Effective Date: February 2015
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.
Table of Contents
- What Information Does the Site Collect?
We collect and receive certain information about you as you interact with our Site, explained further in this section.
- Information You Provide to Us
We may collect certain Personal Information and Demographic Information that you provide to us when you interact with the Site. For example, we may collect this information through various forms and in various places on the Site, including when you submit your application to attend SABA, when you sign up to receive more information about SABA, or when you otherwise interact with the Site. More
- Information Collected and Stored As You Access and Use the Site
Certain information may be collected from you automatically when you access and use the Site. For example, we and third parties may use Tracking Technologies to collect Usage Information based on your Device Identifier for a variety of purposes, including tracking, targeting, and advertising, which may include activities across time and third party locations. We do not look for or respond to do not track signals, but you may have certain other options regarding tracking and/or targeting. More
- Information Third Parties Provide About You
We may obtain information about you from third parties. More
- Interactions with Third-Party Services
If you interact with third-party services, those services may send us information about you and you or we may send them information about you. More
- Information You Provide About a Third Party
You may provide us information about others, such as when you send a friend a message. If so, the information you provide (names, email addresses, etc.) may be used to facilitate the communication, but will not be used for other marketing purposes unless your friend consents. You may be identified to the friend in connection with such a message. More
- Information You Provide to Us
- How Do We Use the Information Collected?
- Use of Information By Us
We use your Personal Information, Demographic Information and Usage Information for a variety of purposes detailed in this section. More
- Use of Information For Recruitment Purposes
If you apply for a job with us, we use the application information for considering you for a position.More
- Interest-Based Advertising and Location-Based Services.
We may use your Personal Information, Demographic Information and Usage Information to target and understand advertisements as detailed in this section. More
- Contact Us
If you contact us, we may use the information you provide to contact you for marketing purposes, but you may opt-out of such communications at any time. More
- Use of Information By Us
- How and When Do We Share Information With Third Parties?
We may provide your information to third parties under various circumstances detailed in this section.These may include:
- 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 services, 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. This may also include ordering or purchasing products from third parties through us where we indicate that the third party rather than Saba is the seller. More
- Third Parties Providing Services on Our Behalf
Our vendors may collect your information on our behalf or we may share it with them so that they may provide services to us and you. Some may offer you choices regarding the collection and use of your information. More
- To Protect the Rights of Saba and Others
There are a variety of administrative and legal reasons for which we may share some or all of your information. More
- Affiliates and Business Transfer
We may share your information with our affiliates or in the event of a sale, merger or similar transaction. More
- EEOC/Affirmative Action Reporting
Certain employment application, self-identifying information (e.g., race and gender) may be shared with the government and other third parties. More
- Your California Privacy Rights
California Civil Code Section 1798 allows California residents to ask companies with whom they have an established business relationship to provide certain information about the companies’ sharing of personal information with third parties for direct marketing purposes. More
- Your Connecticut Privacy Rights
We make good faith efforts to protect the security of Social Security numbers.More
- Your European Privacy Rights
Certain European residents have certain data protection rights.More
- When You Request Information From or Provide Information to Third Parties
- What About Information I Disclose Publicly or to Others?
- User-Generated Content and Public Information
- Name and Likeness
You grant us the right to use your name and likeness in connection with your posting and activities. More
- User-Generated Content and Public Information
- Do Third-Party Content, Links to Third-Party Sites and/or Third-Party Apps Appear on the Site?
We may allow you to access third-party content on the Site, or to link to third-party applications and locations from the Site, but we are not responsible for your interaction with third-party content, apps, and locations. More
- What About Ads?
We and third parties may send you targeted ads based on your location, information and/or behavior. If you object, do not use our Site and/or exercise choices some third parties may offer. More
- How Do I Change My Information and Communications Preferences?
You may change certain account information and communications preferences as more fully detailed in this section. More
- What About Transfer of Information to the United States?
You consent to your data being transferred to the United States, which has different data protection laws than other countries. More
- What Should Parents Know About Children?
We do not intend to collect Personal Information from children. If you think we have, let us know. More
- What About Security?
No data security is absolute, but we endeavor to take reasonable steps to secure data appropriately. More
- Student Educational Records
To learn more about our FERPA policy, click here.
1. What Information Does the Site Collect?
(a) Information You Provide to Us
(b) Information Collected and Stored 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, browser, laptop, tablet, mobile phone or other device (a “Device”) whenever you visit or interact with our Site. To the extent we associate Usage Information with your Personal Information we collect directly from you on the Site, we will treat it as Personal Information.
This Usage Information may include:
- your IP address, UDID 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 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 web site 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 email 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 emails 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.
Browser Fingerprinting . Collection and analysis of information from your Device, such as, without limitation, your operating system, plug-ins, system fonts and other data, for purposes of identification.
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.
Tracking Technologies Usage. We may use Tracking Technologies for a variety of purposes, including:
Targeting‑Related . We may use Tracking Technologies to deliver content, including ads, relevant to your interests on our Site and third‑party sites based on how you interact with our advertisements or content. This includes using Tracking Technologies to understand the usefulness to you of the advertisements and content that havebeen delivered to you. Further information on this, and your opt-out choices, is found in Section 6 below.
Tracking Technologies Choices and Consent.
We are giving you detailed notice of the Tracking Technologies and your limited choices regarding them so that your consent is meaningfully informed.
Third Party Tracking and Do Not Track .
Various third parties are developing or have developed signals or other mechanisms for the expression of consumer choice regarding the collection of information about an individual consumer’s online activities over time and across third-party web sites or online services (e.g., browser do not track signals). Currently, we do not monitor or take any action with respect to these do not track signals or other mechanisms.
(c) Information Third Parties Provide About You
(d) Interactions with Third-Party Services
(e) 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 (names, email addresses, 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 contact information, 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.
2. How Do We Use the Information Collected?
- to provide you with information or services or process transactions that you have requested or agreed to receive or to provide you with marketing materials or services on behalf of us or third parties;
- to determine your admissibility and to register you for your selected educational programs;
- if you are a student at Saba, to allow you to gain access to course materials and other related content and services we make available to our students;
- to analyze academic and learning outcomes and preferences;
- to provide you with information concerning arrangements and other options for the repayment of funds loaned to you for your education;
- to enable you to participate in a variety of the Site’s features such as to allow you to participate in a webinar about the university;
- to process your application and/or registration submitted through the Site, including verifying your information is active and valid;
- 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;
- to contact you with regard to your use of the Site and, in our discretion, changes to the Site and/or Site’s policies;
- for internal business purposes; and
(b) Use of Information for Recruitment Purposes. Where you have provided us with Personal Information or Demographic Information as part of an online application for employment or internship, we may use that information in order to allow us to make an informed decision about whether to proceed with your application. We may, as part of this recruitment process, collect information about your education, employment history and similar matters. Where this Personal Information or Demographic Information is considered to be sensitive, you expressly consent to our processing of this information for recruitment purposes by submitting it to us.
(c) Interest-Based Advertising and Location-Based Services. We may also use your Personal Information, Demographic Information or Usage Information that we collect about you: (1) to specifically target relevant advertisements or content to you based on how you interact with our Site; (2) to understand the usefulness to you of the advertisements or content that have been delivered to you; and (3) to increase our Site profile, including allowing you to comment or add content to the Services.
3. How and When Do We Share Information with Third Parties?
(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. In addition, third parties may store, collect or otherwise have access to your information when you interact with their Tracking Technologies, content, tools apps or ads 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 and by so interacting you consent to such third party practices. It may also include ordering or purchasing products from third parties through us where we indicate that the third party rather than us is the seller. 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.
(c) To Protect the Rights of Saba and Others . To the fullest extent permitted by applicable law, we may also disclose your information if we believe in good faith that doing so is necessary or appropriate to: (i) protect or defend the rights, safety or property of Saba or third parties (including through the enforcement of this Policy, our Terms of Service, and other applicable agreements and policies); or (ii) comply with legal and regulatory obligations (e.g., pursuant to law enforcement inquiries, subpoenas or court orders). To the fullest extent permitted by applicable law, we have complete discretion in electing to make or not make such disclosures, and to contest or not contest requests for such disclosures, all 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 (“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) EEOC / Affirmative Action Reporting . In conjunction with U.S. laws and regulations enforced by the Equal Employment Opportunity Commission (“ EEOC”), the Office of Federal Contract Compliance Programs (“OFCCP”) and similar state and local regulatory agencies, we may ask you to provide us with self-identifying information (such as veteran status, gender and ethnicity). Providing such self-identifying information is voluntary, but if you do provide us with such information, we may submit that information, to the EEOC, the OFCCP and similar state and local regulatory agencies or otherwise use or disclose it for business-related purposes, including, without limitation, responding to information requests, fulfilling regulatory reporting requirements and defending against employment related complaints.
(f) Your California Privacy Rights .Under California law, California residents who have an established business relationship with Saba or one of its Affiliates may choose to opt out of Saba’s disclosure of personal information about them to third parties for direct marketing purposes. Unless noted at the time of collection, our policy is not to disclose personal information collected online to a third party for direct marketing purposes without your approval. If you choose to opt-out at any time after granting approval, write to Saba at Saba University School of Medicine, c/o R3 Education Inc., 27 Jackson Road, Suite 301, Devens, Massachusetts 01434, United States; By email: firstname.lastname@example.org.
(g) Your Connecticut Privacy Rights . Connecticut law requires any person or entity that collects Social Security numbers from Connecticut residents in the course of business to create a privacy protection policy and to publish or display it publicly. It is our policy to protect the confidentiality of Social Security numbers in our possession from misuse and improper disclosure by maintaining and enforcing policies and physical and electronic safeguards against misuse and improper disclosure. Unlawful disclosure of Social Security numbers is prohibited, and access to them is limited to personnel who need access to such information in order to perform their job functions.
(h) Your European Privacy Rights. If you are a resident of a Member State of the European Union you may have the right to ask us not to process your Personal Information for marketing purposes. We will inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking/unchecking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us in the following ways: Postal mail: Saba at Saba University School of Medicine, c/o R3 Education Inc., 27 Jackson Road, Suite 301, Devens, Massachusetts 01434, United States; By email: email@example.com .
4. What About Information I Disclose Publicly or to Others?
(a) User-Generated Content and Public Information. The Site may permit you to submit ideas, photographs, user profiles, writings, music, video, audio recordings, computer graphics, pictures, data, questions, comments, suggestions or other content, including Personal Information (collectively, “User Content”), such as on blogs and message boards. 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. Please think carefully before deciding what information you share, including Personal Information, in connection with your User Content. Please note that Saba 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. We are not responsible for the privacy or security of any information that you make publicly available on the Site or what others do with information you share with them on the 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 Service.
5. Do Third-Party Content, Links to Third-Party Sites, and/or Third-Party Apps 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 and they may be tracking you across multiple sites and may be sharing the results of that tracking with us and/or others. 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.
Third-party applications may also 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 and they may be tracking you across multiple sites and may be sharing the results of that tracking with us and/or others. 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. We also 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. What About Ads?
The Site’s third-party ad network and exchange providers, the advertisers, the sponsors and/or traffic measurement services may themselves set and access their own cookies (including Flash cookies), web beacons and other Tracking Technologies on your Device and track certain behavioral Usage Information regarding users of your Device via a Device Identifier. These third-party Tracking Technologies may be set to, among other things: (a) help deliver advertisements to you that you might be interested in; (b) prevent you from seeing the same advertisements too many times; and (c) understand the usefulness to you of the advertisements that have been delivered to you. You acknowledge and agree that associated technology may access and use your Device and may set or change settings on your Device in connection with the associated operations. Note that any images (or any other parts of content) served by third parties in association with third-party ads or other content may serve as web beacons, which enable third parties to carry out the previously described activities.
While we may use a variety of companies to serve advertisements, you may wish to visit http://www.networkadvertising.org/optout_nonppii.asp, which provides information regarding this practice by Network Advertising Initiative (“NAI”) members, and your choices regarding having this information used by these companies, including the “opt-out” procedures of NAI members. Opting out of one or more NAI members only means that those NAI members no longer will be allowed under their own rules to deliver targeted content and/or ads to you, which will affect this and other sites, but does not mean you will no longer receive any targeted content and/or ads. Also, if your browsers are configured to reject cookies when you visit this opt-out page, or you subsequently erase your cookies, use a different Device or change web browsers, your NAI opt-out may not, or may no longer, be effective. Additional information is available on the NAI’s web site accessible by the above link. You may also be able to opt-out of receiving third-party behavioral ads on certain sites by visiting the Digital Advertising Alliance (“DAA”) web site at http://www.aboutads.info/choices/#completed. Similar limitations may apply to the DAA opt-out. We are not responsible for effectiveness of or compliance with any third-parties’ opt-out options.
7. How Do I Change My Information and Communications Preferences?
8. What About Transfer of Information to the United States?
9. What Should Parents Know About Children?
We understand the importance of protecting children’s privacy in the interactive world. We are a general audience Site and do not use the Site to knowingly collect personal information from children under the age of 13 that requires parental notice and consent under the Children’s Online Privacy Protection Act (“COPPA”) without such parental consent. If you are a child under 18 years of age, you are not permitted to use the Site and should not send any information about yourself to us through the Site.
In the event that we become aware that we have collected personal information from any child, we will dispose of that information in accordance with COPPA and other applicable laws and regulations. If you are a parent or guardian and you believe that your child under the age of 13 has provided us with personal information without COPPA-required consent, please contact us at firstname.lastname@example.org.
10. What About Security?
We endeavor to incorporate commercially reasonable safeguards to help protect and secure your Personal Information. 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.
12. Student Educational Records
If you become a student, your educational records are subject to the U.S. federal Family Educational Rights and Privacy Act (“FERPA ”), state laws and SABA’s policies. Students have the right to limit access to FERPA-defined directory Information about them. To obtain a copy of Saba’s FERPA policy, click here. If you have questions about our FERPA policy, you may also contact us at email@example.com.
The following third parties that collect information from you on the 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|
PLEASE NOTE: We are not responsible for third-party policies or practices. We try to keep this information current, and will add to and subtract from the chart above as appropriate, 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.