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.
We value the privacy of our students, policymakers, stakeholders, and research partners and we take certain organizational and operational steps designed to protect this privacy.
Personal Information We Collect
We may collect your personal information (i) automatically, when you use the Sites; and (ii) when you provide personal information to us directly, such as when you complete a form provided on the Sites or contact us for more information.
Personal information you provide to us through the Sites may include:
- Membership application information, including organizational and personal contact information, such as your first and last name, phone number, email and mailing addresses, professional title, institutional/organizational name and digital signature.
- Contact Us information, including email address, and content you choose to include in the message. Please refrain from sending us Protected Health Information or sensitive personal information.
- Account information, such as username and access credentials for an online account to access the Sites.
- Newsletter registration information, including name, organization, title, and email.
- Registration information, such as information that may be related to a service, an account or an event for which you register.
- Feedback or correspondence, such as information you provide when you contact us with questions, feedback, or otherwise correspond with us online.
- Testimonial information, such as information you provide when you submit a testimonial regarding your experience with our services.
- Marketing information, such as your preferences for receiving communications about our activities, events, and publications, and details about how you engage with our communications staff.
Cookies and Other Information Collected by Automated Means
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 Sites, 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 Sites, 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.
Google Analytics. Visitors to the Sites may be tracked using Google Analytics. The data personal information collected by Google Analytics is primarily used to optimize the Sites for users; however, we may also use this data for marketing purposes. The personal information we automatically collect using Google Analytics is shared with Google. For more information on Google’s Privacy Policies, visit: https://policies.google.com/privacy. You can also opt-out of having your personal information used by Google Analytics by following the instructions located at https://tools.google.com/dlpage/gaoptout/.
Third Parties, Including Referrals
Sites 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.
Additionally, we may receive Personal Information from third parties, such as our payment processors to facilitate transactions and services.
How We Use Your Personal Information
We use your personal information:
- to provide, operate and improve the Sites and related services;
- to provide information about our services;
- to establish and maintain your user profile or membership;
- to communicate with you about our services, including by sending you announcements, updates, security alerts, and support and administrative messages;
- to communicate with you about events in which you participate;
- to enable security features of the Sites, such as by sending you security codes via email or SMS or other means and remembering the devices from which you have previously logged into the Sites;
- to facilitate your ability to interact with others who use the Sites such as by identifying and suggesting individuals with whom you should connect;
- to understand your needs and interests, and personalize your experience with the Sites and related services and our communications;
- to provide support and maintenance for the Sites;
- to respond to your requests, questions and feedback;
- to send you marketing and promotional communications. You will have the ability to opt-out of our marketing and promotional communications as described in the Opt out of marketing communicationssection below.
- to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.
- to maintain 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 Sites and related services; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.
- to 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 Sites and related services and promote our functions.
- as otherwise directed with your consent to collect, use or share your personal information.
How We Share Your Personal Information
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 Sites and the public. We may provide functionality that enables you to disclose personal information to other users of the Sites and its related services or the public. For instance, you may submit a testimonial or other content to the Sites (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. With permission, 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, web developers, SEO consultants, 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.
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 firstname.lastname@example.org. You may continue to receive service-related and other non-marketing emails.
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 our services 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 services by designating it as required at the time of collection or through other appropriate means.
Other Sites, Mobile Applications and Services
The Sites 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.
International Data Transfers
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.
WICHE Cooperative for Educational Technologies (“WCET”) and International Members
WCET may attract members from outside the United States, including but not limited to the European Economic Area (“EEA”) and Canada. If you are from the EEA or Canada and applying to be a member or requesting information on WCET, please see our below additional privacy practices and rights.
EEA Members and Sites Users
For this section, Personal Data means any information relating to an identified or identifiable natural person (“Data Subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier.
- Personal Data Collected. When WCET contracts with third parties outside of the United States, Personal Data transferred to WCET with regard to these is governed by those agreements. However, WCET may obtain Personal Data directly from you by signing up for our newsletters, browsing our Sites, or registering for events, inquiring about membership, or by supplying personal data as part of your institutional/organizational membership.
- Consumer Rights. Data Subjects may have the following rights under the GDPR:
- Right of Access: You have the right to obtain confirmation from WCET as to whether or not we process Personal Data from you, and you also have the right to at any time obtain access to your Personal Data stored by WCET.
- Right to Rectification: If WCET processes your Personal Data, WCET uses reasonable measures to ensure that your Personal Data is accurate and up-to-date for the purposes for which your Personal Data was collected. If your Personal Data is inaccurate or incomplete, you have the right to require WCET to correct it.
- Right to Erasure: You may have the right to require WCET to delete your Personal Data.
- Right to Restrict Processing: You may have the right to request the restriction or suppression of Personal Data.
- Right to Withdraw Consent: If you have given your consent to the processing of your Personal Data, you have the right to withdraw your consent at any time, without affecting the lawfulness of processing based on the consent before the withdrawal.
- Right to Data Portability: You may have the right to receive the Personal Data concerning you and which you have provided to us, in a structured, commonly used and machine-readable format or to transmit this data to another controller.
- Right to Lodge a Complaint with Supervisory Authority: You have the right to lodge a complaint with a data protection supervisory authority located in the European Union or UK. Further information about how to contact your local data protection authority is available on the European Commission’s website.
If you would like to exercise any of these rights, please contact us as set forth in the Contact Us section below. WCET will process such requests in accordance with applicable law.
- Choices under GDPR. Data Subjects have the right to opt out of (a) disclosures of their Personal Data to third parties not identified at the time of collection or subsequently authorized, and (b) uses of Personal Data for purposes materially different from those disclosed at the time of collection or subsequently authorized. Data Subjects who wish to limit the use or disclosure of their Personal Data should please contact us as set forth in the Contact Us section below. We will cooperate with Data Subjects’ instructions regarding Data Subjects’ choices.
- Security Measures To Protect Your Personal Data. WCET uses industry standard data protection protocols to protect your data.
Canadian Members and Site Users
- Commercial Electronic Messages (“CEM”) in Canada. Canada’s Anti-Spam Law requires that the WCET obtain the express consent of Canadian citizens before sending an electronic message such as an email that contains a promotion about our products. We will ask you for your explicit consent when you provide us with your email address or other personal information through which we intend to encourage your participation in a commercial activity, such as a promotion for our products. If you explicitly consent to receiving CEM, each communication sent to you will contain an option to unsubscribe to the communications or to revoke your consent to receive CEM. Alternatively, you can contact us at the address or email provided in the “Contact and Electronic Communications” section to be removed from our mailing lists.
As a general rule, children are not allowed to use the Sites, and we do not collect personal information from them. We define “children” as anyone under 16 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.
How to Contact Us
Western Interstate Commission for Higher Education
Attn: Legal – Privacy
3035 Center Green Drive, Suite 200
Boulder, CO 80301