PRIVACY POLICY

California Institute of Advanced Management (“CiAM”) respects your privacy rights and has adopted clear guidelines for all of its departments and offices requiring that information you submit will only be used for the purposes for which you have consented. CiAM will never sell, rent, loan, trade or lease your personal information to any third party. We are committed to protecting the privacy and security of your information.

This policy explains our website information practices and the choices you can make about the way CiAM collects and uses your information. This Privacy Policy covers the information you provide to us online at public CiAM websites (ciam.edu and www.ciam.edu/apply-now).

With the exception of those listed above, our Privacy Policy does not apply to third-party websites that may be accessible through CiAM websites or internal university websites. We encourage you to read the privacy policies of those third parties to learn how they collect and use information about you. Additionally, this Privacy Policy does not apply to information you submit to the university through other means (such as in person at our various offices, or through paper applications). Through these types of offline processes, those interested in or associated with the university may be added to mailing lists or databases that are not centrally managed by the university, but are instead managed by departments or offices on campus. While we will make every reasonable attempt to assist you in removing yourself from these databases, this privacy policy does not apply to them or to any other information that is not submitted online.

To assist you with reading through our Privacy Policy, we have provided answers to questions that you may find most important:

HOW DOES CIAM COLLECT AND USE MY PERSONAL INFORMATION?

CiAM collects and uses your personal information to respond to your requests for information, products and services. Unless we have your consent, your personal information submitted online will only be used or shared for purposes related to your request.

Information You Provide

CiAM collects personal information when you:

• Request information about degree programs on our Information Request Forms. We use this information to provide you with program information via mail, phone, and email. Your personal information is used to answer your questions and to contact you regarding your interest in our programs. It is not shared with outside parties.
• Apply to become a student using our online applications. This personal information is collected and provided securely to our Admissions offices. CiAM keeps the information you provide confidential and uses it only for purposes related to your request. Upon your acceptance as a student at CiAM, the official Student Records Policy governs the use and release of student information.
• Register for events using online registration. Information such as name, email address, phone number, and physical address may be requested. If you pay for event registration online, we may also collect a valid credit card number, expiration date and billing address, which we will use for the purpose of the single transaction only. We may share this information with banks and other entities in the financial system that process credit card transactions, however, it will only be used to fulfill your request.
• Contact CiAM using online forms with a question or suggestion in which we collect your name, email address and any comments you have. If your question identifies you as a potential student, we may use your contact information to inquire about your continued interest in our programs. For all other inquiries, we only use your information to respond to and/or resolve your question or concern.

Optional Information

When accessing CiAM websites, we may give you the ability to submit optional information, such as gender, when you plan to attend, and how you heard about CiAM. Optional fields are NOT marked with a red asterisk (*), as is the case with required fields. Optional information is requested to help us better understand our clients, customers, and Web visitors. If you have requested that we send you additional information regarding CiAM products, services, and events, we may also use the optional information to fulfill this request.

Technical Information

When visitors use our website, CiAM may collect technical information that does not by itself identify a specific individual. This information (sometimes referred to as "non-personally identifiable information") may include which pages visitors view on our website, which browser they use to view our website and terms they use to search our website. This technical data is aggregated to provide an overview of the browsing patterns of large groups of unidentified visitors and is used to measure and improve the effectiveness of the Azusa Pacific University website. We do not combine this technical data with the personal information we collect on our website.

DOES CIAM USE COOKIES, WEB BEACONS, OR THIRD PARTY ADVERTISERS?

Cookies

A “cookie” is a small amount of data that a website may send to your browser and that your browser may then store on your computer and send back to the website on subsequent visits. We sometimes use cookies to simulate a continuous connection; cookies let us “remember” information about your preferences to allow you to move within our website without reintroducing yourself. For example, on our bookstore website, cookies are used to keep track of what you have selected to purchase as you click through the website. We also use cookies to gather information about how certain types of users navigate our website. For example, we track which pages visitors typically use to enter the website, and where they go from those entry pages. This helps us improve our content by tracking which pages of our website are most useful to our visitors. We do NOT, however, use cookies to track the navigational habits of identified visitors. We never tie any personal information you provide to us with the navigational information gathered using cookies. Furthermore, we do NOT allow advertisers to set cookies via CiAM websites.

Most browsers automatically accept cookies, but you can usually refuse cookies, or selectively accept cookies, by adjusting the preferences in your browser. If you turn cookies off, there may be some features of our website that will not be available to you and some pages may not display properly. You can find information about how you can adjust your cookie settings at the following websites:

• Microsoft Internet Explorer
• Safari
• Firefox
• Chrome

Web Beacons

Yes: The CiAM website uses electronic images known as Web beacons, or clear GIFs to monitor the activity on our website.

Spyware

The CiAM website does NOT use spyware in any form.

Third-Party Advertisers

Yes: We use third-party advertising companies to serve ads when you visit our website. These companies may use information (not including your name, address, email address, or telephone number) about your visits to this and other websites in order to provide advertisements about goods and services of interest to you.

Does CiAM Track Online Activity?

Yes: When you visit and view a page at CiAM website, that request is logged on our servers with information including the IP Address of the computer that requested the page. CiAM uses this data in an effort to constantly improve the value of materials on the website. From time to time, CiAM may break down overall usage statistics according to multiple users' domain names, browser types, or IP Addresses by reading information from the “user agent” string (information sent to websites by every user’s browser). We do NOT, however, track the navigational habits of identified visitors. We never tie any personal information you provide to us with navigational information.

Does CiAM Allow Third-Party Banners?

No: CiAM does not allow third-party advertisers or ad servers to post banners on our website.

Does CiAM Use Personal Information?

Yes: We use your personal information to fulfill your requests. For example, to respond to your questions, to provide you with information about our programs, to process your registration for events, or to allow you to make purchases through this website. We will not use your information for purposes unrelated to your request.

Does CiAM Share My Personal Information?

CiAM does NOT sell, rent, loan, trade or lease personal information such as membership data, application information, or email lists to any third party. We treat all information you provide as confidential. Occasionally, we may contract with other companies to provide services on our behalf such as processing event registration, but these companies are required to keep your information confidential and to use it only to fulfill your request.

From time to time, we may be required to provide personal information in response to a valid court order, subpoena, government investigation, or as otherwise required by law. We reserve the right to report to law enforcement agencies any activities that we, in good faith, believe to be unlawful. We may release certain personal information when we believe that such release is reasonably necessary to protect the rights, property, and safety of others and ourselves

FAMILY EDUCATIONAL RIGHTS AND PRIVACY ACT (FERPA)

CiAM is bound by the Family Educational Rights and Privacy Act of 1974, better known as the Buckley Amendment or FERPA. This act generally provides that students have the right to access their educational records, and with limited exceptions, educational institutions cannot release educational records to non-school employees without consent of the student. In the event of conflict with CiAM’s online privacy policy, FERPA will govern.

The university’s registrar maintains copies of the official CiAM Student Records Policy, which contains detailed information and procedures with regard to a student’s rights under FERPA. Students may obtain a copy of that written policy upon request to the Registrar, CiAM, 1000 S. Fremont Ave., Mailbox 45, Building A10, 4th Floor, Suite 10402, Alhambra, CA 91803.

Any student alleging failure of the university to comply with FERPA may file a complaint with the Family Education Rights and Privacy Act Office (FERPA), United States Department of Education, 4511 Switzer Building, 330 C Street SW, Washington, DC 20201.

How Does CiAM Secure My Personal Information?

CiAM uses a variety of safeguards to protect your sensitive information from loss, misuse, alteration, or destruction. For example, whenever you send us sensitive information, we redirect you to a secured server to prevent unauthorized parties from viewing any information transmitted to or from CiAM during your session at our website. We also only provide access to your personal information to CiAM employees and other authorized parties on a “need to know” basis.

For the purposes of this policy, sensitive information is defined to be the combination of name, home address, birth date, and any additional information. Social security number, credit card number, and driver’s license number are always considered to be sensitive information, regardless of the other information submitted. For the purposes of this policy, name and email address in combination are not considered to be sensitive.

Please be careful whenever sending sensitive information to CiAM via email. Email is not necessarily a secure means of transferring information.

Do I Have Choices Regarding How My Information Is Used?

Yes: CiAM will not use or share the personal information we collect on the website in ways unrelated to the purpose for which you provided the information without first obtaining your consent (opt-in).

If we collect your information and you are not presented with a choice, it indicates that the information you submit will only be used for purposes related to your request. If you do opt in online to marketing or recruitment communications from CiAM, you can opt out at any time. If you wish to opt out of receiving communications from us, contact Paul-Long Lee at [email protected] and provide your full name, phone number, and a description of the communications you wish to opt out from. We may need to contact you for further information to process your request. Once your request has been received, we will use every reasonable means to ensure that you do not receive the communications you have asked to opt out from in the future (excluding any mailings in process before your request was received).

Some individuals may have placed themselves on mailing lists maintained by specific departments or offices of the university. The opt-out process outlined here does not automatically remove your name from these decentralized mailing lists. You may need to contact specific departments or offices on campus to remove yourself from their independently maintained lists.

Can I Alter/Update My Information?

CiAM maintains and updates personal information about current students, alumni, faculty, staff, and prospective students who inquire about our programs. Information that you supply for other purposes (such as event registrations, bookstore purchases, and through email forms) is not maintained after it is used to fulfill your request.

Various departments and offices on campus maintain records of information on the people they serve. If you wish to alter information that is being maintained about you, the following contact information should help you do so:

• For prospective and current students:
• For alumni, donors, parents, and friends:
• For faculty and staff:
• Human Resources – (626) 350-1500

GENERAL DATA PROTECTION REGULATION

If you are a current student, student applicant, employee, potential employee, or other individual located in a European Union country, Iceland, Liechtenstein, Norway, or Switzerland and you provide us with your personal data, you are now afforded new widespread privacy rights under the General Data Protection Regulation (GDPR) effective May 25, 2018. Under the GDPR, new higher standards on what is considered the lawful processing of EU data are imposed; there are now more explicit privacy rights afforded to you; and there are now new accountability standards imposed on organizations that collect, handle, store and/or process your data.

Under the GDPR, the moment that we first collect your data, you are now afforded various new privacy rights, including but not necessarily limited to:

• The right to know who decided what personal data is being collected from you and the purpose behind doing so
• The right to know each purpose and legal justification why your personal data is being collected and processed and why collecting and processing it is needed to accomplish the disclosed purpose(s)
• The identity of all third party recipients who are to receive your personal data
• The right to know if your personal data is to be transferred out of the EU
• The right to know how long your personal data will be stored and not to have it stored longer than needed to accomplish the stated purpose
• The right to access, receive or correct your personal data at any time
• The right to have your personal data erased (where there is no longer legal or necessary grounds to process or store your personal data)
• The right to have your personal data transferred to another at any time
• The right to restrict or otherwise object to, the processing of your personal data at any time where your personal data is not accurate, where the processing is unlawful, where your personal data is no longer needed or where there is no longer good legitimate grounds to process your personal data
• The right to easily and conveniently withdraw your consent to the collection, handling, storage and/or processing of your personal data at any time and to complain to us and/or the appropriate EU “supervisory authorities” if you believe any of your rights are being violated
• The right to know if you are being “profiled” or “monitored” or if certain decisions are being made automatically based on your personal data
• The right to know and to have your personal data processed only for the purpose that you had provided explicit affirmative informed consent and not for any other purpose from which was either never disclosed to you or for a purpose which you never provided explicit affirmative informed consent
• The right to know that all of the personal data that was collected, handled, stored and processed was needed in order to accomplish the purpose that you have affirmatively and explicitly consented

The lawful collection and processing of your personal data is necessary for us to perform the service of providing you with further information pertaining to the purpose for which you are voluntarily providing your personal data to CiAM, and we always seek to provide you with affirmative options so that you may decide if you want us to process your data for a particular purpose. We strive to make certain that all of the data that we request is necessary in order to provide you with our service or to otherwise accomplish the stated purpose. CiAM may share your data with a third party in order to accomplish the task for which the data was provided. Our third party vendors, like CiAM itself, are required to comply with GDPR. Further, all of the opt-in consents that are presented to you are intended to fully inform you whether you want us to process your data, the purpose behind processing your data and who, if anyone, we will be sharing your data with in order to accomplish that purpose. If you wish to know the identity of any third parties to which we share data, please contact the Marketing Director and we will provide you with the requested information.

Please note that if you are an individual located in a European Union country, Iceland, Liechtenstein, Norway, or Switzerland who is under the age of 13, you will not be permitted to submit data, and we will neither accept nor process your personal data. If you are under the age of 18 but age 13 or over, we will not process any of the personal data that you may have submitted to us until we have promptly received the express consent from your parent or legal guardian. If this consent is not promptly provided to us, any data that you may have submitted during the account creation process will be immediately purged from our system in order to make certain that we are not retaining any of your data. Note also that no data about you will be retained by us if you are unable to complete the account creation process or if you decide at anytime that you are withdrawing your consent. If you withdraw a previously submitted consent, we shall also inform all of our relevant partners that your consent has been withdrawn.

Note also that we have put into place with our trustworthy partners and members certain mechanisms of cooperation, communication and agreements so that your EU privacy rights are also honored by our partners and members. Should you decide to lawfully access, rectify, erase, object to or otherwise transfer any of your data that you submitted to us or if you wish to withdraw any one or all of your consents, please send your instruction to [email protected] and we will review and proceed accordingly.

Please note that if you are an individual located in a European Union country, Iceland, Liechtenstein, Norway, or Switzerland and you have sent to us your personal data unsolicited, after we have completed our review of your communication, we will appropriately delete your communication, including any personal data that may be contained therein, upon your lawful request.

If you have any questions or concerns about your rights under the GDPR or the steps that we have taken to comply with the GDPR, please contact us at (626) 350-1500.

Does CiAM Have A Dispute Resolution Process?

Yes: CiAM provides a mechanism by which you may send us any concerns or complaints regarding our information practices or policies.

Those who wish to be removed from mailing lists should first go through the opt-out process by contacting [email protected]. For more information about this process, see the opt-out section of this policy. If this process does not adequately remove the name, please contact the specific departments or offices on campus that would reasonably be expected to maintain your name in their databases. For more information about this process, see the alter/update section of this policy. If you have any additional questions or concerns about this privacy policy or the practices of our websites, please contact [email protected] in the Office of the General Counsel.

Will This Privacy Policy Change?

If there are changes or additions to this Privacy Policy, we will post those changes here so that you will always know what information we collect online, how we use it, and what choices you have.

SMS Messaging

By providing CiAM with your mobile number, you are agreed to receive text messages (SMS) from CiAM. Standard text messaging and data rates from your wireless carrier may apply and please check with your cellphone provider for details on receiving text messages (SMS).



Original Effective Date: January 1, 2021