Effective as of February 15, 2021
This “Privacy Policy” describes the privacy practices of the Western Interstate Commission for Higher Education (“WICHE”, “we”, “us”, or “our”) in connection with the www.wiche.edu website and any other website that we own or control and which posts or links to this Privacy Policy as well as WICHE’s educational services, units, organization, and special interest networks/cooperatives, including, without limitation,
We refer to our offerings collectively as the “Service.” This Privacy Policy also describes the rights and choices available to individuals with respect to their information. WICHE may provide additional or supplemental privacy policies to individuals for specific services that we offer at the time we collect personal information. These supplemental privacy policies will govern how we may process the information in the context of the specific service.
As you can see on our website, WICHE offers a variety of Services. Correspondingly, we collect personal information from a variety of sources and for a variety of reasons, and not all of the below categories of information or sources of information will be relevant to all Service users. Rather, the scope and sources of information are dependent upon the particular Service and your engagement with WICHE.
Information you provide to us. Personal information you provide to us through the Service or otherwise may include:
We, our service providers, and our partners may automatically log information about you, your computer or mobile device, and activity occurring on or through the Service, including but not limited, your computer or mobile device operating system type and version number, manufacturer and model, device identifier (such as the Google Advertising ID or Apple ID for Advertising), browser type, screen resolution, IP address, the website you visited before browsing to our website, general location information such as city, state or geographic area; information about your use of and actions on the Service, such as pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and length of access; and other personal information. Our service providers and partners may collect this type of information over time and across third-party websites and mobile applications.
On our webpages, this information is collected using cookies, browser web storage (also known as locally stored objects, or “LSOs”), web beacons, and similar technologies, and our emails may also contain web beacons.
A “cookie” is a text file that websites send to a website visitor‘s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. Browser web storage, or LSOs, are used for similar purposes as cookies. Browser web storage enables the storage of a larger amount of data than cookies. A “web beacon,” also known as a pixel tag or clear GIF, is typically used to demonstrate that a webpage was accessed or that certain content was viewed, typically to measure the success of our marketing campaigns or engagement with our emails and to compile statistics about usage of our websites.
Web browsers may offer users of our websites or mobile apps the ability to disable receiving certain types of cookies; however, if cookies are disabled, some features or functionality of our websites may not function correctly. Please see the “Targeted online advertising” section for information about how to exercise choice regarding the use of browsing behavior for purposes of targeted advertising.
Service users may have the opportunity to refer family members, professional contacts, colleagues, fellow students, or other contacts to us. If you are an existing user, you may only submit a referral if you have permission to provide the referral’s contact information to us so that we may contact them.
We use your personal information for the following purposes and as otherwise described in this Privacy Policy or at the time of collection:
To operate the Service. We use your personal information to:
For research and development. We analyze use of the Service to improve the Service and to develop new services, including by studying user demographics and use of the Service. We may use this information for any purpose in our discretion information, including to inform educational and governmental decisions.
To send you marketing and promotional communications. We may send you WICHE-related marketing communications as permitted by law. You will have the ability to opt-out of our marketing and promotional communications as described in the Opt out of marketing communications section below.
To comply with law. We use your personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.
For compliance, fraud prevention, and safety. We may use your personal information and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate to: (a) protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); (b) enforce the terms and conditions that govern the Service; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.
With your consent. In some cases we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.
To create anonymous, aggregated or de-identified data. We may create anonymous, aggregated or de-identified data from your personal information and other individuals whose personal information we collect. We make personal information into anonymous, aggregated or de-identified data by removing information that makes the data personally identifiable to you. We may use this anonymous, aggregated or de-identified data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our functions.
Service providers. We may share your personal information with third-party companies and individuals that provide services on our behalf or help us operate the Service (such as customer support, hosting, analytics, payment processing, event registration, email delivery, marketing, and database management services).
Partners. We may share your personal information with partners. For example, if you attend an event that we host, we may share your information with other event sponsors. You should review the Privacy Policy of any such partner as we do not control how these partners may use your personal information.
Educational institutions. We may share your personal information with your originating educational institution or the educational institutions in which you are interested in enrolling. We may allow these educational institutions to collect information directly via our service. We do not control how these institutions may use your personal information. For information on how these institutions may use your personal information, please review the relevant institution’s Privacy Policy.
State and territorial agencies. We may share your personal information with state educational agencies in your state/territory of residence or the state/territory in which you are interested in enrolling in an educational institution. We do not control how these state/territorial agencies may use your personal information. For information on how these agencies may use your personal information, please refer to the specific agency to whom your personal information is disclosed.
Other users of the Service and the public. We may provide functionality that enables you to disclose personal information to other users of the Service or the public. For instance, you may submit a testimonial or other content to the Service (such as comments, reviews, surveys, blogs, photos, and videos), and we will display your information such as your name and educational information along with the content you submit. We may also display your information in association with events that we host. We do not control how other users or third parties use any personal information that you make available to such users or the public.
Professional advisors. We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.
For compliance, fraud prevention and safety. We may share your personal information for the compliance, fraud prevention and safety purposes described above.
Organizational change. We may transfer or otherwise share some or all of our organizational assets, including your personal information, in connection with an organizational change (or potential organizational change) such as a merger, consolidation, reorganization or sale of assets, or in the event of bankruptcy or dissolution.
In this section, we describe the rights and choices available to all Service users. Access or Update Your Information. If you have registered for an account with us, you may review and update certain personal information in your account profile by logging into the account.
Opt out of marketing communications. You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions here. If you do not see an option for opting out of a particular type of communication, contact us at privacy@wiche.edu. You may continue to receive service-related and other non-marketing emails.
Cookies and browser web storage. We may allow service providers and other third parties to use cookies and similar technologies to track your browsing activity over time and across the Service and third-party websites. Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that if you set your browser to disable cookies, the Sites may not work properly. Similarly, your browser settings may allow you to clear your browser web storage.
Do not track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
Choosing not to share your personal information. Where we are required by law to collect your personal information, or where we need your personal information in order to provide the Service to you, if you do not provide this information when requested (or you later ask to delete it), we may not be able to provide you with our services. We will tell you what information you must provide to receive the Service by designating it as required at the time of collection or through other appropriate means.
The Service may contain links to other websites, mobile applications, and other online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or in mobile applications or online services that are not associated with us. We do not control third party websites, mobile applications or online services, and we are not responsible for their actions. Other websites, mobile applications and services follow different rules regarding the collection, use and sharing of your personal information. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.
The security of your personal information is important to us. We employ a number of organizational, technical and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies. We cannot guarantee the security of your personal information.
We are headquartered in the United States and may have service providers in other countries, and your personal information may be transferred to the United States or other locations outside of your state, province, or country where privacy laws may not be as protective as those in your state, territory, province, or country.
As a general rule, children are not allowed to use the Service, and we do not collect personal information from them. We define “children” as anyone under 13 years old. If we learn that we have collected personal information of a child without the consent of the child’s parent or guardian, we will delete it. We encourage parents with concerns to contact us.
We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service. We may, and if required by law will, also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via e-mail (if you have an account where we have your contact information) or another manner through the Service.
Any modifications to this Privacy Policy will be effective upon our posting the new terms and/or upon implementation of the new changes on the Service (or as otherwise indicated at the time of posting). In all cases, your continued use of the Service after the posting of any modified Privacy Policy indicates your acceptance of the terms of the modified Privacy Policy.
Please direct any questions or comments about this Privacy Policy or privacy practices to privacy@wiche.edu. You may also write to us via postal mail at:
Western Interstate Commission for Higher Education
Attn: Legal – Privacy
3035 Center Green Drive, Suite 200
Boulder, CO 80301