California Consumer Privacy Act Website Consumer Data Privacy Notice
This Data Privacy Notice describes how the University of Arizona Global Campus complies with the California Consumer Privacy Act of 2018 (“CCPA”), with respect to California residents (“consumers”).
The CCPA is a California law that is designed to give residents of that state additional rights in relation to the collection, processing and sharing of their personal information. The law, while not directly applied to not-for-profit universities, may apply by extension to vendors or 3rd-parties we might contract with for services that collect and process personal information about California residents, even if the business doesn’t have its headquarters or other locations in California.
UAGC has put in place the following methods for California residents to exercise their rights under the CCPA. With respect to the right to opt-out, right to know/access, and right to request deletion, we have also included direct links in the relevant sections of this Data Privacy Notice (below) to exercise those rights.
- Website address: www.uagc.edu
- Toll-free number: (866)475-0317
- Email address: [email protected]
- Webform: https://www.uagc.edu/do-not-sell
- Mailing address: CCPA Rights, Legal Dept., UAGC, 180 South Arizona Avenue, Suite #301 Chandler, AZ 85225
For individuals with disabilities, and those who require language translations, please see the relevant sections of this Notice.
Personal Information Collection
The personal information that UAGC collects and processes about California residents is limited to those data elements that are relevant and proportionate for the particular purpose(s) of collection. They may include:
- Email address
- Phone number
- Mailing address
- User name and password (such as for certain restricted areas of our websites)
- Information to respond to your question(s)
- Website cookies and IP (Internet Protocol) address if your browser is set to allow cookies
- Website browsing information collected through Google Analytics if you visit our websites
- Information that you may post on our social media platforms or on other public platforms in relation to UAGC
Please see our Website Privacy Statement at www.UAGC.edu/privacy-policy for additional information.
Personal Information Uses
UAGC limits its use of personal information pertaining to California residents to the purposes for which the data is collected, such as to address your question or provide the services that are requested. We may also use the data for any surrounding legal, compliance, or regulatory obligations.
Personal Information Sharing
We may share your personal information with (1) third-party ‘service providers’ assisting us with our business services; or (2) when we are required by law to make disclosures to other third-parties including, for example, government or law enforcement agencies, such as in relation to legal, compliance or regulatory obligations.
In terms of third-party disclosures, we may retain subcontractors (i.e. our own “Service Providers”) to assist with a variety of business activities such as our websites, data hosting, student education activities and services, IT security, and social media activities. UAGC evaluates those service providers in advance to ensure that they are capable of upholding a similar level of protection for the data and also requires them to enter into a written agreement confirming their understanding that they are expressly prohibited from using the personal information for any unrelated purposes or from selling the information.
To the extent that we entrust your personal information “Service Providers”, they may only use that information for authorized purposes, and are prohibited from ‘selling’ your information or sharing it with any other parties for unrelated purposes.
In rare situations where UAGC may be required to entrust limited personal information of California residents to other third parties, such as regulatory or government agencies or law enforcement, we take reasonable steps to ensure that those parties recognize the confidential, non-public nature of the information and will protect it accordingly. In addition, most of those organizations are required to comply with other state and federal data privacy and security laws, which means that they also have a legal obligation to uphold appropriate protections for your information.
1. Cookies are small pieces of data sent from a website and stored on a user's web browser. When the user browses the same website in the future, the cookie notifies the website of the user's previous activity. Cookies do not harm your computer in any way, and some are automatically deleted after a certain period of time, such as six months. While cookies identify the IP address of the website visitor, they do not identify the visitor himself/herself.
2. Google Analytics is a web analytics service offered by Google that tracks and reports website traffic to website owners. It is used by more than one-third of all websites, so that the website operators can evaluate use of the site, make improvements, and offer content that is of interest to the visitors. The tool does not identify specific visitors but does capture IP addresses if the visitor sets their browser to permit cookies.
Use of Authorized Agents
In accordance with the CCPA, UAGC allows California residents to exercise their CCPA rights via an authorized agent. California consumers must recognize that in those situations, UAGC requires authentication/verification of the authorized agent as well as the individual about whom the data relates, and we may deny the request if we are unable to obtain appropriate authentication/verification at either level. The authentication/verification requirements adopted by UAGC vary by right, and take into consideration the potential risks to the individual of sharing their personal data with an unauthorized individual. Please see the specific rights (below), and general information about authentication/verification obligations associated with each of them.
Right to Opt-Out (Do Not Sell My Information)
Right to Know/Access
In accordance with the CCPA requirements, California residents may contact UAGC to request information about the categories of, or specific types of, personal information that we hold about them as well as how the data was used, the categories of third parties with whom the data was shared, and the purpose(s) for the sharing of the information. They can do so by emailing [email protected] or via one of the other options identified in the Contact Methods section of this Notice.
UAGC will acknowledge a right to know/access within 10 days of receipt, and request appropriate verification information. California residents who exercise this right or use an authorized agent to do so are subject to comprehensive verification using a variety of authentication tools to minimize any risk to individuals of unauthorized sharing of their person information. UAGC can deny the request if it is unable to verify the requestor and/or his/her authorized agent, and if so, will inform the individual/authorized agent within 45 days of receipt of their request. Of course, UAGC can also deny the request if it does not hold any information about the individual which falls within the scope of the CCPA.
Properly verified California residents and/or their authorized agents are entitled to receive information about (or a copy of) Personal Information collected by UAGC within the last 12 months before their request was made. UAGC will endeavor to fulfill those requests within 45 days, but may require an additional period of time (up to a total of 90 days) if necessary. If so, it will inform the requestor about the delay and the reasons therefore within the 45-day period.
California residents are limited to two such requests to know/access their data in any 12-month period (whether directly or via an authorized agent).
Right to Request Deletion
With certain exceptions as described below, California residents have the right to request deletion of their personal information, and can make the request directly or via an authorized agent. They can do so by emailing [email protected] or via one of the other options identified in the Contact Methods section of this Notice.
UAGC is not obligated to delete the personal information if it must be retained for one of the following purposes:
- Complete a transaction for which the personal information was collected.
- Fulfill the terms of a written warranty or product recall conducted in accordance with federal law.
- Provide a good or service requested by the consumer (California resident), or reasonably anticipated within the context of a business’ ongoing business relationship with the consumer.
- Otherwise perform a contract between the business and the consumer.
- Detect security incidents.
- Protect against malicious, deceptive, fraudulent, or illegal activity or prosecute those responsible for that activity.
- Debug to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law.
- 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 businesses deletion of the information is likely to render impossible or seriously impair the achievement of such research, if the consumer has provided informed consent.
- Enable solely internal uses of the data that are reasonably aligned with the expectations of the consumer based on the consumer’s relationship with the business.
- Comply with a legal obligation.
- Otherwise use the consumer’s personal information, internally, in a lawful manner that is compatible with the context in which the consumer provided the information.
In situations where UAGC receives a request for deletion from a California resident or authorized agent, it will acknowledge the request within 10 days of receipt, and will endeavor to fulfill the request within 45 days. If it becomes evident that UAGC is unable to delete all of the California resident’s data within the 45-day period, the company will inform the individual and/or the authorized agent within that period, and may take an additional 45-days to fulfill the request (i.e., a total of 90 days). Individuals who request deletion of their personal information or retain an authorized agent to do so on their behalf, will be subject to detailed verification in accordance with the CCPA requirements.
When UAGC processes a request for deletion from a California resident (which has been properly verified), it will delete the data from its systems in a secure and irreversible manner, such that the data cannot be restored. At the same time, in accordance with the CCPA, UAGC may refrain from deleting copies of information stored on back-up systems if it is unable to do so at the time that that it deletes the remaining personal information within the scope of the request. In those situations, UAGC will mark that data for future deletion when the deletion can take place. In addition, UAGC will not use that data for any unrelated purpose once it is marked for deletion.
To the extent that UAGC has entrusted any of the Personal Information of the California resident to a (downstream) service provider, it will also contact that service provider to process the deletion request and will confirm to the California resident (or his/her authorized agent, if applicable) that it has done so.
Rights of Minors
UAGC upholds the rights of California residents who are minors, including those that apply to minors who are under the age of 13 and those that apply to minors between the ages of 13 and 16. UAGC has also put in place practices to uphold the surrounding obligations to parents and legal guardians of those minors.
Parents and legal guardians who seek to exercise the CCPA rights of their children will also be subject to authentication so as to prevent the release of any information pertaining to a minor to an unauthorized individual.
Right to No Discrimination
In accordance with the CCPA, UAGC does not discriminate against individuals. Including those who choose to exercise their CCPA rights.
Rights of Individuals with Disabilities
UAGC provides accommodations to students with disabilities and chronic health conditions. To engage with these services, please contact the Office of Access and Wellness at (866) 974-5700 x20050.
Questions or Concerns
California residents who have questions or who believe that UAGC has mismanaged their personal information or otherwise infringed their rights may contact us using the contact methods listed in this Notice.
For additional information about UAGC’s CCPA practices, please contact us via one of the options provided in the Contact Methods section of this Notice.
Updates to this Notice
UAGC will review its CCPA notices and practices regularly, and may also make updates to this Notice at other intervals, such as in relation to new information issued by the California regulators or in connection with changes to its business activities. We encourage you to review this Notice periodically to be sure you are aware of those changes. Any changes will serve to enhance or strengthen the privacy and security protections that are in place for personal information of California residents, and not diminish them.
Issued: March 23, 2023
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