially encountering third party Tracking Technologies in connection with use of our Site and accept that our statements under this Privacy Policy do not apply to the Tracking Technologies or practices of such third parties.
(c)        Information Third Parties Provide About You
We may receive information about you from your friends, colleagues and others that use the Site, such as when they submit content to us or post on the Site.  Additionally, we may, from time to time, supplement the information we collect directly from you on our Site with outside records from third parties for various purposes, including to enhance our ability to serve you, to tailor our content to you and to offer you opportunities that may be of interest to you.  To the extent we combine information we receive from those sources with Personal Information we collect on the Site, it will be treated as Personal Information and we will apply this Privacy Policy to such combined information, unless we have disclosed otherwise.  In no other circumstances do our promises under this Privacy Policy apply to information we receive about you from third parties.
(d)        Information You Provide About a Third Party
You may send someone else a communication from the Site, such as sending an invitation to a friend.  If so, the information you provide (e.g., names, e-mail addresses, mobile number, etc.) is used to facilitate the communication and is not used by us for any other marketing purpose unless we obtain consent from that person or we explicitly say otherwise.  Please be aware that when you use any send-to-a-friend functionality on our Site, your e-mail address, mobile number, name or user name and message may be included in the communication sent to your addressee(s).  Some of these tools may be third party tools subject to third party privacy policies as further detailed in Section 5 and Section 6 .
2.         How Do We Use the Information Collected?
We may use your Personal Information, Demographic Information or Usage Information that is subject to this Privacy Policy: (1) to provide you with information or services or process transactions that you have requested or agreed to receive including to send you electronic newsletters, or to provide you with special offers or promotional materials on behalf of us or third parties; (2) to enable you to participate in a variety of the Site’s features such as online lectures, courses and or other educational opportunities; (3) to process your registration with the Site, including verifying your information is active and valid; (4) to improve the Site or our services, to customize your experience on the Site, or to serve you specific content that is relevant to you; (5) to contact you with regard to your use of the Site and, in our discretion, changes to the Site and/or Site’s policies; (6) for internal business purposes such as troubleshooting, data analysis, testing, research and service improvement; and (7) for purposes disclosed at the time you provide your information or as otherwise set forth in this Privacy Policy. 
Please note that information submitted to the Site via a “contact us” or other similar function may not receive a response; we will not use that information so provided to contact you for marketing purposes unrelated to your inquiry unless you agree otherwise.
3.         How and When Do We Disclose Information to Third Parties?
We may share non-Personal Information, such as aggregated user statistics, with third parties.  We may share your Device Identifiers with third parties along with data related to you and your activities.  We do not share your Personal Information with third parties for those third parties’ marketing purposes unless you consent to such sharing at the time you provide your Personal Information.  In addition, we may share the information we have collected about you, including Personal Information, as disclosed at the time you provide your information and as described below or otherwise in this Privacy Policy.
(a)        When You Request Information From or Provide Information to Third Parties.
You may be presented with an option on our Site to receive certain information and/or marketing offers directly from third parties or to have us send certain information to third parties or give them access to it.  If you choose to do so, your Personal Information and other information may be disclosed to such third parties and all information you disclose will be subject to the third party privacy policies and practices of such third parties.  As examples, we may offer you the opportunity to provide information on your completion of courses or activities to your employer, certification organizations and/or third party institutions that offer academic and/or continuing education credit.  If you exercise such an option you consent to our providing all information requested by them.  In addition, third parties may store, collect or otherwise have access to your information when you interact with their Tracking Technologies, tools, content or apps on our Site or link to them from our Site.  This may include using third party tools such as Facebook, Twitter, Pinterest or other third party posting or content sharing tools.  We are not responsible for the privacy policies and practices of such third parties and, therefore, you should review such third party privacy policies and practices of such third parties prior to requesting information from or otherwise interacting with them.
(b)        Third Parties Providing Services on Our Behalf.  We may use third party vendors to perform certain services on behalf of us or the Site, such as hosting the Site, designing and/or operating the Site’s features, tracking the Site’s activities and analytics, and enabling us to send you special offers or perform other administrative services.  This may include content or courses provided or operated by, in whole or in part, third parties, but we require them not to use your Personal Information for their own purposes without your express consent.  We may provide these vendors with access to user information, including Device Identifiers and Personal Information, to carry out the services they are performing for you or for us.  If you request that we share information with third parties (e.g., your employer or a certification organization), such authorization also applies to our third party content/course providers.  Third party analytics service providers may set and access their own Tracking Technologies on your Device and they may otherwise collect or have access to your Personal Information.  We are not responsible for those third party technologies or activities arising out of them.  However, some may offer you certain choices regarding their practices, and information we have been informed of regarding such choices is available here [LINK TO CHART AT END OF THE POLICY].
(c)        Administrative and Legal Reasons.  We may access, use, preserve, transfer and disclose your information (including Device Identifiers and Personal Information), including disclosure to third parties: (i) to satisfy any applicable law, regulation, subpoenas, governmental requests or legal process if in our good faith opinion such is required or permitted by law; (ii) to protect and/or defend the Site’s Terms of Use or other policies applicable to the Site, including investigation of potential violations thereof; (iii) to protect the safety, rights, property or security of the Site or any third party; and/or (iv) to detect, prevent or otherwise address fraud, security or technical issues.  Further, we may use IP address or other Device Identifiers, to identify users, and may do so in cooperation with third parties such as copyright owners, internet service providers, wireless service providers and/or law enforcement agencies, including disclosing such information to third parties, all in our discretion, subject to applicable law.  Such disclosures may be carried out without notice to you.
(d)        Affiliates and Business Transfer.  We may share your information, including your Device Identifiers and Personal Information, Demographic Information and Usage Information with our parent, subsidiaries and affiliates.  We also reserve the right to disclose and transfer all such information: (i) to a subsequent owner, co-owner or operator of the Site or applicable database; or (ii) in connection with a merger, consolidation, restructuring, the sale of substantially all of our interests and/or assets or other corporate change, including, during the course of any due diligence process.   
(e)        Co-branded Areas.  Certain areas of the Site may be provided to you in association with third parties (“Co-Branded Areas”) such as our sponsors, and may require you to disclose Personal Information to them.  Such Co-Branded Areas will identify the third party and indicate if they have a privacy policy that applies to their collection and use of you information.  If you elect to register for products and/or services, communicate with such third parties or download their content or applications, at Co-Branded Areas, you may be providing your information to both us and the third party.  Further, if you sign-in to a Co-Branded Area with a username and password obtained on the Site, your Personal Information may be disclosed to the identified third parties for that Co-Branded Area.  We are not responsible for such third party’s data collection or practices and you should look to such third party privacy policies for more information.
(f)        Sweepstakes, Contests and Promotions.  We may offer sweepstakes, contests, and other promotions (any, a “Promotion”) through the Site that may require registration.  By participating in a Promotion, you are agreeing to official rules that govern that Promotion, which may contain specific requirements of you, including, allowing the sponsor of the Promotion to use your name, voice and/or likeness in advertising or marketing associated with the Promotion.  If you choose to enter a Promotion, Personal Information may be disclosed to third parties or the public in connection with the administration of such Promotion, including, in connection with winner selection, prize fulfillment, and as required by law or permitted by the Promotion’s official rules, such as on a winners list.
4.         What About Information I Disclose Publicly?
(a)        User Generated Content and Public Information.  When you register with the Site, you may be required to create your own account.  As part of the interactive aspects of the Site, some Personal Information of registered users of the Site (“Members”) and postings may be automatically displayed to the public on the Site as part of a Member’s profile in connection with using our community forums.  Additionally, the Site permits you to submit and/or publicly post ideas, photographs, lessons, lectures, writings, music, video, audio recordings, computer graphics, pictures, data, questions, comments, suggestions or other content, including Personal Information (collectively, “User Content”), such as on your profile and community forums.  We or others may store, display, reproduce, publish, distribute or otherwise use User Content online or offline in any media or format (currently existing or hereafter developed) and may or may not attribute it to you.  Others may have access to this User Content and may have the ability to share it with third parties.  Postings to our community forums, bulletin boards, or similar public forums where you and other users of our Site can communicate are public or semi-public, and therefore may be reviewed by Members and non-Members, indexed by third-party search engines and appear in search results on third-party websites.  Accordingly, you should exercise discretion and good judgment regarding what you elect to include as User Content.  Please note that USM does not control who will have access to the information that you choose to make public, and cannot ensure that parties who have access to such publicly available information will respect your privacy or keep it secure.  Our promises under this Privacy Policy do not apply to any information that you disclose publicly, share with others or otherwise upload onto the publicly available positions of our Site.  We are not responsible for the accuracy, use or misuse of any User Content that you disclose or receive from third parties through the Site. 
(b)        Name and Likeness.  We may also publish your name, voice, likeness and other Personal Information that is part of your User Content, and we may use the content, or any portion of the content, for advertising, marketing, publicity and promotional activities.  For full terms and conditions regarding User Content you submit to the Site, please review our Terms of Use .
(c)        Profiles.  When you participate in a Site community forum, you will be required to maintain a profile on the Site.  A Member’s profile may be, by default, set up to display information such as the Member’s display name, images, location (city/state/country), and optional information added by the Member including, for example, the Member’s tagline, photographs and educational materials, etc.  Profile information is used by us primarily to be presented back to and edited by you when you access the Site and to be presented to others permitted to view that information on the Site.  In some cases (e.g., posting to your profile), other users of the Site may be able to supplement your profile.  We recommend that you do not post information or content as part of your profile that you are not prepared to make public.  Further, other users that have access may repost or otherwise make public your information or content.  Accordingly, discretion and good judgment should be exercised when posting information or content as part of your profile.
5.         Do Third Party Content and Links to Third Party Sites Appear on the Site?
The Site may contain content that is supplied by a third party, and those third parties may collect Usage Information and your Device Identifier when pages from the Site are served to you.  In addition, when you are on the Site you may be directed to other sites that are operated and controlled by third parties that we do not control.  We are not responsible for the data collection and privacy practices employed by any of these third parties or their sites.  For example, if you “click” on a link, the “click” may take you off the Site onto a different site.  These other sites may associate their Tracking Technologies with you, independently collect data about you, including Personal Information, and may or may not have their own published privacy policies.  We encourage you to note when you leave our Site and to review the third party privacy policies of all third party locations and exercise caution in connection with them.
6.         Do Third Party Applications Appear on the Site?
Third party applications may be available via the Site.  The owners of these applications (“Third Party Owners”) may collect Personal Information and other data from you and may have their own policies and practices.  We are not responsible for how Third Party Owners or their applications collect or use your information.  These Third Party Owners may have their own terms of service, privacy policies or other policies and ask you to agree to the same.  We are not responsible for these third party privacy policies or the practices of Third Party Owners.  Be sure to review any available policies before submitting any personally identifiable information to a third party application or otherwise interacting with it and exercise caution in connection with these applications.
7.         How Do I Change My Information and Communications Preferences?
You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information provided as part of registration.  The Site may allow you to review, correct or update Personal Information you have provided through the Site’s registration forms or otherwise, and you may provide registration updates and changes, and otherwise request access to your information, by contacting us at customersupport@usmonline.org.  If so, we will make good faith efforts to make requested changes in our then active databases as soon as reasonably practicable.  Please note that it is not always possible to completely remove or delete all of your information from our databases and that residual data may remain on backup media or for other reasons.  Also, if you have made any public postings on the Site such as in forums or blogs, these communications cannot generally be removed.  When you edit your Personal Information or change your preferences on the Site, information that you remove may persist internally for USM’s administrative purposes.  You may cancel or modify our e-mail marketing communications you receive from us by following the instructions contained within our promotional e-mails or in some cases by logging into your account and changing your communication preferences.  This will not affect subsequent subscriptions and if your opt-out is limited to certain types of e-mails the opt-out will be so limited.  Please note that we reserve the right to send you certain communications relating to your account or use of our Site, such as administrative and service announcements and these transactional account messages may be unaffected if you choose to opt-out from receiving our marketing communications.  If you have any questions about the Privacy Policy or practices described in it, you should contact us by e-mail at: webmaster@usmonline.org
8.         What About Transfer of Information to the United States?
Our Site is operated in the United States and intended for users located in the United States.  If you are located outside of the United States, please be aware that information we collect, including Personal Information, will be transferred to, and processed, stored and used in the United States.  The data protection laws in the United States may differ from those of the country in which you are located, and your Personal Information may be subject to access requests from governments, courts, or law enforcement in the United States according to laws of the United States.  By using the Site or providing us with any information, you consent to the transfer to, and processing, usage, sharing and storage of your information, including Personal Information, in the United States as set forth in this Privacy Policy.
9.         What Should Parents Know About Children?
The Site is a general audience web site and we do not knowingly collect any personal information from children younger than the age of thirteen (13) as required by U.S. law.  We will delete any personal information collected that we later determine to be from a user younger than the age of thirteen (13).  If you are a parent or guardian of a child under the age of thirteen (13) and believe he or she has disclosed personal information to us, please contact us at webmaster@usmonline.org.  
10.       What About Security?
We incorporate commercially reasonable safeguards to help protect and secure your Personal Information in our custody or control.  However, no data transmission over the Internet, mobile networks, wireless transmission or electronic storage of information can be guaranteed to be 100% secure.  Please note that we cannot ensure the security of any information you transmit to us, and you use our Site and provide us with your information at your own risk.
11.       What About Changes to the Privacy Policy?
We reserve the right to change this Privacy Policy at any time without notice to you.  Any changes will be effective immediately upon the posting of the revised Privacy Policy.  We will not use your Personal Information, however, in a manner materially different than promised at the time it was collected without your consent.  To the extent any provision of this Privacy Policy is found by a competent tribunal to be invalid or unenforceable, such provision shall be severed to the extent necessary for the remainder to be valid and enforceable.
12.       Who can I Contact?
If you have questions, comments or complaints regarding our Privacy Policy or the manner in which we or our service providers treat your Personal Information, contact our Webmaster at: webmaster@usmonline.org.
//End Privacy Policy//
The following third parties that collect information from you on our Site have given us notice that you may obtain information on their policies and practices, and in some instances opt-out of certain of their activities, as follows:


Party

Service

For More Information

Use of Tracking Technologies

Privacy Choices

Google

Google Analytics for Display Advertisers, Ads Preferences Manager, and Google Analytics Opt-out Browser Add-on

http://support.google.com/analytics/bin/answer.py?hl=en&topic=2611283&answer=2700409
http://www.google.com/settings/ads/onweb/?hl=en&sig=ACi0TCg8VN3Fad5_pDOsAS8a4...
https://tools.google.com/dlpage/gaoptout/

Yes

See information links in prior column

NOTE: We are not responsible for third party policies or practices.  We try to keep this information current, but it is provided as a courtesy and may not be current or accurate.  Please contact the applicable third parties regarding their privacy and data security policies and practices.