Summary

Updated: September, 2016

Summarized below are key elements of our Privacy Policy or read our full Privacy Policy (“Policy”).

Scope of Privacy Policy

This policy applies to website visitors, current and potential students, employees, suppliers, alumni, and any other user of services offered through our Sites, including any websites or mobile applications operated by or on our behalf.

This policy applies to both online and offline collection, storage, processing, and transfer of Personal Information. However, certain Sites or services may be subject to additional privacy policies or privacy disclosures relating to the services provided on the Site(s) (collectively “Additional Policies”).

Information Collected

We collect various types of Information through our Sites, and other websites where you can express interest in our services, through our mobile applications, over the phone, and in person where print materials may be used to collect Information from you. Some Information is collected automatically through various Web and Internet technologies, including Social Networking tools used by our Sites to foster communication and collaboration among members of our community. Other Information is collected when you provide it in response to a survey or a request for information; in connection with employment opportunities or other products and services; set up a Social Network or other Site profile; or use one of our career resources or other interactive tools. We may also obtain information from other sources and combine that with Information we collect about you.

Information Uses

We will not sell, rent, or lease your Personal Information to others except as provided in this policy. We may collect, use, and disclose Personal Information for the following purposes:

  • to provide requested information, products and services
  • to respond to your inquiries and provide support
  • for employment related purposes
  • for investor relations related purposes
  • for media related purposes
  • for supplier related purposes
  • for our internal marketing purposes, which includes, but is not limited to, sending you material about products, services, updates, etc. that we think may be of interest to you
  • for fostering communication and collaboration through Social Networks
  • for sharing with our Educational Partners who may contact you with respect to their educational or other services
  • for sharing with our Educational Partners or Business Associates who are performing services on our behalf
  • to analyze how Sites and services are being accessed and used
  • for investigation of information security and information asset protection related incidents
  • to test, correct and improve our content, applications and services
  • to develop new applications, products and services
  • to improve Site and service performance and delivery
  • to prevent potentially illegal activities (including illegal downloading of copyrighted materials in accordance with our Copyright Infringement policy)
  • to investigate suspicious information that denotes illegal activity
  • to analyze risk and business results
  • to maintain business records for reasonable periods
  • to enforce our Terms of Use
  • to provide to Educational Partners, Business Associates or Unrelated Entities in connection with the contemplated or actual reorganization, merger, acquisition, financing, securitization, insuring, sale or other disposal of all or part of our business or assets, including for the purposes of determining whether to proceed with such transaction or fulfilling any records or other reporting requirements to such parties. In the event of any actual reorganization, merger, or acquisition such Information may be transferred as part of the transaction to the acquirer
  • and/or as may be required or permitted by legal, regulatory, industry self-regulatory, insurance, audit, or security requirements applicable to Apollo Education Group, our Educational Partners, or our Business Associates.

Your Rights and Choices

Marketing Communications

If you do not wish to receive marketing email communications from us, you may express your choice where indicated on the applicable email or other communication, or email privacy@apollo.edu.

If you do not wish to receive marketing telephone calls or mailings, you may express your choice to opt-out by emailing privacy@apollo.edu..

Your California Privacy Rights

Under California’s Shine the Light law, Cal. Civ. Code § 1798.83, we provide California residents the ability to opt out of disclosures to Educational Partners for direct marketing purposes. To opt out of these disclosures at no cost, email privacy@apollo.edu.

Do Not Track

Apollo does not itself respond to web browser-based DNT signals.

Other Collection, Use, and Disclosure

You may be able to opt-out of our collection, use, and disclosure of your Personal Information in other situations subject to applicable contractual, educational, legal or technical restrictions and reasonable notice. Note that if you opt-out of certain uses of your Personal Information, we may no longer be able to provide certain products or services. For more information on your ability to opt-out, email privacy@apollo.edu.

Other Important Information

We will take commercially reasonable measures to secure and store your Information to protect against the loss, misuse, and alteration of the Information under our control. We utilize industry standard security measures when accepting your credit card Information during your registration or other transaction you have initiated with us, as well as whenever we ask you to login to any of our Sites.

Apollo Education Group, Inc. may update this policy or revise it from time to time. If you are concerned about how your Personal Information is used or disclosed, you should contact us as described below or check back at this Site periodically to obtain a current copy of this Privacy Policy.

How to Contact Us or Access Your Information

If you want access to or wish to update any of your Personal Information or have any questions about our privacy practices, please contact our Chief Ethics and Compliance Officer at privacy@apollo.edu or

Apollo Education Group, Inc.
Attn: Chief Ethics & Compliance Officer
4025 S. Riverpoint Parkway
Phoenix, AZ 85040 USA

Privacy Policy – Full Version

Updated: September, 2016

Scope

This policy applies to website visitors, current and potential students, alumni, and any other user of services offered through our Sites, including any websites or mobile applications operated by or on our behalf. This policy applies to both online and offline collection, storage, processing, and transfer of Personal Information.

Certain Sites or services may be subject to additional privacy policies or privacy disclosures relating to the services provided on the Site(s) (collectively “Additional Policies”). In the event of any direct conflict between any Additional Policies and this policy, the Additional Policies will control.

Apollo may amend or otherwise modify this Privacy Policy at any time, so please re-visit this page periodically to check for updates. The date of last revision is shown at the top of this document.

Contents

1. Definitions

As used in this Privacy Policy, the following terms have the following meanings:

"Business Associates" means third party service providers which Apollo Education Group, Inc. may contract with to provide services on its behalf including but not limited to, Social Networking, hosting, web analytics, lead generation, educational business, or career services.

“Do Not Track” or “DNT” means a browser based signal that, when set, signifies an Internet user’s desire not to be tracked online.

 “Educational Partners” means: a.) Apollo Education Group, Inc. and its subsidiaries and affiliates including educational companies or institutions that Apollo Education Group, Inc. or its subsidiaries may be providing educational or other related services to under contract; and b.) third party companies who may participate in Apollo Education Group, Inc.  career initiatives.

 “Information” means any Information collected and includes: “Personal Information”, “Web Analytical Information” or any other Information collected from you through our Sites.

“Personal Information” means Information that may be used, alone or in combination, to identify a specific individual.

"Site" or "Sites", means websites operated by or exclusively on behalf of Apollo Education Group, Inc., regardless of domain name or IP address.

“Social Network”, means various Internet communication technologies provided on Sites that facilitate conversation and interaction between people online and includes, but is not limited to, blogs, discussion forums, wikis, chat sessions, news groups, etc.

“Social Network Content” (or “SNC”) means user-generated content you consent to share via a Social Network and includes, but is not limited to, Personal Information, digital sounds, and pictures that you upload to a Social Network. It also includes your Personal Information that may be displayed on other users’ Social Network pages.

“We”, “us”, and “our” refer to Apollo Education Group, Inc.

“Unrelated Entities” means third parties that are not Educational Partners and who are not providing services as Business Associates.

“Web Analytical Information” means internet-generated Information we collect when you visit our Sites. This Information may be linked with Personal Information. When linked with other Information identifying you personally, either alone or in combination with other Information, then such Information also will be considered Personal Information.

2. How We Collect Information

We collect various types of Information from you through our Sites and other websites where you can express interest in our services, through our mobile applications, over the phone, via printed forms, and in person. Some Information is collected automatically through various web and internet technologies including Social Networking tools used by our Sites. Other Information is collected when you provide it to us voluntarily. We may also obtain information from Educational Partners and Unrelated Entities and combine that with information we collect about you. 

3. Information Collected Automatically on the Sites

Each time you visit one of our Sites, Web Analytical Information is automatically gathered. In general, this Information does not identify you personally. Examples of Web Analytical Information include, but are not limited to:

  • IP address
  • Collection Date
  • Publisher Name
  • Connection Speed
  • Day of Week Time of Day (hour)
  • Language settings
  • Country, State, Designated Market Area (DMA), City (relating to IP address, if available)
  • Domain (.com, .net, .mil, .org, .edu, etc.)

This Information may be linked with Personal Information to accomplish the purposes described in this Privacy Policy. 

4. Information You Provide to Us

In addition to the Web Analytical Information automatically collected when you visit our Sites, Apollo also collects, uses, and discloses Personal Information that you provide to us voluntarily online or offline when you respond to a survey or a request for information; in connection with employment opportunities or other products and services; set up a Social Network or other Site profile; or use one of our career resources or other interactive tools. While the exact nature of the Personal Information may vary depending on the type of response or service requested, the following is a non-exclusive list of the types of Information that may be collected to the extent it is necessary and applicable for the intended purposes:

  • First, Middle and Last Name, Previous Names
  • Street Address, City, State, Country, Postal Code
  • Date of Birth
  • Place of Birth
  • Gender
  • Race
  • Ethnicity
  • Country of origin
  • Employment History
  • Native Language
  • Address Type
  • E-mail address
  • Valid Day or Evening Telephone Number
  • Cell Phone Number
  • Confirmation of the age of majority
  • Citizenship
  • Prior Education History
  • Social Networking Content
  • Learning, Skill, or Career Assessment data
  • Job Title
  • Information related to Supplier opportunities
  • Social Security Number in connection with employment opportunities
  • Disability status in connection with employment opportunities
  • Veterans status in connection with employment opportunities 

5. How We Use and Disclose This Information

Personal Information

We will not sell, rent or lease your Personal Information to others except in accordance with this policy.

We may collect, use, and disclose Personal Information for the following purposes:

  • to provide requested information, products and services
  • to respond to your inquiries and provide support
  • for employment related purposes
  • for investor relations related purposes
  • for media related purposes
  • for supplier related purposes
  • for our internal marketing purposes, which includes, but is not limited to, sending you material about products, services, updates, etc. that we think may be of interest to you
  • for fostering communication and collaboration through Social Networks
  • for sharing with our Educational Partners who may contact you with respect to their educational or other services
  • for sharing with our Educational Partners or Business Associates who are performing services on our behalf
  • to analyze how Sites and services are being accessed and used
  • for investigation of information security and information asset protection related incidents
  • to test, correct and improve our content, applications and services
  • to develop new applications, products and services
  • to improve Site and service performance and delivery
  • to prevent potentially illegal activities (including illegal downloading of copyrighted materials in accordance with our Copyright Infringement policy)
  • to investigate suspicious information that denotes illegal activity
  • to analyze risk and business results
  • to maintain business records for reasonable periods
  • to enforce our Terms of Use
  • to provide to Educational Partners, Business Associates or Unrelated Entities in connection with the contemplated or actual reorganization, merger, acquisition, financing, securitization, insuring, sale or other disposal of all or part of our business or assets, including for the purposes of determining whether to proceed with such transaction or fulfilling any records or other reporting requirements to such parties. In the event of any actual reorganization, merger, or acquisition such Information may be transferred as part of the transaction to the acquirer
  • and/or as may be required or permitted by legal, regulatory, industry self-regulatory, insurance, audit, or security requirements applicable to Apollo Education Group, our Educational Partners, or our Business Associates. 

6. Location of Information Processing

We operate or may process information in multiple jurisdictions and some Educational Partners and Business Associates may be located outside of the jurisdiction in which you reside. In such cases, your Personal Information may be collected, used, disclosed, stored and processed in these other jurisdictions for the purposes described in this Privacy Policy. The data protection and other laws of the United States and other countries might differ from your jurisdiction. We require our Educational Partners and Business Associates to use your Personal Information in accordance with this policy and to take reasonable steps to ensure that your privacy is protected in accordance with applicable laws. Please be advised that, by using our Sites and services, you are consenting to the transfer and processing of your Information across international borders. Your Information may be subject to the laws of those other jurisdictions, including lawful requirements to disclose Personal Information to government authorities. 

7. Do Not Track

Do Not Track (DNT) is a browser based signal that, when set, signifies your desire not to be tracked online. Because there is not yet a consensus on how companies should respond to web browser-based or other DNT mechanisms, Apollo does not itself respond to web browser-based DNT signals. 

8. Opt-Out

Marketing Communications

If you do not wish to receive marketing email communications from us, you may express your choice where indicated on the applicable email or other communication, or email privacy@apollo.edu.

If you do not wish to receive marketing telephone calls or mailings, you may express your choice to opt-out by emailing privacy@apollo.edu.

Marketing opt-out requests will only remove you from our list and the list of any Business Associate performing services on our behalf. We are not responsible for the use any other party may make of the Information once it has been transferred in accordance with this Policy and you will need to contact such entity to have your Information removed from their database.

Social Networking Content

You may change various user settings related to sharing your Personal Information contained in any user profile you set up as part of Social Network activities furnished by us, subject to contractual, educational, legal or technical restrictions and reasonable notice. Note that your withdrawal from Social Network activities might prevent us from providing you with certain products or services.

Other Collection, Use, and Disclosure

You may be able to opt-out of our collection, use and disclosure of your Personal Information subject to applicable contractual, educational, legal or technical restrictions and reasonable notice. Note that if you opt-out of certain uses of your Personal Information, we may no longer be able to provide certain products or services. For more information on your ability to opt-out, email privacy@apollo.edu

9. Your California Privacy Rights

Under California’s Shine the Light law, Cal. Civ. Code § 1798.83, we provide California residents the ability to opt out of disclosures to Educational Partners for direct marketing purposes. To opt out of these disclosures at no cost, email privacy@apollo.edu

10. Our Security Measures

We will take commercially reasonable measures to secure and store your Information to protect against the loss, misuse, and alteration of the Information under our control. We utilize industry standard security measures when accepting your credit card Information during the online ordering process, as well as whenever we ask you to login to any of our Sites.

Unfortunately, no data transmission over the internet can be guaranteed to be completely secure. As a result, although we will utilize such measures, we do not guarantee you against the loss, misuse, or alteration of Information under our control, and you provide Information to us at your own risk. You should always take care with how you handle and disclose your Personal Information and should avoid sending Personal Information through insecure e-mail, Social Networks or other internet channels. 

11. Monitoring of Communications

We may monitor and retain all incoming and outgoing communications for training of our representatives and for quality assurance purposes. To the extent such communications are selected, they are only retained as long as necessary to adequately discharge these purposes, unless a specific communication needs to be retained for legal reasons. If you prefer that your communications not be retained for any reason, please advise your representative. 

12. Internet Technologies Used

Cookies, web beacons, and other relevant internet technologies are used on our Sites to allow us to accomplish the uses set out above as well as to deliver Sites messaging and to keep track of your Information. These small pieces of program code reside in your computer and browser and can be removed. If you desire to remove such technologies you may do so, but this may render our Sites unusable to you. You can opt out of cookies or the other internet technologies used by disabling these features in your browser program. Consult your browser’s “Help” menu for assistance in changing cookie settings or removing cookie files. 

13. Site Hosting and Links from Our Sites to Other Websites

Some of our Sites may contain links to websites hosted by Educational Partners, Unrelated Entities, and Business Associates operating websites on their own behalf or on behalf of multiple entities. Some of these websites may collect your Personal Information and may apply their own policies on how your Personal Information is used. In addition, some of our Sites may have Additional Policies that apply to the use of Personal Information collected on that Site. Please make sure to read the policies of any websites you visit on the internet carefully. Please be aware that we are not responsible for the privacy practices or the content of any websites that are not operated by or exclusively for us, and the collection, use, and disclosure of Information about you will be subject to the policies applicable on those websites. 

14. Privacy Shield

EU-U.S. PRIVACY SHIELD FRAMEWORK
Apollo Education Group, Inc., Apollo Global, Inc., and their affiliates in the United States (individually and collectively, the "Company") participates in the EU-U.S. Privacy Shield Framework (the "Framework"). Company's participation in the Framework applies to personal data received in the United States from the European Union ("EU") about employees ("EU Employee Data"), students ("EU Student Data"), clients ("EU Client Data") and suppliers ("EU Supplier Data") (collectively, "EU Personal Data"). In addition to having implemented Standard Contractual Clauses for the transfer of certain EU Personal Data, we are committed to subjecting such EU Personal Data to the Framework to the extent that we have received it in reliance on the Framework, including its Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. To learn more about the Framework, visit the U.S. Department of Commerce's Privacy Shield List.

EU Personal Data Collection, Use, and Disclosure
EU Employee Data: The Company provides to EU employees a notice about the collection, use, and disclosure of their EU Employee Data through internal company policies.

EU Student and Prospective Student Data: The Company collects and processes the following categories of EU Student and Prospective Student Data: name, email address, student number, national ID number (where permitted by applicable law), city, telephone number, financial account information, network usage information, educational information (classes, grades, schedule, academic record). The Company will use and otherwise process EU Student and Prospective Data in the United States for the following purposes: educational related activities, finance and accounting related activities, technical support, and disaster recovery. The Company transfers EU Student and Prospective Student Data to the following types of third parties: student management system provider; IT helpdesk and support provider; backup storage provider.

EU Client and Prospective Client Data: The Company collects and processes the following categories of EU Client and Prospective Client Data: name, email address, client number, national ID number (where permitted by applicable law), city, telephone number, financial account information, network usage information, educational information (classes, schedule, educational record). The Company will use and otherwise process EU Client and Prospective Client Data in the United States for the following purposes: educational related activities, finance and accounting related activities, legal compliance activities, contracting, sales, technical support, and disaster recovery. The Company transfers EU Client and Prospective Client Data to the following types of third parties: client management system provider; IT helpdesk and support provider; backup storage provider.

EU Supplier Data: The Company collects and processes the following categories of EU Supplier Data: name, email address, mailing address, telephone number, financial account information. The Company will use and otherwise process EU Supplier Data in the United States for the following purposes: finance and accounting related activities, legal compliance activities, contracting, sales, project management, technical support, and disaster recovery. The Company transfers EU Supplier Data to the following types of third parties: supplier management system provider; IT helpdesk and support provider; backup storage provider.

Rights of EU Data Subjects
If you are an EU data subject, you have the right to access your own EU Personal Data subject to certain limitations, such as where the legitimate rights of other persons would be infringed or where the burden or expense of providing access would be disproportionate. If you wish to exercise such rights, please contact us as described below.

Choices of EU Data Subjects
Students and clients have the right to exercise choice (opt-out) from our use of their EU Student Data or EU Client Data for direct marketing purposes. To exercise this right, please email privacy@apollo.edu or follow the instructions in any direct marketing message you may have received. We do not otherwise use or disclose EU Student Data and EU Client Data in a manner that is subject to choice requirements under the Framework. We describe the choices for EU Employee Data through internal company policies.

Recourse, Enforcement, and Liability
Please contact us as specified below if you have any questions, need access to your EU Personal Data, or otherwise need assistance. We remain responsible for our collection, use and disclosure of EU Personal Data in accordance with the Framework. We also are responsible for third party agents that are processing such data on our behalf, unless we prove that we are not responsible for the event giving rise to the damage. In certain situations, we may be required to disclose EU Personal Data in response to lawful requests by public authorities, including meeting national security or law enforcement requirements.

If you have an unresolved concern about EU Personal Data that we have not addressed satisfactorily, we have committed to cooperate with the panel established by the EU Data Protection Authorities to serve as our independent dispute resolution body for the Framework. We are also subject to the investigatory and enforcement powers of the Federal Trade Commission with respect to the Framework. In addition, under certain conditions, more fully described on the Privacy Shield website, EU residents may invoke binding arbitration for non-monetary issues when other dispute resolution procedures have been exhausted.

Contact Us

Please contact us at privacy@apollo.edu if you have any questions, wish to exercise your rights of access, or seek other assistance as described above.  

 

15. Privacy Policy Changes

Apollo Education Group may update this Privacy Policy or revise it from time to time. You should contact us as described below or check back at this Site periodically to obtain a current copy of this Privacy Policy. We urge you to review this Privacy Policy frequently to obtain the current version. Your continued provision of Personal Information or use of our services following any changes to this Privacy Policy constitutes your acceptance of such changes. If we intend to use Information that personally identifies you in a manner materially different from what we stated at the time it was collected, we will attempt to notify you at least 30 days in advance. You will be given a choice as to whether or not previously provided Information may be used in a new way. 

16. How to Access Your Information and Contact Us

If you want access to or wish to update any of your Personal Information or have any questions about our privacy practices, please contact our Chief Ethics and Compliance Officer at privacy@apollo.edu or

Apollo Education Group, Inc.
Attn: Chief Ethics & Compliance Officer
4025 S. Riverpoint Parkway
Phoenix, AZ 85040 USA