Humphreys University

1. Introduction

Agreement and Parties. Humphreys University (“Humphreys University,” “us,” or “we”) respects the privacy of the visitors to the Humphreys University website (“website” or “site”). This Privacy Policy (“Privacy Policy” or “Policy”) is an agreement between Humphreys University and you, as the user of the Humphreys University website (“you”). This agreement tells you when this Policy is effective, what information we collect from you, how we might use it, how you can review or change the personal information you provided to us, how we may change this Policy, and the steps we take to ensure that your personal information is protected.

 

2. Agreement to Terms of Privacy Policy and Terms of Use

Agreement to Terms. All activities in which you may engage on this website are voluntary. You are not required to provide any personal information to us unless you choose to access features on this site that require the information. If you do not agree with the terms of this Policy or other terms of use on this website, then you should immediately exit this website and discontinue using the site. If you do not agree with the terms of this Privacy Policy and our terms of use posted at https://www.humphreys.edu/privacy-policy/, please do not provide us with personal information, and leave this website. The terms of use of this site are expressly incorporated herein by reference and made a part of this Policy. By using the Humphreys University website, you signify that you agree to the terms of this Privacy Policy as well as to our terms of use.

 

3. Effective Date of and Changes to Privacy Policy

Effective Dates. This Privacy Policy is effective as of October 1, 2021, and will remain in effect except with respect to any of its provisions that are changed in the future, in which case the changes will become effective on the date they are posted on the website. We reserve the right to change, update, or modify this Privacy Policy at any time, without any notice to you. Changes, modifications, additions, or deletions will be effective immediately on their posting to this site. You should check this Policy periodically, as its terms may change from time to time. Your continued use of the site after we post any such modifications will constitute your acknowledgment of the modified Policy and your agreement to abide and be bound by the modified Policy. We will also revise the “last updated” date found at the beginning of this Privacy Policy when we post changes to it.

 

4. Policy Applicable to Online Activities Only

Disclaimers. This Privacy Policy does not extend to anything that is inherent in the operation of the Internet, and therefore beyond Humphreys University’s control, and is not to be applied in any manner contrary to applicable law or governmental regulation. This online Privacy Policy only applies to information collected through this site. This Privacy Policy does not apply to any information we may collect from you in any place other than this website.

 

5. Personal Information We May Collect

Types of Information Collected. We may ask you for certain information referred to on this site as “personal information,” which includes information that pertains to your identity. Such information may include, but is not limited to, items such as your name, address, date of birth, age, gender, e-mail address, telephone number, or credit card or debit card number. You may be required to provide personal information to access or use certain parts of our website or features of the site. If you do not provide the requested personal information, you may not be able to access or use the features of the site where such information is requested.

 

6. General Information We May Collect

Types of Information Collected. There may be other instances in which we collect information from you that is more general in nature (“general information”). Such information may include your Internet Protocol (IP) address, which enables us to identify your computer or device on a Transmission Control Protocol/Internet Protocol (TCP/IP) network, which includes the World Wide Web. Your computer has an IP address, which is required in order for you to communicate with others via the Internet. Such general information, including the click stream data and cookies, as mentioned below, may be collected from you whenever you access the site, whether or not you provide us with any other personal information.
A set of website features may be accessible from web-enabled mobile devices. The intent is to provide screens that are optimized for the size of the screen and operating systems. On some devices, functionality may be limited. If you access this website through a mobile device, then we may collect information about your mobile device whether or not you provide us with any other personal information.

6.1 Click Stream Data

When you visit our website, we may also collect “click stream data” (server address, domain name). This information can be combined with information you have provided to us by registering, for example, which will enable us to analyze and better customize your visits. We may use click stream data for traffic analysis or e-commerce analysis of our website, to determine which features of our site are most or least effective or useful to you.

6.2 Cookies

We may also use cookies to gather information about your visits to our website and enhance your experience. More information on how we use cookies is available in Section 11.

6.3 How We Respond to “Do Not Track” Disclosures

We are strongly committed to not sharing personal information with third parties. Under this Privacy Policy, we may share your information only under particular situations, as described in this Policy. Because we protect all users in this manner, we do not change our behavior in response to a web browser’s “do not track” signal.

6.4 Use of Social Media Tools

This website allows you to use your social media accounts to pre-populate certain fields. If you choose to use this feature, you are allowing us to access your personal information. We encourage you to review the privacy policy and any terms and conditions for the social media platform you select.

 

7. General Information About You

Use of General Information. We will primarily use the personal information you provide and any general information we receive from you to provide products and services to you, including, but not limited to, the following:

A. To administer a content promotion survey or other site and to provide you with the relevant products or services (for example, to deliver a prize you may have won in a contest).

B. To send you information or materials via e-mail about products, offers, and news we think might interest you. This information may relate to products, offers, and news of Humphreys University or its licensees or selected commercial partners. We send you this only if you have double-opted-in to receive e-mails from Humphreys University. If you no longer wish to receive any e-mails from us, or if you want to modify your personal data or want your personal data to be deleted from our database, see Sections 12 and 13.

C. To analyze visits to the website and learn about the interests of our visitors in aggregate and also on a personal level to better understand your interests and needs, so we can improve our products and services and deliver to you the type of content, features, and promotions that you are most interested in.

 

8. Protection of Your Personal Information and General Information

8.1 Security Measures
In order to protect both the personal information and the general information that we receive from you through our website, we have implemented various security measures. Whenever we collect personal information, that information is encrypted and transmitted to us in a secure manner. You can verify this by looking for a closed lock icon at the bottom of your web browser, or by looking for “https” at the beginning of the webpage address.
We have also implemented security measures to protect personal information and general information transmitted offline. Only employees who require your personal information or general information to perform a specific task (i.e., billing or customer service) are granted access to the information. In addition, the computers and servers on which we store personal information and general information are kept in a secure environment.

8.2 Risk of Interception
Please keep in mind, however, that whenever you give out personal information online, there is a risk that third parties may intercept and use that information. While Humphreys University strives to protect your personal information and privacy, we cannot guarantee the security of any information you disclose online. By using this site, you expressly acknowledge and agree that we do not guarantee the security of any data provided to or received by us through this site and that any personal information, general information, or other data or information received from you through the site is provided to us at your own risk, which you expressly assume.

 

9. No Use of this Site by Persons Under Age 18 Permitted

9.1 Registration Declined
Humphreys University intends only persons who are 18 years or older to use this website. Personal registration information submitted by a person under the age of 18 will not be accepted. Any general information provided by a person under the age of 18 and gathered (for example, through the use of cookies) during his or her visit may be used as indicated in this policy (see Section 6). Humphreys University is committed to protecting the privacy of children and has no intention of collecting personal data from children under the age of 18. We encourage parents and guardians of children under 18 to regularly check and monitor their children’s use of e-mail and other activities online.

9.2 Notice Concerning Children
Please Note: We are a general audience site, and do not direct any of our content specifically at children under 13 years of age. We understand and are committed to respecting the sensitive nature of children’s privacy online. If we learn or have reason to suspect that a site user is under age 13, we will promptly delete any personal information in that user’s account.

 

10. Third Parties

10.1 Disclosing Information to Third Parties
Who May Have Access to Your Information. Other than to the companies belonging to Humphreys University for the purposes set out above, and except as described in this Policy, we do not sell, trade, or otherwise transfer your personal information or general information to third parties without informing you in advance. We provide some of our services through contractual arrangements with affiliates, services providers, partners and other third parties (collectively, “service partners”). Our service partners may use your personal information to operate our sites and to deliver their services. For example, your data may be transferred to website hosting partners and other parties who assist us in designing and operating the website, executing services (such as for prize fulfillment), or helping us analyze collected data. These parties will only use your data for the purpose of carrying out the work as agreed with us and will be required to keep the information confidential. We will encourage our service partners to adopt and post privacy policies. However, the use of your personal information by our service partners is governed by the privacy policies of those service partners and is not subject to our control. Please also see Paragraph 6.3 on how we will respond to “do not track” signals.

Information We Disclose to Third Parties. We may disclose personal information that you provide via Humphreys University’s website to the following third parties:

• Our subsidiaries, affiliates, and joint venture partners; and
• Contractors, vendors, and service providers we use to support our business and website.
  We may also disclose personal information that you provide via this Website in the event of a merger, acquisition, or any form of sale of some or all of our assets, in which case personal information we collect via our website will be among the assets transferred to the buyer. Further, we may disclose your personal information to third parties to:
• Comply with any court order or other legal obligation;
• Enforce or apply our terms of use and other agreements; and
• Protect the rights, property, or safety of our business, our clients, customers, employees, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection, information security, and other related matters.

10.2 Sharing Information With Persons or Entities Who Manage This Website
Humphreys University’s website and the personal information and general information it collects are managed and controlled by Sandra Curiel, Humphreys University’s webmaster, who can be reached at webmaster@humphreys.edu, and Amit Kumar, Humphreys’ University’s backend and technical support manager, who can be reached at techsupport@humphreys.edu. The servers that make Humphreys University’s website available are located in Iowa, South Carolina, Oregon, and Montreal. Please note that the information you provide over Humphreys University’s website will be transferred to Sandra Curiel and Amit Kumar, and by submitting the information, you authorize this transfer. Sandra Curiel and Amit Kumar have entered into an agreement with the hosting company, WP Engine, located at 504 Lavaca Street, Suite 1000, Austin, TX 78701 to provide safeguards for the protection of your data that are consistent with this policy.

10.2.1 Categories of Personal Information Collected
We identify below the categories of personal information that we have collected about our users in the last 12 months, using the categories provided in the CCPA.

• Identifiers
• Customer Records Information
• Characteristics of protected classifications under California or federal law
• Commercial Information
• Internet or Other Electronic Network Activity Information
• Professional or Employment-related Information
• Educational Information
• Inferences

10.2.2 Categories of Personal Information Shared for a Business or Commercial Purpose
We identify below the categories of personal information that we have shared for a business or commercial purpose in the last 12 months, using the categories provided in the CCPA.

• Identifiers
• Customer Records Information
• Characteristics of protected classifications under California or federal law
• Commercial Information
• Internet or Other Electronic Network Activity Information
• Professional or Employment-related Information
• Educational Information
• Inferences

10.3 Security
Release of Information. Humphreys University will release personal or general information without your consent for security purposes, when required by law, or to prevent imminent harm to any person or entity. We will disclose personal or general information on receipt of a court order or subpoena, or to cooperate with a law enforcement investigation, which may include responding to requests and court orders from jurisdictions outside the United States. We fully cooperate with law enforcement agencies in identifying those who use our services for illegal activities. We reserve the right to report to law enforcement agencies any activities that we in good faith believe to be unlawful, as determined in our sole discretion. Release of your personal data for security purposes, as described in this agreement, to any person or entity under any circumstances shall be based on a determination made solely by us, exercising our own discretion, permission for which is expressly granted by you to us in accordance with this Policy.

10.4 Links to Third Parties
Purpose of Links. For your convenience and to improve usage of the website, we may insert links to third parties on this site. This Privacy Policy does not apply to such third party websites. These links take you outside our service and off Humphreys University’s site and are beyond our control. This includes links from partners that may use Humphreys University’s logos as part of a co-branding agreement. The sites those links can take you to have their own separate privacy policies and, although we seek to protect the integrity of our site, Humphreys University is not liable for the content and activities of those sites. Your visits and access to such websites is at your own risk. Please note that those other sites may send their own cookies to users, collect data, or solicit personal information.

 

11. Automatic Collection

Cookies. A cookie is a small string of information that the website you visit transfers to your computer for identification purposes. Cookies can be used to follow your activity on the website and that information helps us to understand your preferences and improve your website experience. Cookies are also used for such activities as remembering your user name and password, if you use such a feature on this site. You can turn off all cookies, in case you prefer not to receive them. You can also have your computer warn you whenever cookies are being used. For both options, you have to adjust your browser settings (such as Chrome, Safari, Firefox, Internet Explorer, or other browser). There are also software products available that can manage cookies for you. Please be aware, however, that when you choose to reject cookies, this choice may limit the functionality of the website you visit and you may lose access to some of its features.

 

12. Rights of California Residents Under The California Consumer Privacy Act of 2018

The California Consumer Privacy Act of 2018 (“CCPA”) provides additional rights to California residents regarding Humphreys University’s information collection and use practices.

12.1 Right to Know
You have the right to know certain details about our data practices in the past 12 months. In particular, you may request the following from us:

• The categories of personal information we have collected about you;
• The categories of sources from which the personal information was collected;
• The categories of personal information about you we disclosed for a business purpose or sold;
• The categories of third parties to whom the personal information was disclosed for a business purpose or sold;
• The business or commercial purpose for collecting or selling the personal information; and
• The specific pieces of personal information we have collected about you.

To exercise the Right to Know, please submit a request by calling our phone number at 209-478-0800, or by emailing us at communications@humphreys.edu. In the request, please specify which right you are seeking to exercise and the scope of the request. We will confirm receipt of your request within 10 days. We may require specific information from you to help us verify your identity and process your request. If we are unable to verify your identity, we may deny your requests to know.

12.2 Right to Delete
Subject to statutory exclusions, you have the right to request that we delete the personal information we have collected from you in the last 12 months. To exercise the Right to Delete, please submit a request by calling our phone number at 209-478-0800, or by emailing us at communications@humphreys.edu. We will confirm receipt of your request within 10 days. We may require specific information from you to help us verify your identity and process your request. If we are unable to verify your identity, we may deny your request to delete. If we deny your request, we will explain the reason why in our response.

12.3 Right to Opt Out
You have the right to opt out of the sale of your personal information. Humphreys University does not sell your personal information.

12.4 Right to Non-Discrimination
If you exercise your rights under the CCPA, you have the right to not be discriminated against.

12.5 Authorized Agent
You can designate an authorized agent to submit requests on your behalf. However, we will require written proof of the agent’s permission to do so and verify your identity directly.

12.6 Notice of Financial Incentives
Financial incentives are programs, benefits, or other offerings, including payments to consumers as compensation, for the disclosure, deletion, or sale of personal information about them. Humphreys University does not offer any financial incentives or price or service differences for the disclosure, deletion, or sale of personal information about you.

 

13. Changing Your Information or Preferences

13.1 Update Your Contact Information
We encourage you to promptly update your contact and personal information when it changes.

13.2 Update Your Preferences
You may cancel your registration at any time, and you may opt out of receiving any e-mails from Humphreys University.

 

14. Questions or Comments

Contact Information. If you have any questions or comments relating to our website or this Privacy Policy, please send an e-mail to communications@humphreys.edu, call our phone number at 209-478-0800, or write us at:
Attn: Privacy Compliance Officer
6650 Inglewood Avenue
Stockton, CA 95207