Please read through this Policy in its entirety and understand its terms. We may update the Policy from time to time, so please check it regularly.
This Policy describes:
- Personal Information We Collect;
- How We Collect Your Personal Information;
- How We Use Your Personal Information;
- How We Share Your Personal Information With Third Parties;
- How We Protect Your Personal Information;
- How To Make Changes To Your Information;
- How Long We Retain Your Personal Information
- Other Information;
- Changes to the Policy;
- Questions About This Policy; and
- Privacy Information For California Residents
PERSONAL INFORMATION WE COLLECT
Information You Provide to Us
We may collect, use, store and transfer different kinds of Personal Information about you, which we have grouped together as follows:
- Identifiers such as your first name, last name, video (in recorded classes) and online identifiers (cookies, mobile advertising IDs, Device IDs).
- Contact Information such as your mailing address, email address, and telephone numbers.
- Demographic Information such as age and gender.
- Financial Information such as credit or debit card information, payment details, payment information and information on Federal Student Aid forms.
- Sensitive Information such as geolocation data, social security number, Financial Information.
- Profile Data such as date of birth, account number, education, occupation and professional background, certifications, school name, year in school.
- Technical Information such as your hardware model, internet protocol (IP) address, other unique identifiers, operating system version, browser type and settings, and the settings of the device you use to access a Service.
- Usage Data such as information about the Services you use, the date and time, the duration of your usage, the files downloaded or viewed, and other information about your interaction with content offered through a Service.
- Communications Information such as your communication preferences.
- Inference Data including inferences drawn from the Personal Information identified above.
HOW WE COLLECT YOUR PERSONAL INFORMATION
Information We Collect From You
Information You Voluntarily Provide. We may collect Personal Information from you that you voluntarily provide to us in various ways, including but not limited to when you:
- Call, email, or otherwise communicate with us
- Fill out an application or lead card
- Otherwise interact with our websites or use our Services
- Engage with the Career Center Network
- Create Your Profile
You may have the opportunity to create a profile, which consists of information about you ("Profile"). Some of the information in your Profile may be visible to third parties or to everyone. FIDM may also make the information contained in your Profile accessible through means other than the Services (such as through an app or an application programming interface (API)).
Note that in order to provide services and opportunities to you, educational organizations, scholarship providers and other third parties may (to the extent permissible by law) be able to review certain information in your Profile for some of the Services, whether or not you have limited public access to that information. You may have the opportunity to control whether this information is shared, but some information may be shared automatically – all as disclosed on the website or other service where you created your Profile. FIDM does not share your contact information (email, full postal address or phone number) with those third parties unless you request or agree to that sharing.
Participate in our Clubs or Community Forums: The Services may provide you the opportunity to participate and post content publicly in forums, through interactive features and through other communication functionality ("Community Forums"). You may choose, through such features or otherwise, to submit or post reviews, suggestions, ideas, questions, answers, comments, testimonials, feedback, messages, images, videos, text or other material ("User Content"). Your User Content may also be posted in your Profile. You may edit or remove your Profile information, but you may not be able to remove answers or postings or other uploaded User Content on some Services. To request removal of content you posted publicly on the Services, contact us via email by clicking here. We will honor removal requests received from registered users under the age of 18 or not yet enrolled in FIDM or where required by law. Other removal requests received, may, in our sole discretion, be honored or refused (except that all such requests will be considered in the context of all applicable laws and regulations). In some cases, we may remove only your Personal Information but maintain the rest of your User Content. Note that removal of public postings does not ensure complete or comprehensive removal of the content or information posted.
In addition, the Services may allow members to communicate and collaborate with each other, including some Services that allow members to engage in one-on-one communication using a video chat or text chat feature. If you create an account, participate in a Community Forum or choose to communicate with others through the Services, certain information about you may be disclosed in connection with your or others' use of the Services, including certain information about you and your network (such as your name and profile photo, the number of your connections, and the names and pictures of your connections). Our servers may record, and we may retain, records of the content of any such user-to-user communications.
Information We Collect Automatically.
Automated technologies or interactions. As is true of most websites, we receive and store certain types of Personal Information whenever you interact with us or our Services. This information may include Technical and Usage Data.
Usage Information may include the browser and operating system you are using, the URL or advertisement that referred you to our Services (if applicable), the search terms you entered into a search engine that lead you to our Services (if applicable), all of the areas within our Services that you visit (including information about any ads you may view), and the time of day you used the Services, among other information.
We automatically collect your IP address or other unique identifier ("Device Identifier") for any computer, mobile phone or other device (any, a "Device") you may use to access the Services. A Device Identifier is a number that is automatically assigned to your Device used to access a Service, and our servers identify your Device by its Device Identifier. Some mobile service providers may also provide us or our third party service providers with information regarding the physical location of the Device used to access a Service, internet service provider (ISP), date and time of your visit, browser language, browser type, referring and exit pages and URLs, amount of time spent on particular pages, which parts of our Services you use, which links you click, search terms, operating system, traffic and related statistics, keywords, and/or other general browsing or usage data. Usage Information is generally non-identifying, but if we associate it with you as a specific and identifiable person, we treat it as Personal Information.
Usage Information collected via tracking technologies includes:
- Cookies: A cookie is a text file that is placed on your hard disk by a web page server to help identify the user’s computer and can be used to help FIDM recall your information on subsequent website visits. Cookies help our systems recognize you if you return to our Services shortly after exiting them. In order to use certain secure areas of the site, cookies must be enabled. If you have a question about how to enable “cookie” settings please visit www.enablecookies.info. If you turn off your cookies, some of the features of the website may not function properly. You can manage your cookie preferences through your Internet browser. Modern browsers allow you to change your cookie settings. These settings are usually found in the “options” or “preferences” menu of your browser. You can find out more about cookies, including how to see what cookies have been set and how to manage and delete them, at http://www.allaboutcookies.org.
- Web Beacons: We, as well as our Affiliated Entities, service providers, and other third parties, may employ a software technology called clear gifs (a.k.a. web beacons/web bugs), that help us better manage content on our Services by informing us of what content is effective. Clear gifs are used to track the online movements of web users for our affiliate program and to help improve the overall quality and experience of our Services. We tie the information gathered by clear gifs to our customers' Personal Information.
- An Embedded Script: Is programming code that is designed to collect information about your interactions with the Services, such as the links you click on. The code is temporarily downloaded onto your computer or other device from our server or a third-party service provider and is deactivated or deleted when you disconnect from the Services.
- HTML5: We use Local Storage Objects (LSOs) such as HTML5 to store content, information and preferences. Third parties with whom we partner to provide certain features on our site or to display advertising based upon your Web browsing activity use LSOs such as HTML 5 to collect and store information. Various browsers may offer their own management tools for removing HTML5 LSOs.
In addition, we may use a variety of other technologies that collect similar information for security and fraud detection purposes.
Google Analytics. We use third party cookies provided by Google Analytics to assist us in better understanding our visitors. These cookies collect Technical Information such as IP address and Usage or Click Stream Data, such as the length of time a user spends on a page, the pages a user visits, and the websites a user visits before and after visiting our Services. Based on this information, Google Analytics compiles data about website traffic and interactions, which we use to offer better user experiences and tools in the future. For information on how to opt-out from Google Analytics, click here.
Access of FIDM’s Services through a Mobile Device. If you use the Services through a mobile device or one of our mobile applications, your mobile Device Identifier your mobile carrier, and your physical location may be transmitted to FIDM. You agree that FIDM may store and use that information for security purposes (for example, for user verification or authentication and to ensure that our APIs are being used appropriately). If you wish to no longer allow FIDM to track your physical locations you may turn this off within your device settings. You may be able to opt-in to receiving text messages from FIDM. You may always opt-out by replying "STOP" to one of the text messages received. You also acknowledge and agree that use of the Services through a mobile device may cause data to be displayed on and through your mobile device which may be viewed by your mobile carrier or other access provider. We will send you push notifications if you agree to receive them. You may opt-out of receiving these at any time by going to the phone settings and turning them off.
Information We Collect From Third Parties
We may collect Personal Information from various third parties, including those listed below. We do not control third-party websites and are not responsible for any information they may collect. The collection, use, and disclosure of Personal Information received from third parties is governed by the privacy policies listed on the website where the information was collected by the third party and/or submitted by the user. For example, if you are on a third-party web site, and you opt-in to receive information from us, that third party will forward information about you to us so that we may contact you as requested. Third parties may also send their own cookies and pixel tags to you, and may collect information and use it in a way that is different from this Policy. Please carefully review these third-party privacy policies to understand how your information may be collected, used and disclosed by these third parties.
Third Party Services and Social Media Platforms.
Interactions Between The Services And A Third-Party Web Site Or Service
Third Party Applications or Features
You may also choose to participate in a third party application or feature through our Services (such as logging in through social media or otherwise linking the Services with another web site or interactive service) or on a third party web site or service (such as social media applications or a feature on a third party web site or service) through which you allow us to collect (or the third party to share) information about you, including Personal Information. Information about you, including your name and profile photo, may be shown to other users of the Services if you are logged in through the Services or through a third-party web site or service. The third party may allow you to remove the application or feature, in which case we will no longer collect information about you through the application or feature, but we may retain the information previously collected. When you choose to participate, you may be opting to link your activity on our Services with that third-party web site or service, which may then collect information about your visits to our Services and may publish that activity as you request to your profile or similar feature with that third party. In some instances, we may require that you participate in the Services through a third-party application or feature and, if you choose not to authorize or use the required third-party application or feature, you will not be able to use the applicable Service.
Video conferencing services, such as Zoom or similar services, may be used by FIDM. When sessions are recorded, you will be provided with notice of the recording. To the extent that a recording is made of your class session, you have the option to (a) leave the session and watch the recording at a later time or (b) use the microphone and/or camera, which will record your voice and/or image. If you do not consent to being recorded, you must log out of the recorded session. If you choose to stay in the recorded class, your continued presence and/or participation in the class is your consent to the recording and later reposting by your instructor and FIDM on Canvas and Vimeo for internal use by FIDM and its students. Your election to use a microphone and/or camera constitutes a release and waiver of rights in the capture of your image, likeness, and/or voice for the exclusive use by FIDM.
It is also important that you respect the privacy and intellectual property rights of our FIDM community, which includes but is not limited to our faculty and students. By participating in a video conferencing session at FIDM, you agree that you will not save, record, share or post the session or any photos from the session without prior permission.
Marketing Partners. We may receive your name, contact information and educational background from marketing partners.
Third Party Service Providers. We collect Personal Information from service providers such as website hosting platforms and email service providers.
Your ‘Do Not Track’ Browser Setting. Some web browsers incorporate a Do Not Track (“DNT”) feature that signals to the websites that you visit that you do not want to have your online activity tracked. At this time, our Services do respond to DNT signals. Other third-party websites may keep track of your browsing activities when they provide you with content, which enables them to customize what they present to you on their websites.
HOW WE USE YOUR PERSONAL INFORMATION
We will use your Personal Information for the following purposes:
- Identifiers, Contact Information, Demographics, Financial and Sensitive Information may be used for academic and business purposes (service delivery, compliance, reporting and operations, business transfers, security, fraud protection and safety), research and development and marketing.
- Technical Information may be used for business purposes (service delivery, compliance and operations, business transfers, security, fraud protection and safety), research and development, marketing and Aggregated or anonymous data for analytics.
- Profile Data may be used to provide Services and for marketing purposes.
- Usage Data may be used for marketing purposes.
- Communications Information may be used to contact you and for other business purposes.
HOW WE SHARE YOUR PERSONAL INFORMATION
We share your Identifiers, Contact Information, Profile Data, Financial Information, Sensitive and Technical Information with professional advisors, affiliates, advertising partners, authorities and others and business transferees and as discussed below.
Other Educational Institutions
We work with other colleges, universities, scholarship providers, foundations, benefactors and educational institutions ("Educational Institutions") to help guide students through the educational journey – exploring, learning, planning and collaborating, as well as extract insights from across various siloes. We do not share your contact information (email address, full postal address or phone number) with these Educational Institutions without your consent, but we may send you information on their behalf.
Affiliated Entities. FIDM may share your Personal Information with affiliated entities, including but not limited to the Alumni Association.
Other Business Partners. We may share non-Personal Information, such as aggregated or pseudonymous information user statistics, demographic information and Usage Information with third parties, including advertisers, content providers, and analytics providers; and third parties may collect non-Personal Information when you visit the Services.
Advertising Partners. FIDM does not share your Personal Information with third parties for their marketing purposes without your consent and in compliance with applicable laws.
Service Providers. We may use third-party service providers to perform certain business services and may disclose Personal Information to such service providers as needed for them to perform these business services. Business services provided include, but are not limited to, payment processing services, hosting vendors, data analytics and customer support providers, IT service providers, communications services, website development services, compliance services, and analytics services.
Third-Party Networks and Analytics Providers. We work with analytics service providers and other vendors to provide us with information regarding traffic on the Services, including the pages viewed and the actions users take when visiting the Services; to serve our advertisements on other websites, within mobile apps, and elsewhere online; and to provide us with information regarding the use of the Services and the effectiveness of our advertisements. FIDM does not currently serve advertisements on or through the Services. Some of the companies who serve these targeted ads participate in a self-regulatory program that allows you to opt-out of having information about you used for this purpose, and you may access that opt-out by clicking here. Please note this does not opt you out of being served advertising. You will continue to receive generic ads while online. We may share Usage Information about visitors with analytics providers and other vendors. Our analytics service providers and other vendors may set and access their own tracking devices (including cookies and web beacons) and they may otherwise collect or have access to information about you and your online browsing activities. Some of these third parties may collect Personal Information over time when you visit the Services or other web sites and services.
Third-Party Content, Links to Other Sites, and FIDM Content Found Outside of the Services. Certain content provided through the Services may be hosted and served by third parties, which may include third party widgets (such as those that allow you to "like" or "share" content with third party web sites and online services. In addition, the Services may link to third party web sites or content over which FIDM has no control and which are governed by the privacy policies and business practices of those third parties. In addition, third-party partners of FIDM from whom your order through the Services may have different privacy policies which apply to such partners use of your information. Please also note that FIDM content and widgets may be included on web pages and web sites that are not associated with us and over which we have no control. These third parties may independently collect data.
Sweepstakes, Contests and Promotions
We may offer sweepstakes, contests, and other promotions ("Promotion") that may require registration. By participating in a Promotion, you agree to governing terms, conditions or official rules, which may contain specific requirements of you, including allowing the sponsor(s) of the Promotion to use your name, voice, likeness or other indicia of persona in advertising or marketing associated with the Promotion. If you choose to enter a Promotion, Personal Information, such as your name and shipping address, may be disclosed to third parties or the public in connection with the administration of such Promotion, including, without limitation, in connection with winner selection, prize fulfillment, and as required by law or permitted by the Promotion's official rules, such as on a winners list.
We may display personal testimonials on our Services in addition to other endorsements. With your consent we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us via email by clicking here.
Legal Process. Subject to applicable law, we may disclose information about you: (i) if we are required to do so by law, regulation or legal process, such as a subpoena; (ii) in response to requests by government entities, such as law enforcement authorities; (iii) when we believe disclosure is necessary or appropriate to prevent physical, financial or other harm, injury or loss; or (iv) in connection with an investigation of suspected or actual unlawful activity. We may also use Device Identifiers, including IP addresses, to identify users, and may do so in cooperation with copyright owners, Internet service providers, wireless service providers or law enforcement agencies in our discretion. These disclosures may be carried out without your consent or without notice to you.
HOW WE PROTECT YOUR PERSONAL INFORMATION
We have reasonable security measures in place to prevent your Personal Information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Information on our instructions and they are subject to a duty of confidentiality.
We endeavor to keep your Personal Information confidential and protected against unauthorized access, misuse or alteration with commercially reasonable physical, technical, and administrative measures. However, as effective as these measures are, no security system is impenetrable. We cannot guarantee the security of electronic data nor can we guarantee that the information you supply will not be intercepted.
HOW LONG WE RETAIN YOUR PERSONAL INFORMATION
FIDM keeps information consistent with its retention practices. We will not hold personal information longer than is reasonably necessary for the disclosed purpose and as required by law.
Our Website and Services are intended for adult use only and are not directed towards children, minors, or anyone under the age of 18. If you are under the age of 13, you are not authorized to provide us with any Personal Information. If the parent or guardian of a child under 13 believes that the child has provided us with any Personal Information, the parent or guardian of that child should contact us at the email address below and to have this Personal Information deleted from our files.
CHANGES TO THIS POLICY
QUESTIONS ABOUT THIS POLICY
Our offices are located at:
919 S. Grand Ave.
Los Angeles, CA 90015 USA
PRIVACY INFORMATION FOR CALIFORNIA USERS
If you are a resident of California, the California Consumer Privacy Act ("CCPA") and California Privacy Rights Act (“CPRA”) provide you with specific rights regarding your Personal Information. These include:
Right to Know: You have the right to know the categories of Personal Information that we collect about you over the past 12 months, the categories of sources from which the Personal Information was collected, the business or commercial purposes for which the Personal Information was collected, sold, shared, and the categories of third parties with whom we share the Personal Information, and the specific pieces of personal information we collected about you.
Right to Correct: You have the right to correct inaccurate personal information that we maintain about you.
Right to Delete: You have the right to request that we delete Personal Information that we collected from you and retained, subject to certain exceptions.
Right to Limit the Use or Disclosure of Sensitive Personal Information: We do not use or disclose your sensitive Personal Information.
Non-Discrimination: Unless permitted by applicable law, we will not discriminate against you for exercising any of your privacy rights under CCPA or applicable law, including by, but not limited to:
- Denying you goods or services;
- Charging you different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
- Providing you a different level of quality of goods or services; or
- Suggesting that you will receive a different price or rate for goods or services or a different level of quality of goods or services.
Exercising Your Rights - Only you or an authorized agent may make a verifiable consumer request related to your Personal Information. Each of these rights may be exercised through our online request form at https://fidm.tfaforms.net/217961, or by sending an email to firstname.lastname@example.org, or contacting us at 1.800.624.1200.
Designating a Third-Party to Act on Your Behalf - In order to designate a third party to act on your behalf, that person must be registered with the California Secretary of State and must have valid written evidence of authority from you to act on your behalf, e.g. a validly executed Power of Attorney or some other written, notarized documentation that they can provide to us. Absent such documentation, we reserve the right to refuse to comply with third-party requests for information.
Verifying Your Requests - During the verification process, depending on the nature of your request, e.g. whether you are seeking access to information versus deleting information, we will first seek to verify your identity against known information in our environment, such as your name, e-mail address, and telephone. Upon receiving your request, we may also contact you via email and/or other secured communication channel to verify your identity. In certain instances, e.g. a mismatch against known information or where you are seeking information on behalf of another person with authorization, we may seek additional verification from you, which may be in the form of you providing a copy of a valid, government issued identification or a notarized attestation.
Response Timing and Format
We endeavor to respond to a verifiable consumer 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. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
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.
Exceptions - We may deny certain requests, in whole or in part, based on our legal rights and obligations. For example, we may retain personal information as permitted by law, such as for tax or recordkeeping or to comply with legal obligations, to process transactions, perform continuing obligations, and facilitate requests.