Legal

Privacy Policy

LAST UPDATED:  June 2023

The University of St. Augustine for Health Sciences (“USAHS”) wants you to be familiar with how we collect, use and disclose information. This Privacy Policy describes our practices in connection with information that we collect through websites operated by us (the “Websites”), through the software applications made available by us (unless subject to a privacy policy specific to the app) (the “Apps”), through our social media pages (our “Social Media Pages”), through HTML-formatted email messages, and through short message service (“SMS”) that we send to you that link to this Privacy Policy, as well as offline interactions you may have with us (collectively, including the Websites, the Apps, our Social Media Pages, SMS, and offline activity, the “Services”). USAHS may also collect information during the employee application and employment process.

Personal Information

“Personal Information” is information that identifies you as an individual or relates to an identifiable individual, such as:

  • Name
  • Postal address
  • Email address
  • Telephone number
  • Educational records
  • Work history
  • Emergency contact details
  • Demographic data, including, where relevant, racial and ethnic origin, health and disability information
  • National and student ID numbers, such as a social security or tax ID
  • Dependent’s or other individual’s information
  • Health and Safety Information
  • Membership in professional or industry associations
  • Credit and debit card number
  • Bank account details
  • Profile picture
  • Social media account ID

Collection of Personal Information

We and our service providers collect Personal Information in a variety of ways, including:

  • Directly through you

–We may collect personal information directly from you. For example, the forms you complete through USAHS or a third-party service provider regarding your employment or application.

  • Through the Services

–We collect Personal Information through the Services, for example, when you visit one of our sites, apply for admission, or maintain an ongoing relationship with us as a student.

–From you during your course of study or period of enrollment with us.

  • Offline

–We collect Personal Information from you offline, such as when you complete an application for admission, fill out a form at an education or career fair, apply for a student ID card,
participate in a promotion, or contact our call center.

  • From Other Sources

–We receive your Personal Information from other sources, for example:

  • our affiliates, partners and services providers, including, but not limited to the Common Application System (CAS);
  • private and publicly available databases;
  • application references and/or recommendation writers; and
  • other educational institutions.

–If you connect your social media account to your Services account, you will share certain Personal Information from your social media account with us, for example, your name, email address, photo, list of social media contacts, and any other information that may be or you make accessible to us when you connect your social media account to your Services account.

We need to collect Personal Information in order to provide the requested Services to you and in order to consider and maintain an educational relationship with you.  If you do not provide the information requested, we may not be able to provide the Services, consider you for admission, or maintain your status as an enrolled student.  If you disclose any Personal Information relating to other people to us or to our service providers in connection with the Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

Use of Personal Information

We, our affiliates and our service providers use Personal Information for legitimate business purposes including:

  • Providing the functionality of the Services and fulfilling your requests.

–To provide the Services’ functionality to you, such as arranging access to your registered account and providing you with related assistance.

–To respond to your inquiries and fulfill your requests, when you contact us via one of our online contact forms or otherwise, for example, when you send us questions, suggestions, or complaints.

–To complete your transactions and provide you with related assistance.

–To send administrative information to you, such as changes to our terms, conditions and policies.

–To allow you to send messages to another person if you choose to do so.

We will engage in these activities to manage our contractual relationship with you and/or to comply with a legal obligation.

  • Providing you with our newsletter and/or other marketing materials and facilitating social sharing

–To send you marketing related emails, with information about our services and other news about us.

–To facilitate social sharing functionality that you choose to use.

We will engage in this activity with your consent or where we have a legitimate interest.

  • Analysis of Personal Information for business reporting and providing personalized services.

–To analyze or predict our users’ preferences in order to prepare aggregated trend reports on how our digital content is used, so we can improve our Services.

–To better understand you, so that we can personalize our interactions with you and provide you with information and/or offers tailored to your interests.

–To better understand your preferences so that we can deliver content via our Services that we believe will be relevant and interesting to you.

We will provide personalized services either with your consent or because we have a legitimate interest.

  • Allowing you to participate in sweepstakes, contests or other promotions.

–We may offer you the opportunity to participate in a sweepstakes, contest or other promotion.

–Some of these promotions have additional rules containing information about how we will use and disclose your Personal Information.

We use this information to manage our contractual relationship with you.

  • Aggregating and/or anonymizing Personal Information.

–We may aggregate and/or anonymize Personal Information so that it will no longer be considered Personal Information. We do so to generate other data for our use, which we may use and disclose for any purpose.

  • Accomplishing our business purposes.

–For data analysis, for example, to improve the efficiency of our Services;

–For audits, to verify that our internal processes function as intended and are compliant with legal, regulatory or contractual requirements;

–For fraud and security monitoring purposes, for example, to detect and prevent cyberattacks or attempts to commit identity theft;

–For developing new services;

–For enhancing, improving, or modifying our current services;

–For identifying usage trends, for example, understanding which parts of our Services are of most interest to users;

–For determining the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users;

–For operating and expanding our business activities, for example, understanding which parts of our Services are of most interest to our users so we can focus our energies on meeting our users’ interests;

–For recruiting and evaluating job applicants and candidates for employment;

–For conducting background checks.; and

–For managing your employment relationship with USAHS, including onboarding, payroll, benefits administration and other human resource purposes.

We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or because we have a legitimate interest.

Disclosure of Personal Information  

We disclose Personal Information:

  • To our third-party service providers, to facilitate services they provide to us.

–These can include providers of USAHS services such as website hosting, data analysis, payment processing, order fulfillment, information technology and related infrastructure provision, customer service, email delivery, auditing, and other services.

  • To third parties, to permit them to send you USAHS marketing communications, consistent with your communication preferences.
  • By using the Services, you may elect to disclose Personal Information

–On message boards, classroom discussion forums, chat, profile pages, blogs and other services to which you are able to post information and content (including, without limitation, our Social Media Pages). Please note that any information you post or disclose through these services will become public and may be available to other users and the general public.

–Through your social sharing activity. When you connect your Services account with your social media account, you will share information with your friends associated with your social media account, with other users, and with your social media account provider. By doing so, you authorize us to facilitate this sharing of information, and you understand that the use of shared information will be governed by the social media provider’s privacy policy.

No mobile information will be shared with third party affiliates for their own direct marketing/ promotional purposes. This information will not be shared with any third parties for their own use.

 

Other Uses and Disclosures

We also use and disclose your Personal Information as necessary or appropriate, especially when we have a legal obligation or legitimate interest to do so:

  • To comply with applicable

–This can include laws outside your country of residence.

  • To respond to requests from public and government authorities.

–These can include authorities outside your country of residence.

  • To cooperate with law enforcement.

–For example, when we respond to law enforcement requests and orders.

  • For other legal reasons.

–To enforce our terms and conditions; and

–To protect our rights, privacy, safety or property, and/or that of our affiliates, you or others.

  • In connection with a sale or business transaction.

–We have a legitimate interest in disclosing or transferring your Personal Information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings). Such third parties may include, for example, an acquiring entity and its advisors.

OTHER Information

“Other Information” is any information that does not reveal your specific identity or does not directly relate to an identifiable individual

  • Browser and device information
  • App and/or Website usage data
  • Information collected through cookies, pixel tags and other technologies
  • Demographic information and other information provided by you that does not reveal your specific identity, such as your gender or date of birth
  • Information that has been aggregated in a manner such that it no longer reveals your specific identity

If we are required to treat Other Information as Personal Information under applicable law, then we may use and disclose it for the purposes for which we use and disclose Personal Information as detailed in this Policy.

Collection of Other Information

We and our service providers collect Other Information in a variety of ways, including:

  • Through your browser or device
    • Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version and the name and version of the Services (such as the App) you are using. We use this information to ensure that the Services function properly.
  • Through your use of the Apps
    • When you download or use the Apps, we and our service providers may track and collect App usage data, such as the date and time the App on your device accesses our servers and what information and files have been downloaded to the App based on your device number.
  • Using cookies
    • Cookies are pieces of information stored directly on the computer that you are using. Cookies allow us to collect information such as browser type, time spent on the Services, pages visited, language preferences, and other traffic data.  We and our service providers use the information for security purposes, to facilitate navigation, to display information more effectively, and to personalize your experience.  We also gather statistical information about use of the Services in order to continually improve their design and functionality, understand how they are used and assist us with resolving questions regarding them.  Cookies further allow us to select which of our advertisements or offers are most likely to appeal to you and display them while you are on the Services.  We may also use cookies or other technologies in online advertising to track responses to our ads.  We do not currently respond to browser do-not-track signals.  If you do not want information collected through the use of cookies, most browsers allow you to automatically decline cookies or be given the choice of declining or accepting a particular cookie (or cookies) from a particular website.  You may also wish to refer to http://www.allaboutcookies.org/manage-cookies/index.html. If, however, you do not accept cookies, you may experience some inconvenience in your use of the Services.  You also may not receive advertising or other offers from us that are relevant to your interests and needs.
  • Using pixel tags and other similar technologies
    • Pixel tags (also known as web beacons and clear GIFs) may be used to, among other things, track the actions of users of the Services (including email recipients), measure the success of our marketing campaigns, and compile statistics about usage of the Services and response rates.
    • Analytics. This website uses Google® Analytics Premium, a web analytics service provided by Google Ireland Limited (“Google”). Google Analytics Premium uses “cookies”, which are text files placed on your computer, to help the website analyze how users use the site. The information generated by the cookies about your use of the website and your current IP-address will be transmitted by your browser to and will be stored by Google on servers in the United States and other countries. On behalf of the operator of this website Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity and providing other services relating to website activity and internet usage to the website operator. The IP address collected through Google Analytics will not be associated with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however, please note that if you do this you may not be able to use the full functionality of this website. You may also stop the transmission of information generated by the cookies about your use of the website and of your IP address to Google, by downloading and installing the Google Analytics Opt-out Browser Add-on.
  • IP Address
    • Your IP address is automatically assigned to your computer by your Internet Service Provider. An IP address may be identified and logged automatically in our server log files whenever a user accesses the Services, along with the time of the visit and the page(s) that were visited.  Collecting IP addresses is standard practice and is done automatically by many websites, applications and other services.  We use IP addresses for purposes such as calculating usage levels, diagnosing server problems and administering the Services.  We may also derive your approximate location from your IP address.
  • Physical Location
    • We may collect the physical location of your device by, for example, using satellite, cell phone tower or Wi-Fi signals. We may use your device’s physical location to provide you with personalized location-based services and content.  We may also share your device’s physical location, combined with information about what advertisements you viewed and other information we collect, with our marketing partners to enable them to provide you with more personalized content and to study the effectiveness of advertising campaigns.  In some instances, you may be permitted to allow or deny such uses and/or sharing of your device’s location, but if you do, we and/or our marketing partners may not be able to provide you with the applicable personalized services and content.

Uses and Disclosures of Other Information

We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law.  In some instances, we may combine Other Information with Personal Information.  If we do, we will treat the combined information as Personal Information as long as it is combined.

Security

We seek to use reasonable organizational, technical and administrative measures to protect your Personal Information from accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure.  If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contacting Us” section below.

CHOICES AND ACCESS

Your choices regarding our use and disclosure of your Personal Information

We give you choices regarding our use and disclosure of your Personal Information for marketing purposes.  You may opt-out from:

  • Receiving email marketing from us:  If you no longer want to receive marketing-related emails from us on a going-forward basis, you may unsubscribe at any time; however, we may continue to send you transactional or relationship messages, such as press releases, newsletters, or account information
  • Receiving other types of marketing communications from us:  If you no longer want to receive marketing-related communications from us on a going-forward basis, you may unsubscribe at any time; however, we may continue to send you transactional or relationship messages, such as press releases, newsletters, or account information
  • Our sharing of your Personal Information with affiliates for their direct marketing purposes:  If you would prefer that we discontinue sharing your Personal Information on a going-forward basis with our affiliates for their direct marketing purposes, you may unsubscribe at any time; however, we may continue to send you transactional or relationship messages, such as press releases, newsletters, or account information
  • Our sharing of your Personal Information with unaffiliated third parties for their direct marketing purposes:  If you would prefer that we discontinue sharing your Personal Information on a going-forward basis with unaffiliated third parties for their direct marketing purposes, you may unsubscribe at any time; however, we may continue to send you transactional or relationship messages, such as press releases, newsletters, or account information.

We will try to comply with your request(s) as soon as reasonably practicable.  Please note that if you opt-out of receiving marketing-related communications from us, we may still send you important administrative messages, from which you cannot opt-out.

How you can access, change or delete your Personal Information 

If you would like to request to review, correct, update, suppress, restrict or delete Personal Information that you have previously provided to us, or if you would like to request to receive an electronic copy of your Personal Information for purposes of transmitting it to another organization (to the extent this right to data portability is provided to you by applicable law), you may contact us using the “Contact Us” information below.  We will respond to your request consistent with applicable law.

In your request, please make clear what Personal Information you would like to have changed, whether you would like to have your Personal Information suppressed from our database or otherwise let us know what limitations you would like to put on our use of your Personal Information.  For your protection, we will only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request.  We will try to comply with your request as soon as reasonably practicable.

Please note that we need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion (e.g., when you make a payment, you may not be able to change or delete the Personal Information provided until after the completion of such transaction).

If you are a resident of California, under 18 and a registered user of the Services, you may ask us to remove content or information that you have posted to the Services by writing to us at the Contact Us address below.  Please note that your request does not ensure complete or comprehensive removal of the content or information, as, for example, some of your content may have been reposted by another user.

RETENTION PERIOD

Except as otherwise permitted or required by law, we retain your personal data for as long as necessary to fulfill the purposes they were collected for and in accordance with document retention schedules approved by USAHS. Schedules are based on the content itself and where it resides.

The criteria used to determine our retention periods includes:

  • The length of time we have an ongoing relationship with you and provide the Services to you (for example, for as long as you are a student or employee of ours);
  • Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
  • Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

THIRD PARTY SERVICES

This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any website or service to which the Services link.  The inclusion of a link on the Services does not imply endorsement of the linked site or service by us or by our affiliates.

In addition, we are not responsible for the information collection, use, disclosure or security policies or practices of other organizations, such as Facebook, Apple, Google, Microsoft, RIM or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including with respect to any Personal Information you disclose to other organizations through or in connection with the Apps or our Social Media Pages.

THIRD PARTY ADVERTISING  

We use third-party advertising companies to serve advertisements regarding goods and services that may be of interest to you when you access and use the Services and other websites or online services.

  • You may receive advertisements based on information relating to your access to and use of the Services and other websites or online services on any of your devices, as well as on information received from third parties. These companies place or recognize a unique cookie on your browser (including through the use of pixel tags).  They also use these technologies, along with information they collect about your online use, to recognize you across the devices you use, such as a mobile phone and a laptop.  If you would like more information about this practice, and to learn how to opt out of it in desktop and mobile browsers on the particular device on which you are accessing this Privacy Policy, please visit:

If you are in the U.S., you may download the AppChoices app at www.aboutads.info/appchoices to opt out in mobile apps.

Use of Services by Minors

The Services are not directed to individuals under the age of sixteen (16), and we do not knowingly collect Personal Information from individuals under sixteen (16).

Jurisdiction and CROSS-BORDER TRANSFER

Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services you understand that your information will be transferred to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country.  In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Information.

If you are located in the European Economic Area (“EEA”): Some of the non-EEA countries are recognized by the European Commission as providing an adequate level of data protection according to EEA standards (the full list of these countries is available here). For transfers from the EEA to countries not considered adequate by the European Commission, we have put in place adequate measures, such as standard contractual clauses adopted by the European Commission to protect your Personal Information.  You may obtain a copy of these measures by following this link.

THIRD PARTY PAYMENT SERVICE

We will use a third-party payment service to process payments made through the Services. If you wish to make a payment through the Services, your Personal Information will be collected by such third party and not by us and will be subject to the third party’s privacy policy, rather than this Privacy Policy.  We have no control over, and are not responsible for, this third party’s collection, use and disclosure of your Personal Information.

UPDATES TO THIS PRIVACY POLICY

The “Last Updated” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised.  Any changes will become effective when we post the revised Privacy Policy on the Services.  Your use of the Services following these changes means that you accept the revised Privacy Policy.

CONTACTING US

The University of St. Augustine for Health Sciences, LLC, 700 Windy Point Dr., San Marcos, CA  92069, is the company responsible for collection, use and disclosure of your Personal Information under this Privacy Policy.

If you have any questions about this Privacy Policy, please contact us at [email protected]or at the postal address above.  Because email communications are not always secure, please do not send sensitive information in your emails to us.

ADDITIONAL INFORMATION FOR INDIVIDUALS IN THE EEA

If you are located in the EEA, you also may lodge a complaint with a data protection authority for your country or region or where an alleged infringement of applicable data protection law occurs.

PRIVACY NOTICE FOR CALIFORNIA RESIDENTS

This section applies solely to the personal data of users who reside in the State of California and supplements the information contained in the USAHS Privacy Policy. We have included this section to comply with the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CRPA) any terms defined in the CCPA or CRPA have the same meaning when used in this notice. Please note that the University of St. Augustine for Health Sciences has not sold any personal information in the past 12 months.

In addition to the definition of personal information described in this policy and the uses of information described above, please find more detailed information on the records, purpose of collection and retention of personal information here: California Consumer Privacy Act Applicant Notice June 2023 and California Consumer Privacy Act Employee Notice June 2023.

Your Rights and Choices: The CCPA and CPRA provides consumers, and employees with specific rights regarding their personal information. This section describes your rights and explains how to exercise those rights.

  • Access to Specific Information and Data Portability Rights. You have the right to request that University of St. Augustine for Health Sciences disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable request, we will disclose to you: (i) the categories of personal information we collected about you; (ii) the categories of sources for the personal information we collected about you; (iii) our business or commercial purpose for collecting or selling that personal information; (iv) the categories of third parties with whom we share that personal information, if any; (v) the specific pieces of personal information we collected about you (also called a data portability request); (vi) if we sold or disclosed your personal information for a business purpose, two separate lists disclosing: (a) sales, identifying the personal information categories that each category of recipient purchased; and (b) disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
  • Deletion Request Rights. You have the right to request that University of St. Augustine for Health Sciences delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct all appropriate service providers to delete) your personal information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to: (i) complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you; (ii) detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities; (iii) debug products to identify and repair errors that impair existing intended functionality; (iv) exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law; (v) comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.); (vi) engage in public or peer-reviewed research in accordance with Section 1798.105 (d)(6) of the CCPA; (vii) enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us; (viii) comply with a legal obligation; or (ix) make other internal and lawful uses of that information that are compatible with the context in which you provided it.
  • Correction of Personal Information. You have the right to request us to correct any inaccurate personal information about you. If any personal information requires correction, we will use commercially reasonable efforts to fulfill your correction request.
  • Exercising Access, Data Portability, and Deletion Rights. To exercise the access, data portability, and deletion rights described above, please submit a verifiable request to us by email:  [email protected]

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable request related to your personal information.

You may only make a verifiable request for access or data portability twice within a 12-month period. The verifiable request must: (i) provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative; and (ii) describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

  • Response Timing and Format. We endeavor to respond to a verifiable request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination. We will not discriminate against you for exercising any of your rights. Unless permitted by the CCPA, as amended by the CPRA, we will not: (i) deny you goods or services; (ii) charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties; (iii) provide you a different level or quality of goods or services; (iv) suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services. However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

Changes to Our Privacy Notice. We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the website and update the notice’s effective date.

Contact Information: If you have any questions or comments about this notice, the ways in which USAHS collects and uses your information described in this section, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Email: [email protected]
Postal Address:
University of St. Augustine for Health Sciences
700 Windy Point Drive
San Marcos, CA 92069
Attn: Compliance