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Additional EEA Privacy Disclosures


Additional EEA Privacy Disclosures
Last Updated: September 16, 2020

The following EEA privacy disclosures (the “Disclosures”) provide information about the collection, use, processing and sharing of data about individuals located in the European Union, Iceland, Liechtenstein or Norway (the “European Economic Area” or “EEA”). In these Disclosures,
• “GDPR” means the European Union’s General Data Protection Regulation;
• “Personal Data” means information that relates to an individual who is directly or indirectly identified or identifiable; and
• “EEA Processing Activities” means the collection, use, processing or sharing of Personal Data when those activities are within the scope of the GDPR.

These Disclosures apply only to the use of Personal Data in EEA Processing Activities. Further, these Disclosures apply only to the AIU University Schools, Centers, and other AIU units and controlled entities (collectively, “AIU Entities”) that link to these Disclosures or expressly adopt them in writing. In these Disclosures the words “we” or “our” refer to each such AIU Entity. In some cases, a AIU Entity may provide other information about its EEA Processing Activities in its own supplemental or separate disclosures.

These Disclosures apply to EEA Processing Activities by any means, including hardcopy (such as paper applications or forms) and electronic means (such as websites and mobile applications).
A. How We Collect and Use Personal Data
AIU collects personal data that may involve EEA Processing activities.
Which data we collect?
I. Data you provided
II. Data automatically collected (as cookies)
III. Data obtain from third party (as Google or Facebook used for retargeting campaigns)

We use the data to:
I.- Contact you by phone and email based to respond to your requests or inquiries.
II.- Send you automatic/newsletter/weekly emails related to your interest.
III.- Create/update digital marketing campaigns.

The only way AIU collects data directly to our Data Base is from those who decided to fill out the request form. We don’t have direct access to other information collected and third parties (like cookies) which they use for retargeting campaigns, etc.

Please note that, depending on the situation, some of the processing of Personal Data we do in the various circumstances described below may not fall within the scope of the GDPR.

1. Personal Data We Obtain from You
Prospective students who would like to study at AIU
AIU collects only the data that you provide by filling out request forms or applications in our website and/or landing pages.
We also collect the IPs address of the users who fill out the forms in order to avoid/prevent DDOS and other attacks/hacks.
If you share personal information with the Admission Counselor that AIU assigned to you to support you with the enrollment process (if you qualify). He/she will use that data in order to qualify you both academically and financially. Employees and Job Applicants
We collect the data you shared with third parties as well as with AIU directly in order to inform you about current or future opportunities.

2. Personal Data We Obtain from Third Party Sources
Some third parties as Adroll.com, Keystone academy, Perfect Audience, Pontiac Intelligence will share with us candidate who are likely to study at AIU based on request they did or digital marketing resources. AIU will only get information from people who filled out forms. We are not receiving or getting personal data that was not given by the prospective student directly on request forms or applications.

Partners and Service Providers
We use partners and service providers, such as payment processors (FirstData), to perform services on our behalf. Some of these partners have access to Personal Data about you that we may not otherwise have (for example, when you sign up directly with that provider) and may share some or all these data with us.

3. Additional Uses of Personal Data
• At your request, processing and fulfilling transactions for merchandise or other AIU products;
• Alerting you about a safety or security announcement;
• Preventing, investigating, taking action regarding or providing notice of fraud, unlawful or criminal activity, other misconduct, security or technical issues, or unauthorized access to or use of Personal Data, our website or data systems; or
• Responding to subpoenas, court orders, or other legal process; enforcing our agreements; protecting the health, safety, rights or property of you, us or others; and meeting legal obligations.

4 Legitimate Interests
AIU relies on several legitimate interests in using and sharing your Personal Data. These interests include:
• Enhancing protection against fraud, spam, harassment, intellectual property infringement, crime and security risks; and
• Meeting our obligations and enforcing our legal rights.

5 Data Retention
We will retain your Personal Data for as long as is necessary. You can request an opt out at any time. It may take up to 1 month once we received your opt out request for you to stop receiving our emails and communications.

B How We Share and Disclose Personal Data
AIU only share personal data in order to facilitate the prospects candidates, students and alumni the processing of payments.

We don’t share your data to third party CRM since we built our own CRM in-house.

We don’t share your data to student platforms since we built our own Student platform (also known as Virtual Campus).

Social Media Platforms
We may also use services provided by third parties (such as social media platforms) to serve targeted ads or sponsored content on third-party platforms. For more information regarding our use of cookies and similar technologies, see the “Cookies and Similar Technologies” section below.

Legal Process, Safety and Terms Enforcement
We may disclose your Personal Data to legal or government regulatory authorities as required by applicable law. We also disclose your Personal Data to third parties as required by applicable law in connection with claims, disputes or litigation, when otherwise required by applicable law, or if we determine its disclosure is necessary to protect the health, safety, rights or property of you, us or others, or to enforce our legal rights or contractual commitments that you have made.

C. International Data Transfers
AIU may transfer your Personal Data between AIU Entities and/or to the third parties discussed above. We may transfer your Personal Data outside the EEA relying on appropriate or suitable safeguards or specific derogations recognized under data protection laws, including the GDPR.

The European Commission has adopted standard data protection clauses, which provide safeguards for Personal Data transferred outside of the EEA. We may use Standard Contractual Clauses when transferring Personal Data from a country in the EEA to a country outside the EEA. If your Personal Data are affected, you can request a copy of our Standard Contractual Clauses by contacting us as set forth in the Contact Us section below.

E. Your Rights
You can request opt out at any time.
To submit a request, please send an email message to [email protected] or click on “Unsubscribe” in any of the emails you received from AIU.

H. Contact Us:
Via e-mail: [email protected] @aiu.edu
Via mail: Atlantic International University
Attn: Opt Out List Manager
900 Fort Street – 905
Honolulu, HI 96813

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