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OU Online Privacy Policy

Privacy Policy

The University of Oklahoma (the “University”) utilizes Elsmere Education, Inc. (“Elsmere”) to host and provide various websites and/or webpages, including this website. Elsmere is committed to respecting your privacy. This policy describes how this website collects, uses, discloses, and processes personal information, and the rights and choices you may have regarding that processing. 

Scope

This policy applies only to information collected by Elsmere through this website – it does not describe or apply to information the University collects from you through non-Elsmere hosted sites, in person or through other interactions with the University. For information about the University’s privacy practices, please visit the University’s privacy policy, available at https://www.ou.edu/marcomm/web-policies/privacypolicy. When we use the term “we” in this policy, we are referring to Elsmere, not the University

Information Collection

When you visit this website, Elsmere may collect information from you directly when you fill out a form or contact us through the website, and/or automatically via cookies and other tools. The information we collect from you includes personal information, which allows us to identify and communicate with you on behalf of the University. Personal information is information that identifies, relates to, describes, or is reasonably capable of being associated with an individual or household.

We have collected the following categories of personal information from visitors to this website in the last 12 months:
Category Examples Collected
A. Identifiers. A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers. Yes.
B. Personal information categories listed in state statutes, including the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Yes.
C. Protected classification characteristics under state or federal law. Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). Yes.
D. Commercial information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. Yes.
E. Biometric information. Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. No.
F. Internet or other similar network activity. Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. Yes.
G. Geolocation data. Physical location or movements. Yes.
H. Sensory data. Audio, electronic, visual, thermal, olfactory, or similar information. No.
I. Professional or employment-related information. Current or past job history or performance evaluations. Yes.
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. Yes.
K. Inferences drawn from other personal information. Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. Yes.
Sensitive Personal Information The contents of your communications Yes, when you fill out a “Contact Us” form through the website.
Sensitive Personal Information Racial or ethnic origin Yes, from individuals who choose to provide this information.

We may not collect all of the above categories of information from every individual who visits this website.
We rely on cookies and similar technologies to facilitate our collection of information from you automatically. For more information about the use of cookies and similar technologies on this website, please review the section below titled “Cookies.”

Information Use

We use the information we collect from you for the following purposes:
  • To offer our website, online programs, and online services, including to secure and ensure the proper functioning of our website, online programs, and online services
  • To improve the website and Elsmere’s service offerings (including website performance)
  • To market the University’s programs, products, and services to you, including to send you promotional communications about the University’s programs and other programs we think may be of interest to you.
  • To respond to your request, communication, or inquiry and provide you with information and/or services you request
  • To provide colleges and universities with information from or about you so that they may reach out to you with information about their programs
  • To communicate with you
  • To comply with and abide by our legal obligations, including contractual obligations with other parties
  • For any other purpose you consent to at the time of collection
  • For any other purpose you direct us to

Combining Information

We may combine the information we collect from you directly including your name, phone number, and/or email address with information that we collect from you automatically when you visit this website. We may also combine the information we collect from you through this website with information we collect from you through other means, including from third parties or other sites. We use combined information for the above purposes, including to market to you.

Information Retention

Elsmere will retain the information collected through this website for as long as necessary in light of the purpose for which it was collected, consistent with applicable law, regulations, consumer expectations, and our information retention policies. We may retain de-identified or anonymized information beyond the time period that we retain personal information.  

Information Disclosure

Elsmere may disclose your information for a business purpose to third party service providers, contractors, or vendors who assist us in providing this website, online programs, and online service offerings. Our service providers, vendors and contractors include affiliate marketing programs, communication and collaboration tools, data storage service providers, performance monitoring tools, product engineering and design tools, sales and marketing tools, testing tools, and website hosting service providers.

In the last 12 months, we have disclosed the following categories of information to third parties for a business purpose:

Category Disclosed for a business purpose? Categories of third parties
A. Identifiers. Yes Service providers, vendors, consultants; the University; colleges and universities.
B. Personal information categories listed in state statutes, including the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). Yes Service providers, vendors, consultants; the University; colleges and universities.
C. Protected classification characteristics under state or federal law. Yes Service providers, vendors, consultants; the University; colleges and universities.
D. Commercial information. Yes Service providers, vendors, consultants; the University; colleges and universities.
E. Biometric information. Not collected N/A
F. Internet or other similar network activity. Yes Service providers, vendors, consultants; the University; colleges and universities.
G. Geolocation data. Yes Service providers, vendors, consultants; the University; colleges and universities.
H. Sensory data. Not collected N/A
I. Professional or employment-related information. Yes N/A
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). Yes Service providers, vendors, consultants; the University; colleges and universities.
K. Inferences drawn from other personal information. Yes Service providers, vendors, consultants; the University; colleges and universities.
Sensitive Personal Information – The contents of your communications Yes Service providers, vendors, consultants; the University; colleges and universities.
Sensitive Personal Information – racial or ethnic origin Yes Service providers, vendors, consultants; the University; colleges and universities.

When we disclose your information to the University we maintain this website on behalf of pursuant to our agreement and relationship with them, the University’s use of your personal information falls within their privacy policy, which is available here.

In addition to the above, we may also disclose your information in the following circumstances:
  • To respond judicial process or to comply with a legal obligation, consistent with applicable law.
  • In connection with a business transfer, or during negotiations of any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
  • To our affiliates, in which case we will require those affiliates to honor this privacy notice. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.
  • For commercial purposes, as described in the section below beginning with “Remarketing.”
Finally, we will further disclose your information as you direct us to, or as you otherwise consent to at the point of collection.

Remarketing, Behavioral Targeted Advertising and Sales or Sharing of Information

We disclose information collected through this website for a commercial purpose. Under certain state privacy laws, our collection and use of your personal information, particularly as it relates to our marketing practices, may constitute a sale of your personal information. We also use information we collect from or about you on this website, including information collected via cookies, to display advertising to you based on your activity on this website and across other websites. This is sometimes referred to as behavioral targeted advertising, or remarketing. Based upon your visit to this website, we may utilize cookie technology to present you with advertisements about the University or other programs, products, or services during your future web browsing, such as sidebar advertisements, based on your interest in the University.

In the last 12 months, we have sold, shared, or disclosed for a commercial purpose the following categories of information with the following types of third parties:

Category Disclosed for a commercial purpose, sold, shared, or used for targeted advertising? Categories of third parties
A. Identifiers. Yes Network advertisers; affiliate marketing programs; data analytics services; performance monitoring tools; social networks; retargeting platforms; colleges and universities
B. Personal information categories listed in state statutes, including the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). Yes Network advertisers; affiliate marketing programs; data analytics services; performance monitoring tools; social networks; retargeting platforms; colleges and universities
C. Protected classification characteristics under state or federal law. No N/A
D. Commercial information. Yes Network advertisers; affiliate marketing programs; data analytics services; performance monitoring tools; social networks; retargeting platforms; colleges and universities
E. Biometric information. Not collected N/A
F. Internet or other similar network activity. Yes Network advertisers; affiliate marketing programs; data analytics services; performance monitoring tools; social networks; retargeting platforms; colleges and universities
G. Geolocation data. Yes Network advertisers; affiliate marketing programs; data analytics services; performance monitoring tools; social networks; retargeting platforms; colleges and universities
H. Sensory data. Not collected N/A
I. Professional or employment-related information. No N/A
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). No N/A
K. Inferences drawn from other personal information. Yes Network advertisers; affiliate marketing programs; data analytics services; performance monitoring tools; social networks; retargeting platforms; colleges and universities
Sensitive Personal Information – The contents of your communications No N/A
Sensitive Personal Information – racial or ethnic origin No N/A

For more information about rights and choices you may have regarding these practices, please visit the “Your Rights and Choices” section below.

Cookies

This website uses cookies, clear GIFs, pixel tags, and similar technologies (referred to collectively in this policy as “cookies”) to automatically collect information from or about you when you visit the website. Cookies are small data files that are sent to and stored on your computer, smart phone, tablet, or other device for accessing the internet whenever you visit a website. Cookies are useful because they allow a website to recognize a user or device. For more information about cookies generally, visit allaboutcookies.org.  

The website uses the following types of cookies:

  • Preference. These cookies remember actions taken on this website such as which language you review our website in, layout preferences, and cookie consent preferences.

 

  • Advertising. These cookies are used to provide you with personalized or targeted advertisements on this website and across the Internet.

 

  • Analytics. These cookies assist us with learning more about how users use this website, including pages visited, how much time is spent on each page, and similar information.

 

  • Authentication. These cookies assist us with authenticating user requests, and with maintaining session information related to users.

 

  • Functionality. These cookies help us ensure that the website functions properly.

 

  • Security. These cookies allow our servers to mitigate the risk of information leakage attacks by ensuring that requests are submitted to our website from proper domains.

 

Your Choices

Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies by adjusting the settings in your browser. You can also indicate your preferences for cookies the first time you visit our website by adjusting your preferences in the cookie popup banner. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our website. You may opt-out of a third party’s use of cookies by visiting the Network Advertising Initiative opt-out page located at this link.

If you’d like to opt-out of the sale or sharing of your personal information by Elsmere, please visit Elsmere’s website, located here, and navigate to the “Do Not Sell or Share my Personal Information” button. Elsmere’s corporate website also contains additional information on cookies, which may provide you with more details or understanding of the cookies Elsmere uses on this website. Elsmere’s cookies notice is available here.

Security

Elsmere utilizes reasonable technical, organizational, administrative, and physical security measures to protect information collected through this website, based on the information and technology available to Elsmere and the categories of personal information collected. However, despite our safeguards and efforts to ensure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we do our best to protect your personal information, transmission of personal information to and from this website is at your own risk. You should only access this website within a secure environment.

Third Party Hosting and Services

As mentioned throughout this policy, the University contracts with Elsmere to maintain and host the website, to assist in the provision of online services, and to assist the University with its educational offerings, including academic advising, coaching, and similar student support services. Any information collected through the website, including personal information, may be processed by and accessible to Elsmere, and this policy applies to Elsmere’s collection of information from or about you through this website. For more information about Elsmere’s privacy practices in general, please review their privacy policy, available here. By using the website, you acknowledge that third parties will have access to and may process your information.   

For more information about the University’s collection and use of your personal information, please visit the University’s privacy policy, available here.

Third Party Sites

This website may link to other websites, including other websites hosted by Elsmere, other sites of the University, or other external third-party websites. These websites may have different privacy and information practices than Elsmere and the University. We encourage you to review the privacy policies of all websites you visit.

Your Rights and Choices

You may have certain rights regarding the information collected through the website pursuant to state law, including the California Consumer Privacy Act (“CCPA”), Virginia Consumer Data Protection Act (“VCDPA”), Colorado Privacy Act (“CPA”), Connecticut Data Privacy Act (“CTDPA”) or the Utah Consumer Privacy Act (UCPA”), or under federal law, including the Family Educational Rights and Privacy Act (“FERPA”). The applicable law and rights you may have may depend on whether you are a student or applicant of the University, or whether you are a website visitor.  

If the information collected through the website is within the scope of state consumer privacy laws, you may have the following rights:

  • Right to access. You have the right to request that we provide you with the information we have collected about you through the website in the last 12 months in a portable, machine-readable format, to the extent technically feasible
  • Right to know. You have the right to request that we disclose information to you about our collection and use of your personal information collected through the website over the past 12 months. Specifically, you have the right to know:
    • The categories of personal information we collected about you
    • The categories of sources for the personal information we collected about you
    • Our business or commercial purpose for collecting or selling that personal information The categories of third parties with whom we disclose the information for a business purpose
    • The specific pieces of personal information we collected about you
    • If information collected through the website was sold, shared, or disclosed for a business purpose, the categories of third parties it was sold to, shared with, or disclosed to and the categories of personal information that were sold, shared, or disclosed
  • Right to delete. You have the right to have the information collected through the website deleted, subject to applicable exceptions
  • Right to correct or update. You have the right to request that we update your personal information, or that we correct your personal information that is inaccurate.
  • Right to limit certain uses and disclosures of your “sensitive personal information.” You have the right to request that we limit certain uses and disclosures of sensitive personal information, to the extent we collect it or use it in ways that reasonable consumers would not expect. We currently do not collect any sensitive personal information, but you may contact us if you are interested in learning more about this right or if you wish to confirm.
  • Right to opt-out of the “sale,” or “sharing” of personal information, or “behavioral targeted advertising.” You have the right to opt-out of the sale or sharing of your personal information, or to opt-out of targeted advertising, as those terms are defined in applicable law. You may manage information collected through cookies without making a formal request by adjusting your preferences in the cookie consent tool.
  • Right to an authorized agent. You may have the right to have an authorized agent make a request on your behalf. Please note that if you elect to have an authorized agent exercise your rights on your behalf, we will take steps to ensure that they have your authority, consistent with the applicable law and regulations.
  • Right to appeal. If we notify you that we are unable to process your request, you may have the right to appeal our decision not to fulfill your request.
To inquire about whether applicable law affords you the rights listed above, or to exercise your rights, please contact us using the information listed below. Please note that if you wish to exercise your rights, we will take steps to verify your request, including to ensure that you are the individual making the request (or that the individual making the request is your authorized agent).

Changes to our Policy

We may modify this policy from time to time if our practices or the law changes, or for other reasons. Your continued use of the website following our posting of a change notice will constitute binding acceptance of those changes and this Privacy Notice. Changes will be effective upon posting, unless otherwise indicated. We will update the “last updated” date at the bottom of this notice so that you are aware of when it was last updated. We encourage you to check this notice frequently and to observe the last updated date so that you are aware of changes to this notice.

Contact

If you have questions or comments about this privacy notice or our privacy practices, or if you’d like to mention any rights you are afforded under applicable law, you may contact Elsmere at compliance@elsmereeducation.com, by phone at 720-255-2840, or by post to:
Elsmere Education Inc.
Attn: Privacy Manager
90 Madison Street
STE 620
Denver, CO 80206
United States

If you have questions about University-related matters or the University’s use of your information, please contact the University at:

OU Marketing & Communications
339 W. Boyd St.
Norman, OK 73069
marcomm@ou.edu

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