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WQU Privacy Policy

WorldQuant University – Consolidated Privacy Policy

Overview – the key information you should be aware of
(A) Who we are:

We are WorldQuant University, an accredited international not-for-profit dedicated to advancing global education. If you need it, our registered address is at 201, St. Charles Avenue, Suite 2500, New Orleans, LA 70170, USA. WorldQuant University is the controller of your personal information, and is responsible for your personal information. All references in this policy to "University", "our", "us" or "we" refer to WorldQuant University. All references in this policy to "our website", refer to the website owned by WorldQuant University at www.wqu.edu.

(B) Our values and what this policy is for:

We value your privacy and want to be accountable and fair to you as well as transparent with you in the way that we collect and use your personal information. We also want you to know your rights in relation to your information which you can find here.

In line with these values, this privacy policy tells you what to expect when we collect and use personal information about you. We have tried to make it easy for you to navigate so you can find the information that is most relevant to you and our relationship with you.

We are always looking to improve the information we provide to our students, applicants, contacts and our website visitors so if you have any feedback on this privacy policy, please let us know using our contact details in section 13.

(C) Who this policy applies to

This policy applies to:

  1. Students and Applicants
  2. Visitors to our website;
  3. Prospective students (to whom we send marketing communications);
  4. People who contact us with enquiries; and
  5. Our suppliers, and employees of our suppliers.

Depending on our relationship with you, we will collect and use your information in different ways. Please click on the links above to find out the information that we collect about you and how we use this information.

(D) What this policy contains

This privacy policy describes the following important topics relating to your information (you can click on the links to find out more):

  1. How we obtain your personal information;
  2. Collection of your personal information and how we use it:
  3. Legal basis for using your personal information;
  4. How and why we share your personal information with others;
  5. Your rights;
  6. How long we store your personal information;
  7. Children;
  8. Marketing;
  9. Where we may transfer your personal information;
  10. Risks and how we keep your personal information secure;
  11. Links to other websites;
  12. Changes to this privacy policy; and
  13. Further questions and how to make a complaint.
(E) Your rights to object

You have various rights in respect of our use of your personal information as set out in section 6. Two of the fundamental rights to be aware of are that:

  1. you may ask us to stop using your personal information for direct-marketing purposes. If you exercise this right, we will stop using your personal information for this purpose.
  2. you may ask us to consider any valid objections which you have to our use of your personal information where we process your personal information on the basis of our, or another person's, legitimate interest.

You can find out more information in section 6.

(F) What you need to do and your confirmation to us:

Please read this privacy policy carefully to understand how we handle your personal information. By engaging with us in the ways set out in this privacy policy, you confirm that you have read and understood the entirety of this privacy policy, as it applies to you.

The detail – the key information you should be aware of
1. How we obtain your personal information:
  1. You may provide us with your personal information voluntarily.
  2. You may give us personal information about yourself by using the online application forms provided on our website, or by contacting us by phone, email or other means. This includes, for example, where you provide your personal information to us in order to receive information or services from us. If you are a supplier, you may also give us personal information about you when you are offering or providing services to us.
2. Collection of your personal information and how we use it

Please go to the section or sections below that best describes our relationship with you to find out the information that we collect about you and how we use this information. We refer to this as "personal information" throughout this policy.

2.1 Students and Applicants

a) What personal information we collect about you

Applicants – Where you make an application for one of our educational programs we, or third parties on our behalf, may collect and use any of the following information (or documents) about you:

  • Full name
  • Postal address
  • Email address
  • Date of birth
  • Gender
  • Marital status
  • Country of residence
  • Nationality
  • Time zone
  • Highest previous degree earned
  • Field of study (for highest previously earned degree)
  • Previous University
  • Employment level (full time, part time, etc.)
  • Industry
  • Job title (Intern, Junior Management, Senior Management etc.)
  • Picture of Government issued photo ID
  • Copy of unofficial college/university transcript for highest previously earned degree
  • English proficiency certificate (if applicable)
  • Quantitative Proficiency Test results
  • Admissions Quiz results

Students – If your online application is successful and you become one of our students then we, or third parties on our behalf, may collect and use any of the following additional information about you:

  • Enrollment Agreement for our MSc in Financial Engineering program
  • User Agreement for our Applied Data Science Lab
  • List of courses attempted and completed with final grade and credits earned
  • Cumulative Average Score (calculated by our systems using your final grades at the end of each course in the relevant program)
  • Transferred Credits (assigned to you based on submitted official transcripts from a previously completed graduate level degree program)
  • Your courses, grades and SAP (including results from quizzes, group work and coursework)
  • Keystroke analysis (this is provided as part of account creation with the online proctoring service that we use)
  • Medical records (for students needing special learning accommodations)

b) How we use your personal information

We will collect, use and store the personal information listed above for the following reasons:

  1. as part of our admissions process and requirements to determine your eligibility to become a student;
  2. to register you as a student (for example, identity verification);
  3. to maintain your student records and monitor your academic progress
  4. if it is in our legitimate interests, for marketing and communications purposes;
  5. to maintain our educational accreditation (for example, our accreditation rules require us to hold students' contact information, including their physical address);
  6. to administer your study and provide and improve the educational programs that we offer to students;
  7. to keep applicants and enrolled students engaged by reminding them to complete their application or assignments ahead of upcoming deadlines;
  8. to manage online examinations through online proctoring
  9. to manage queries, complaints, appeals and allegations of misconduct;
  10. diversity monitoring;
  11. to meet our obligations under the Family Educational Rights and Privacy Act (FERPA) – for further details about your rights under FERPA and how we may use your data in accordance with FERPA, please see section 5.2 below (Your Rights);
  12. to uphold our policies and procedures (for example, our Code of Conduct);
  13. to facilitate special accommodations for your learning, examinations and assessments;
  14. to ensure your safety and security and that of others; and
  15. to carry out statistical analysis and market research on people who may be interested in our educational programs.

Please see sections 2.6 and 2.7 for more details about how we use your personal information.

c) Automated decision making

As part of your online application, you will be required to complete a multiple-choice assessment with a minimum passing score. We rely on an automatic process (without human intervention) to indicate whether you have met the relevant passing score to be considered eligible for admission. We also use automated grading for quiz assignments in our MSc in Financial Engineering program and all projects in our Applied Data Science Lab. You can ask us to review this decision where you are unhappy with the decision that has been made

d) Source of personal information.

We may receive some of your personal information from third parties.

e) Sensitive data.

Some countries may regard the types of personal information that we collect about you as being particularly sensitive (this type of data is also known as special categories of data). Special categories of data include information about physical and mental health, sexual orientation, racial or ethnic origin, political opinions, philosophical belief, trade union membership and biometric data. For example, we are committed to providing access to education for students with disabilities and will consider reasonable accommodations for qualifying disabled individuals in accordance with law. If you make this type of request we will process health data that you provide in support of your application (such your as your disability or medical records) in order for us to assess the application and, if it qualifies, make the necessary special accommodations for you during your studies.

f) Information we need to provide services to you.

We need certain types of personal information so that we can provide services to you and perform contractual and other legal obligations that we have to you. If you do not provide us with such personal information, or if you ask us to delete it, you may no longer be able to access our educational programs.

2.2 Visitors to our website

a) What personal information we collect about you

We, or third parties on our behalf, may collect and use any of the following information about you:

  1. your name including your title;
  2. your postal address;
  3. your email address;
  4. your telephone number;
  5. information provided when you correspond with us;
  6. any updates to information provided to us;
  7. personal information we collect about you or that we obtain from our third party sources; and
  8. the following information created and recorded automatically when you visit our website:
    1. Technical information. This includes: the Internet Protocol (IP) address used to connect your device to the internet address; the website address and country from which you access information; the files requested; browser type and version; browser plug-in types and versions; operating system; and platform. We use this personal information to administer our website, to measure the efficiency of our systems and to undertake an analysis on the locations from which people access our webpages (including where you visit our webpages by clicking on an advertisement); and
    2. Information about your visit and your behaviour on our website (for example, the pages that you click on). This may include the website you visit before and after visiting our website (including date and time), time and length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, traffic data, location data, weblogs and other communication data and information provided when requesting further service or downloads.

b) How we use your personal information

We will collect, use and store the personal information listed above for the following reasons:

  1. to allow you to access and use our website and the services;
  2. to receive enquiries from you through the website about our services;
  3. for improvement and maintenance of our website and to provide technical support for our website;
  4. to ensure the security of our website;
  5. to recognise you when you return to our website, to store information about your preferences, and to allow us to customise the website according to your individual interests; and
  6. to evaluate your visit to the website and prepare reports or compile statistics to understand the type of people who use our website, how they use our website and to make our website more intuitive. Such details will be anonymised as far as reasonably possible and you will not be identifiable from the information collected.

Please see sections 2.6 and 2.7 for more details about how we use your personal information.

c) A word about cookies

  1. Some pages on our website use cookies, which are small files placed on your internet browser when you visit our website. We use cookies in order to offer you a more tailored experience in the future, by understanding and remembering your particular browsing preferences.
  2. The information from cookies and related technology is stored in web server logs and also in web cookies kept on your devices, which are then transmitted back to us by your devices. These servers are operated and the cookies managed by us, our business partners or our service providers. For example, when you access our website we and our service providers may place cookies on your devices. Cookies allow us to recognize you when you return so you will not be required to register again for use of the same and track your use of the website and/or any such capability, software or service. They also help us to detect certain kinds of fraud.
  3. Some cookies contain numbers that allow us to connect the website with other information we store about you in your profile or as related to your interactions with the website and. Some cookies are temporary, whereas others may be configured to last longer. “Session” cookies are temporary cookies used for various reasons, such as to manage page views. Your browser usually erases session cookies once you exit your browser. “Persistent” cookies are more permanent cookies that are stored on your devices even beyond when you exit your browser. We use persistent cookies for a number of purposes, such as retrieving certain information you have previously provided and storing such information.
  4. Pixel tags and web beacons are tiny graphic images placed on website pages or in our emails that allow us to determine whether you have performed specific actions. When you access these pages or open email messages, the pixel tags and web beacons generate a notice of that action to us or our service providers. These tools allow us to measure response to our communications and improve the website.
  5. We use cookies (including similar technologies) that are essential to enable your use of our site or services, such as assisting with your account login, so we can show you the appropriate experience and features such as your account information, history, and to edit your account settings. They may also provide authentication, site security, and help localize the language based on the geography of your visit.
  6. We also use certain non-essential cookies, which we need your consent to set, which are Google Ads, AppNexus and Facebook cookies. The duration of these cookies is either 90 days or until you clear the cookies (whichever is shorter).
  7. We use:
    1. Google Ads cookies to track conversions from our ads;
    2. AppNexus cookies to buy, sell, and deliver online advertising; and
    3. Facebook cookies to record web and third-party app data received about users through Facebook’s business tools.
  8. We also utilise Google Tag Manager, which is a tag management system that we use to collect information from the Google Ads, AppNexus and Facebook cookies (a) in order to track conversions to our Applied Data Science Lab waitlist and our MSc in Financial Engineering program, and (b) for account creation, the uploading of required documents, and the final completion of an application to either our Applied Data Science Lab or MSc in Financial Engineering program.
  9. Where we use cookies or similar technologies on our website, you may block these at any time. To do so, you can activate the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies similar technologies (including essential cookies similar technologies), you may not be able to access all or parts of our website or to use all the functionality provided through our website.

2.3 Prospective students who have started an application to whom we send marketing communications

a) We, or third parties on our behalf, may collect and use any of the following information about you:

  1. your name including your title;
  2. your email address;
  3. your country; and
  4. information about your communication preferences.

b) How we use your personal information

We will collect, use and store the personal information listed above, if you have consented or, otherwise, if it is in our legitimate interests, for business development and marketing purposes, to contact you (including by telephone, email or post) with information about our services which either you request, or which we feel will be of interest to you (including newsletters).

Please see sections 2.6 and 2.7 for more details about how we use your personal information.

c) Source of personal information.

We may receive some of your personal information from third parties, such as marketing agencies.

2.4 People who contact us with enquiries

a) We, or third parties on our behalf, may collect and use any of the following information about you:

  1. your name including your title;
  2. your country;
  3. your email address;
  4. information provided when you correspond with us; and
  5. any updates to information provided to us.

b) How we use your personal information

We will collect, use and store the personal information listed above to deal with any enquiries or issues you have about our products and services, including any questions you may have about how we collect, store and use your personal information, or any requests made by you for a copy of the information we hold about you. If we do not have a contract with you, we may process your personal information for these purposes where it is in our legitimate interests for customer services purposes.

Please see sections 2.6 and 2.7 for more details about how we use your personal information.

2.5 Our suppliers, and employees of our suppliers

a) We, or third parties on our behalf, may collect and use any of the following information about you:

  1. your name including your title;
  2. work contact information (phone number, postal address, mailing address, email address); and
  3. your job title.

b) How we use your personal information

We will collect, use and store the personal information listed above for the following reasons:

  1. to enable us to purchase and receive products and services from you (including supplier due diligence, payment and expense reporting and financial audits); and
  2. to deal with enquiries from you.

Please see sections 2.6 and 2.7 for more details about how we use your personal information.

c) Source of personal information.

We may receive some of your personal information from third party sources, such as your employer or your employer's company website. We may also collect this personal information from publicly-available sources, such as LinkedIn.

d) Information we need to receive services from you.

Please note that we need certain types of personal information so that you or your employer can provide services to us. If you do not provide us with such personal information, or if you or your employer ask us to delete it, you may no longer be able to provide services to us.

2.6 Whatever our relationship with you is, we may also collect, use and store your personal information for the following additional reasons:

  1. to deal with any enquiries or issues you have about how we collect, store and use your personal information, or any requests made by you for a copy of the information we hold about you. If we do not have a contract with you, we may process your personal information for these purposes where it is in our legitimate interests for customer services purposes;
  2. for internal corporate reporting, business administration, ensuring adequate insurance coverage for our business, ensuring the security of company facilities, research and development, and to identify and implement business efficiencies. We may process your personal information for these purposes where it is in our legitimate interests to do so;
  3. to comply with any procedures, laws and regulations which apply to us – this may include where we reasonably consider it is in our legitimate interests or the legitimate interests of others to comply, as well as where we are legally required to do so; and
  4. to establish, exercise or defend our legal rights – this may include where we reasonably consider it is in our legitimate interests or the legitimate interests of others, as well as where we are legally required to do so.

2.7 Further processing

Before using your personal information for any purposes which fall outside those set out in this section 2, we will undertake an analysis to establish if our new use of your personal information is compatible with the purposes set out in this section 2. Please contact us using the details in section 13 if you want further information on the analysis we will undertake.

3. Legal basis for use of your personal information

3.1 We consider that the legal bases for using your personal information as set out in this privacy policy are as follows:

  1. our use of your personal information is necessary to perform our obligations under any contract with you (for example, to fulfil our obligations under our Enrollment Agreement with students, to enroll a student in an educational program, to communicate with students, to comply with the terms of use of our website which you accept by browsing our website and/or to comply with our contract to receive services from you or your employer); or
  2. our use of your personal information is necessary for complying with our legal obligations (for example, for health and safety purposes); or
  3. where neither (a) nor (b) apply, use of your personal information is necessary for our legitimate interests or the legitimate interests of others (for example, to ensure the security of our website). Our legitimate interests are to:
    1. run, grow and develop the University to fulfil our mission to make advanced, quality education accessible to capable students everywhere by leveraging technology at scale to deliver entirely free online programs;
    2. operate and improve our website and ensure that it is secure;
    3. select appropriately qualified students as part of our admissions process;
    4. select appropriately skilled and qualified suppliers;
    5. ensure a safe environment for our students and employees;
    6. carry out marketing, market research and business development which is tailored to our student audience and helps us to fulfil our mission;
    7. comply with our obligations under US law (such as FERPA and the American with Disabilities Act (ADA)); and
    8. for internal group administrative purposes, such as to support our audit, legal, finance or compliance functions.

If we rely on our (or another person's) legitimate interests for using your personal information, we will undertake a balancing test to ensure that our (or the other person's) legitimate interests are not outweighed by your interests or fundamental rights and freedoms which require protection of the personal information. You can ask us for information on this balancing test by using the contact details at section 13.

3.2 We may use your special categories of data (such as health and wellbeing information for the purposes of special accommodations) where you have provided your consent (which you may withdraw at any time after giving it, as described below).

3.3 We may process your personal information in some cases for marketing purposes on the basis of your consent (which you may withdraw at any time after giving it, as described below).

3.4 If we rely on your consent for us to use your personal information in a particular way, but you later change your mind, you may withdraw your consent by contacting us by using the contact details at section 13 and we will stop doing so. However, if you withdraw your consent, this may impact the ability for us to be able to provide our services to you (for example, if you withdraw your consent to us using your health data we will not be able to make special accommodations for you).

4. How and why we share your personal information with others

4.1 We may share your personal information with companies that are affiliated with our organisation where it is in our legitimate interests to do so for internal administrative purposes (for example, for corporate strategy, compliance, auditing and monitoring, research and development and quality assurance).

4.2 We will share your personal information with the following third parties or categories of third parties:

  1. our partners who support us in delivering the content of our educational programs to you through an online learning management system;
  2. our website management and customer optimisation suppliers;
  3. suppliers who provide online tools to assist with assessments and qualifications, including our online proctoring provider (Examity), our provider of anti-plagiarism tools (Turnitin) and the provider of our online credentials functionality (Credly);
  4. online video-conferencing suppliers, such as Zoom;
  5. AWS and Google who act as our cloud service providers;
  6. our other service providers and sub-contractors, including payment processors, utility providers, suppliers of technical and support services, insurers, and logistic providers;
  7. public agencies and the emergency services;
  8. companies that assist in our communications, administrative student support, marketing, advertising and promotional activities, such as marketing automation and email delivery providers (e.g. MailChimp, Intercom, SendGrid);
  9. suppliers providing functionality allowing us to perform surveys and market research , such as Google Forms and Surveymonkey;
  10. analytics and search engine providers that assist us in the improvement and optimisation of our website; and
  11. the third parties set out in Section 5.2 in connection with our obligations under FERPA.

4.3 We will also disclose your personal information to third parties:

a) where it is in our legitimate interests to do so to run, grow and develop our organisation:

  1. if we sell or buy any business or assets, we may disclose your personal information to the prospective seller or buyer of such business or assets;
  2. if substantially all of our or any of our affiliates' assets are acquired by a third party, in which case personal information held by us will be one of the transferred assets;

b) if we are under a duty to disclose or share your personal information in order to comply with any legal obligation, any lawful request from government or law enforcement officials and as may be required to meet national security or law enforcement requirements or prevent illegal activity;

c) in order to enforce or apply our terms of use, our terms and conditions for customers or any other agreement or to respond to any claims, to protect our rights or the rights of a third party, to protect the safety of any person or to prevent any illegal activity; or

d) to protect the rights, property, or safety of the University, our staff, our students or other persons. This may include exchanging personal information with other organisations for the purposes of fraud protection and credit risk reduction.

4.4 We may also disclose and use anonymised, aggregated reporting and statistics about users of our website or services for the purpose of internal reporting or reporting to our affiliated organisations or other third parties, and for our marketing and promotion purposes. None of these anonymised, aggregated reports or statistics will enable our users to be personally identified.

4.5 Save as expressly detailed above, we will never share, sell or rent any of your personal information to any third party without notifying you and, where necessary, obtaining your consent. If you have given your consent for us to use your personal information in a particular way, but later change your mind, you should contact us and we will stop doing so.

5. Your rights

5.1 Depending on our relationship with you and your location, you may have certain rights in relation to your personal information. If you would like further information in relation to these or would like to exercise any of them, please contact us by using the contact details at section 13 at any time. We have summarised these rights in further detail below. Please go to the section or sections below that best describes our relationship with you to find out the information that we collect about you and how we use this information.

5.2 If you are a student you have rights under the Family Educational Rights and Privacy Act (FERPA)

  1. Our policy regarding student privacy, confidentiality and data rights follows the Family Educational Rights and Privacy Act (FERPA) guidelines. FERPA is a US law designed to protect the privacy of educational records, establish the rights of students to inspect and review their educational records, and provide guidelines for the correction of inaccurate or misleading information through informal and formal hearings.
  2. Under FERPA, our students are afforded the following rights:
    1. the right to inspect and review their own educational record pertaining to academic standing and other information at any time;
    2. the right to request the amendment of their educational record that they believe to be inaccurate or misleading. The University will investigate the request and may decide whether to accept the amendment;
    3. the right to not disclose their educational records without obtaining prior written consent, except to the extent that FERPA authorizes disclosure without consent as outlined in paragraph (c) below; and
    4. the right to file a complaint with the US Department of Education concerning alleged failures by the University to comply with FERPA requirements, in the instance that a complaint cannot be resolved within the University.
  3. In accordance with FERPA, student personal academic information may be disclosed by us without the student’s written permission to the following third parties:
    1. a school official with legitimate educational interest (i.e., WQU employees or third parties contracted by WQU whose responsibility justifies access to all or part of an educational record);
    2. other schools to which the student desires to transfer;
    3. officials of the US Department of Education, state education authorities, and other appropriate parties following health and safety emergency or judicial orders;
    4. accrediting organizations while carrying their functions; and
    5. organizations conducting research for us.
  4. Should students wish to authorize access to information in their student records by another party, such as a spouse or employer, they must submit a written notification to us with the full name of the person or agency to whom the personal information should be released. Those named parties must know personal information regarding the student before a University’s official will disclose the student information.
  5. The University identifies the following items as “Directory Information” which may be released without a student's written permission: Name; City; State and Country of residence; dates of attendance; enrollment status; credentials and awards received; the most recent school attended; and other comparable information. If a student does not want this information disclosed, they must notify the University by using the contact details at section 13.
  6. The University depends on the accuracy of the records submitted by its students. False information on an application as well as any act to intentionally mislead or misinform instructional personnel or administrators is grounds for disciplinary action, including dismissal from the University. Students seeking access or amendment to their educational records should contact the University Student Support team via email at address outlined at the end of this policy.

5.3 You may also have the following additional rights:

  1. Right of access: You have a right of access to any personal information we hold about you. You can ask us for a copy of your personal information; confirmation as to whether your personal information is being used by us; details about how and why it is being used; and details of the safeguards which are in place if we transfer your information outside of the United Kingdom or the European Economic Area ("EEA").
  2. Right to update your information: You have a right to request an update to any of your personal information which is out of date or incorrect.
  3. Right to delete your information: You have a right to ask us to delete any personal information which we are holding about you in certain specific circumstances. You can ask us for further information on these specific circumstances by contacting us using the details in section 13. We will pass your request onto other recipients of your personal information unless that is impossible or involves disproportionate effort. You can ask us who the recipients are, using the contact details in section 13.
  4. Right to restrict use of your information: You have a right to ask us to restrict the way that we process your personal information in certain specific circumstances. You can ask us for further information on these specific circumstances by contacting us using the details in section 13. We will pass your request onto other recipients of your personal information unless that is impossible or involves disproportionate effort. You can ask us who the recipients are using the contact details in section 13.
  5. Right to stop marketing: You have a right to ask us to stop using your personal information for direct marketing purposes. If you exercise this right, we will stop using your personal information for this purpose.
  6. Right to data portability: You have a right to ask us to provide your personal information to a third party provider of services. This right only applies where we use your personal information on the basis of your consent or performance of a contract; and where our use of your information is carried out by automated means.
  7. Right to object: You have a right to ask us to consider any valid objections which you have to our use of your personal information where we process your personal information on the basis of our or another person's legitimate interest.

We will consider all such requests and provide our response within a reasonable period (and in any event within one month of your request unless we tell you we are entitled to a longer period under applicable law). Please note, however, that certain personal information may be exempt from such requests in certain circumstances, for example if we need to keep using the information to comply with our own legal obligations or to establish, exercise or defend legal claims. If an exception applies, we will tell you this when responding to your request. We may request you provide us with information necessary to confirm your identity before responding to any request you make.

6. How long we store your personal information

We keep your personal information for no longer than necessary for the purposes for which the personal information is processed. The length of time for which we retain personal information depends on the purposes for which we collect and use it and/or as required to comply with applicable laws and to establish, exercise or defend our legal rights. For example, in accordance with our obligations under FERPA we maintain student records for a minimum of seven years after the student graduates, or otherwise exits, and transcripts of grades for a period of fifty years. You can find further information about our student record maintenance policy by contacting us by using the contact details at section 13.

7. Children

7.1 You must be aged 18 or over to use our website and receive our services. We do not collect or maintain information from anyone known to be under the age of 13, and no part of our website is designed to attract anyone under the age of 13.

7.2 If you are a child and we learn that we have inadvertently obtained personal information from you from our websites, or from any other source, then we will delete that information as soon as possible.

7.3 Please contact us by using the contact details at section 13 if you are aware that we may have inadvertently collected personal information from a child.

8. Marketing

8.1 We may collect and use your personal information for undertaking marketing by email. For example, we may follow up with prospective students who have expressed interest in our educational programs by signing up on our website, or engaging with our online social profile pages.

8.2 We may send you certain marketing communications (including electronic marketing communications) if it is in our legitimate interests to do so for marketing and business development purposes.

8.3 However, we will always obtain your consent to direct marketing communications where we are required to do so by law and if we intend to disclose your personal information to any third party for such marketing.

8.4 If you wish to stop receiving marketing communications, you can contact us by using the contact details at section 13.

9. Where we may transfer your personal information

9.1 We are headquartered in the United States and so your personal information will be used, stored and/or accessed by staff operating outside the UK or the EEA working for us, and other members of our group or suppliers. Further details on to whom your personal information may be disclosed are set out in section 4.

9.2 If we make an onward transfer of any personal information about you to any such non-UK and non-EEA entities, we will take appropriate measures to ensure that the recipient protects your personal information adequately in accordance with this privacy policy. These measures may include the following:

  1. ensuring that there is an adequacy decision by the UK Government in the case of transfers out of the UK, or by the European Commission in the case of transfers out of the EEA, which means that the recipient country is deemed to provide adequate protection for such personal data; or
  2. where we have in place standard model contractual arrangements with the recipient which have been approved by the European Commission (or the UK Government for transfers out of the UK in due course). These model contractual clauses include certain safeguards to protect the personal data;

9.3 Further details on the steps we take to protect your personal information, in these cases is available from us on request by contacting us by using the contact details at section 13 at any time.

10. Risks and how we keep your personal information secure

10.1 The main risk of our processing of your personal information is if it is lost, stolen or misused. This could lead to your personal information being in the hands of someone else who may use it fraudulently or make public, information that you would prefer to keep private.

10.2 For this reason, we are committed to protecting your personal information from loss, theft and misuse. We take all reasonable precautions to safeguard the confidentiality of your personal information, including through use of appropriate organisational and technical measures such as antivirus software and by carrying regular backups of our information.

10.3 In the course of provision of your personal information to us, your personal information may be transferred over the internet. Although we make every effort to protect the personal information which you provide to us, the transmission of information over the internet is not completely secure. As such, you acknowledge and accept that we cannot guarantee the security of your personal information transmitted to our website and that any such transmission is at your own risk. Once we have received your personal information, we will use strict procedures and security features to prevent unauthorised access to it.

10.4 Where we have given you (or where you have chosen) a password which enables you to access your online account, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

11. Links to other websites

Our website may contain hyperlinks to websites that are not operated by us. These hyperlinks are provided for your reference and convenience only and do not imply any endorsement of the activities of such third-party websites or any association with their operators. This privacy policy only applies to the personal information that we collect or which we receive from third party sources, and we cannot be responsible for personal information about you that is collected and stored by third parties. Third party websites have their own terms and conditions and privacy policies, and you should read these carefully before you submit any personal information to these websites. We do not endorse or otherwise accept any responsibility or liability for the content of such third party websites or third party terms and conditions or policies.

12. Changes to our privacy policy

We may update our privacy policy from time to time. Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by post or email. Please check back frequently to see any updates or changes to our privacy policy.

13. Further questions and how to make a complaint

13.1 If you have any queries or complaints about our collection, use or storage of your personal information, or if you wish to exercise any of your rights in relation to your personal information, please contact info@wqu.edu. We will investigate and attempt to resolve any such complaint or dispute regarding the use or disclosure of your personal information.

13.2 You may also make a complaint to the data protection regulator in the country where you usually live or work, or where an alleged infringement of applicable data protection laws has taken place. Alternatively, you may seek a remedy through the courts if you believe your rights have been breached.

The practices described in this privacy policy statement are current as of April 2022.

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