This Policy is effective as of: January 15, 2021.
For ease of reference, you may click on any of the following links to jump to one of the sections addressed below:
- Scope of this Policy
- Information We Collect, Use and Share
- Processing by Service Providers
- Your Rights and Choices
- Securing Personal Information
- Children’s Privacy
- Non-U.S. Concerns
- How We Handle EU Data
- Contacting Nuventive, LLC
Scope of this Policy
This Policy covers only the Services identified above, and does not apply to information which you may send us by other means. Other Nuventive sites, locations and services, whether online or offline, may have their own privacy policies, and you should consult those accordingly.
Nuventive reserves the right to make changes to this Policy at any time. Since this Policy may change as we modify or expand our Services, we suggest that you check back from time to time in order to understand how we treat your information. Our Policy’s effective date will always be set forth at the beginning and end of the Policy. Any changes will be immediately incorporated into this Policy, and will be prospective only. We will not make any changes that have retroactive effect unless legally required to do so.
Any change to this Policy is effective immediately. Your continued use of the Services after any changes are made constitutes your acceptance of any new terms in the Policy, as revised. If any changes are unacceptable to you, you should cease all use of the Services.
Information We Collect, Use and Share
Personal information is generally defined as information that, by itself or in combination with other information, identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, device or household (“Personal Information”). Personal Information can include, but is not limited to, your name, address, telephone number, email address, username and password, IP address or other online identifiers, browsing or search history, credit/debit card number or other financial information, professional or employment-related information, office address and other business information, demographic information, consumer preferences, biometric information such as fingerprints, precise location information, or any other type of information that, directly or indirectly, can be linked to or is reasonably capable of being associated with you.
When you use Nuventive’s Services, we may collect, use and share the following categories of Personal Information as described in this table:
|Categories of Personal Information we collect||We may collect this Personal Information when…||We collect this Personal Information so that we may…||Types of third parties that may receive this Personal Information|
|Contact information and other data that could be used to identify or communicate with you, including your name, alias, signature, mailing address, email address, telephone number, fax number, company name, job title, role or other professional or business information, and any inferences we might draw from such information.|
|Demographic information such as your job title, role, other professional interests, and any inferences we might draw from such information.|
|First-party cookie identifiers set directly by Nuventive, which may include information on your interaction with the Services, any Nuventive application, or any Nuventive ad, and any inferences we might draw from such information.|
|Third-party cookie identifiers, internet protocol (IP) addresses, pixels and other online identifiers, browsing history, search history, information on a consumer’s interaction with a website, app, or advertisement, and any inferences we might draw from such information.|
Nuventive collects certain data through your use of the Services, which Nuventive uses to help providers of educational services improve strategy, accreditation, graduation rates, retention, learning outcomes, general education, housing, sustainability, administrative outcomes, program review, diversity, and more (“Educational Data”). Educational Data may include certain demographic information, such as age, gender or ethnicity, among other data points. Nuventive collects, uses and shares Educational Data with relevant educational institution(s) in an aggregated format that is not reasonably capable of identifying students and other individuals, but we cannot guarantee that educational institutions will be unable to combine Educational Data in such a way that it becomes Personal Information.
We may also use or disclose any of the above categories of Personal Information we collect for one or more of the following reasons:
- To carry out our obligations and enforce our rights arising from any contracts related to your use of the Services, including for billing and collections;
- As necessary or appropriate to protect the rights, property or safety of Nuventive, our customers or others;
- To respond to law enforcement requests and as required by applicable law, subpoena, court order, other legal process or governmental regulations;
- As otherwise described to you at or before the point when we collect your Personal Information; or
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or to transfer some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us is among the assets transferred.
By providing to Nuventive the Personal Information and other data referenced above, you agree that we may use the Personal Information and other data in accordance with the terms of this Policy. We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Processing by Service Providers
Nuventive does not currently sell Personal Information to third parties. Except as noted herein, Nuventive does not share your Personal Information with any person or entity outside of Nuventive.
We may disclose certain portions of your Personal Information to service providers or third parties as necessary for the business purposes described above. As referenced, the Services may use third-party cookies to analyze how visitors and customers interact with our Services, and for other purposes as described above. These third-party service providers will have access to certain data, which may include Personal Information, needed to perform their functions but cannot use that information for any other purpose. You are not required to accept Nuventive’s use of certain third-party cookies. However, certain functionality of the Services may not work properly (if at all) if you reject cookies.
The Services use a data integration and management platform for education organizations to unify and utilize data across software applications, which includes third-party technology and services provided by Microsoft. Microsoft may collect or have access to certain portions of your Personal Information as a result of this processing. For more information about how Microsoft handles any Personal Information it receives through your use of Nuventive Services, please review Microsoft’s privacy practices as described at https://privacy.microsoft.com/en-us/privacystatement. If you would like to make any requests regarding Microsoft’s collection and use of your Personal Information, please see the options available at https://privacy.microsoft.com/en-US/privacy-questions.
Microsoft may provide Nuventive with crash data and other information related to “bugs” or other potential issues with our Services (“Error Reporting Data”). Error Reporting Data may contain portions of your Personal Information. Nuventive uses Error Reporting Data solely for the purpose of testing and resolving compatibility issues, fixing and resolving bugs or other quality issues, and does not disclose it for any purpose.
Nuventive may share certain data that could be combined with other information to become reasonably capable of identifying you, such as your IP address or cookie identifiers, to Microsoft for use in connection with advertising services to send you information about products you might be interested in based on your use of the Services and your activity elsewhere online. You may be able to opt-out of Microsoft’s cross-product interest-based advertising at https://choice.live.com/advertisementchoice/.
You can generally opt-out of receiving targeted ads from third-party advertisers and ad networks who are members of the Network Advertising Initiative (NAI) by visiting http://optout.networkadvertising.org/. You may opt-out of receiving targeted advertisements from other companies that perform interest-based advertising services via the Digital Advertising Alliance (DAA) site at http://optout.aboutads.info/. Please note that when using the ad industry opt-out tools described above, you may need to execute opt-outs for each browser or device that you use, and that other companies’ opt-outs may function in different ways.
Certain areas of the Services may integrate with social media sharing services which will let you share content from the Services with other third-party sites or online services. Your use of such features may enable the sharing of information with your friends or the public, depending on the settings you establish with the relevant social sharing service. Please review the privacy policies of those social media services for more information about how such services handle the information you provide to or share through them.
Nuventive neither collects nor sells the Personal Information of minors under 16 years of age.
Your Rights and Choices
Depending on where you reside, you may have one or more of the following rights with regard to Nuventive’s collection, use and sharing of your Personal Information:
- The right to request that we disclose what Personal Information we collect, use, disclose or sell about you;
- The right to request the deletion of Personal Information we collected or maintain about you;
- The right to opt-out of the sale of your Personal Information (if Personal Information is sold); and
- The right not to receive discriminatory treatment by Nuventive, in terms of the services and prices offered on or through our Services, because you exercised these rights regarding the collection, use and sharing of your Personal Information.
If you would like to access, review, edit, delete or have us properly dispose of any copies of the Personal Information that Nuventive collected about you (subject to any applicable legal exceptions), if you would like to opt-out of receiving further information or limit what we share, or if you would like to exercise the above rights in any other way, please contact us at firstname.lastname@example.org or call us at +1 412 847 0280 (Toll Free: +1 877 366 8700).
You may be able to opt-out of Nuventive sharing your Personal Information with the entities identified in this Policy by sending us an email at the address above or by visiting this portal, unless the sharing of your Personal Information is necessary to perform one of the following business purposes: to count ad impressions and evaluate their effectiveness; to detect, protect against, and prosecute security incidents; to debug or troubleshoot functional errors that may arise with the Services; to complete short-term tasks related to an existing interaction you have with Nuventive; to maintain or service your account; to process payments and fulfill orders or other transactions you authorize; to verify your customer information; and to ensure the safety and quality of the Services.
Nuventive will do its best to accommodate any request to delete or properly dispose of any copies of your Personal Information, but we cannot guarantee we can eliminate all Personal Information from the specified uses. Therefore, please be as specific as possible in any request to delete or dispose of copies of your Personal Information. We may deny your deletion request if retaining the information is necessary for us or our service providers to:
- 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 to perform a contract we entered into related to your use of the Services;
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
- Debug products to identify and repair errors that impair existing intended functionality;
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546);
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent;
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
- Comply with a legal obligation; or
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
If you choose to delete certain portions of your Personal Information, it may affect your ability to use certain Nuventive Services. If the request relates to information that Nuventive needs to make certain Services function properly for you, you may no longer be able to use those Services. Any removal of content by Nuventive does not ensure or guarantee complete or comprehensive removal of the content in all places. The content may have been shared or reposted by other parties, or federal or state law may require maintenance of the content or information.
You may grant an authorized agent written permission to submit requests regarding your Personal Information, but we may deny authorized agent requests absent proof that you authorized such agent to act on your behalf, or if we are unable to verify your identity.
Nuventive is required to verify the identity of any person or entity that requests the disclosure or deletion of Personal Information. For most consumer requests, Nuventive will ask you to provide information that matches at least two pieces of Personal Information we store about you before responding to your request. If you would like to request the specific pieces of your Personal Information that Nuventive has collected, or if you would like us to delete highly sensitive information, you will need to match at least three pieces of information we store about you, and you must provide a signed declaration under penalty of perjury that you are the person whose Personal Information you are requesting.
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.
Nuventive reserves the right to maintain proper business records as required by law, or for otherwise legitimate business purposes to the extent permitted by law, even if such records contain portions of your Personal Information.
By using the Services, you agree that Nuventive may send you promotional emails about other Nuventive products, services and features you may find useful. If you would like to opt-out of receiving promotional emails from Nuventive, please follow the opt-out instructions at the bottom of the email or send Nuventive a detailed email at email@example.com.
Some browsers also have a “do not track” feature that lets you tell websites that you do not want to have your online activities tracked. Nuventive does not process these automated requests, but to learn more about ways to opt-out of certain kinds of targeted advertising, visit the Network Advertising Initiative website and the Digital Advertising Alliance website. Options you select are browser- and device-specific.
Securing Personal Information
Nuventive has physical, electronic and procedural safeguards in place, including an information security policy, to protect Personal Information provided to Nuventive or stored in Nuventive software applications from loss, theft, misuse and unauthorized access, disclosure, copying, use, alteration and destruction. Such safeguards, however, do not and cannot prevent other users from gaining access to the program, with the permission or by the designation of the licensed subscriber, from being able to view, copy, modify or disclose information contained within the application. Although we cannot guarantee the security of Personal Information provided to Nuventive or stored in a Nuventive software application, Nuventive believes that its security policies and safeguards are reasonable and appropriate to adequately protect such information, regardless of the format in which such information is held. Nuventive intends to review and update its security policies and safeguards on a regular basis. Nuventive requires that its employees keep all Personal Information confidential and comply with its information security policy and privacy practices. Nuventive uses reasonable efforts to ensure that upon disposal or deletion of Personal Information, confidentiality of the information is maintained.
While Nuventive takes the issue of protecting your Personal Information seriously, you should exercise discretion in what you disclose and/or transmit through the Services. Nuventive cannot guarantee that information sent over the internet is fully secure, and therefore the transmitted information may be intercepted by others before it reaches Nuventive. If you are concerned about sending information to Nuventive over the internet, please send the information by mail or call us to make other arrangements. Nuventive is not responsible for the security of information sent over the internet.
Nuventive retains collected information for a reasonable amount of time in order to fulfill the stated purpose for why the information was collected. Nuventive will also retain collected information connected to business records for periods of time required by law. If Nuventive determines that collected information is no longer needed, it will delete such information. Our collection times will be consistent with applicable law. If you have any questions about the security or retention of your Personal Information, you can contact us at firstname.lastname@example.org.
Nuventive’s Services are intended for individuals 16 years of age and older. Our Services are not directed at, marketed to, nor intended for, children under 16 years of age. Nuventive does not knowingly collect or sell any information, including Personal Information, from children under 16 years of age. If Nuventive learns that it has collected any information regarding a person younger than 16 years of age, Nuventive will delete or destroy the information immediately.
If there is concern that information regarding a person younger than 16 years of age was somehow collected by Nuventive, any minor, or the parent(s) or legal guardian(s) of such minor, who wishes to request the removal of the minor’s information should submit their request by using the contact details provided in the “Contacting Nuventive, LLC” section below.
If you provide information to Nuventive from outside of the United States, you do so at your own risk. If you are outside of the United States, you are responsible for complying with any local laws regarding use of the Services, and related data collection. You also agree and acknowledge that by providing any information, including Personal Information, through the Services, that such information will be transmitted to, and stored in, the United States.
How We Handle EU Data
If you reside within the European Economic Area (the “EEA,” which includes the 27 European Union Member States, Iceland, Norway and Liechtenstein), Switzerland or the United Kingdom (collectively, the “EU”), then Nuventive handles your Personal Information and data according to the terms of this Policy, unless the exceptions in this section apply, pursuant to the General Data Protection Regulation (“GDPR”).
Nuventive will collect, process and use your Personal Information as described in this Policy and for the purposes set forth in this Policy. With the exception of uses for which we have obtained your consent, your Personal Information is processed in support of legitimate interests as described in this Policy.
If you reside within the EU, we will seek your consent before using your Personal Information to serve you relevant content and educational materials based on your personal preferences, interests, location and other information that you provide to Nuventive in connection with your use of the Services.
Under the GDPR, users in the EEA have the following rights regarding Nuventive’s processing of Personal Information:
- the right to request details on the Personal Information we hold about you at any time;
- the right to update and correct any inaccurate Personal Information Nuventive holds about you;
- the right to withdraw any consent for marketing activities or processing of Personal Information that you might have provided to Nuventive;
- the right to request erasure of Personal Information;
- the right to request restriction of Nuventive’s processing of your Personal Information;
- the right to object at any time to Nuventive’s processing of Personal Information concerning you; and
- the right to request the portability of Personal Information you provided to Nuventive.
If you would like to review, edit or delete any of the Personal Information Nuventive collected from you, if you wish Nuventive to stop using your Personal Information in the manners specified in this Policy, or if you would like to exercise the rights listed above in any other way, please contact us at email@example.com.
Under the GDPR, users in the EEA also have the right to lodge a complaint about Nuventive’s processing of your Personal Information with a supervisory authority. In particular, such users may lodge a complaint in the Member State where the user lives or works or where the alleged violation took place.
To protect your Personal Information, Nuventive’s Services use appropriate technical and organizational security measures to protect against unauthorized access, alteration, disclosure or destruction of your Personal Information and other data stored on our Services.
Nuventive retains Personal Information only for as long as necessary to fulfill the stated purpose for which the Personal Information was collected or otherwise processed, and thereafter for a variety of legitimate legal or business purposes. These may include retention periods that are: (i) mandated by law, contract or similar obligations applicable to Nuventive’s business operations; (ii) for preserving, resolving, defending or enforcing our legal/contractual rights; or (iii) needed to maintain adequate and accurate business and financial records. We will delete your Personal Information as soon as the respective purpose of use is not applicable anymore and no legal obligation to retain such data exists. If you have any questions about the security or retention of your Personal Information, you can contact us at firstname.lastname@example.org.
Your Personal Information may be disclosed to and processed by staff operating in the United States. Disclosure will be to individuals who work for Nuventive, our subsidiaries, related companies, and companies with which we have contracted to process or store this data on Nuventive’s behalf. The individuals and organizations that receive Personal Information as a result of international transfers out of the EU must follow our express instructions with respect to the use of Personal Information and they must comply with appropriate security measures to protect your information.
Contacting Nuventive, LLC
If you have any questions or comments about this Policy, the Services, or your other interactions with Nuventive, you can contact:
9800B McKnight Road
Pittsburgh, PA 15237 USA
Phone: +1 412 847 0280 (Toll Free: +1 877 366 8700)
Fax: +1 412 847 0285
Nuventive intends to strictly enforce this Policy. If you believe there has been some violation of this Policy, please contact Nuventive.
This Policy was last updated on January 15, 2021.