Boundless Learning Online Learning Services Privacy Statement

Effective Date: May 6TH, 2024

Who is Boundless Learning?

Boundless Learning is the brand name of Embanet Compass Knowledge Group, Inc. referred to herein as Boundless Learning (“Boundless Learning”, “we” or “us”) that partners with ${PARTNER_NAME} (“Institution”) to provide this site and support select online educational programs (“Programs”). Boundless Learning works in collaboration with the Institution to market and promote the Programs to prospective students, and thereafter may work with enrolled students to provide information, services and support.

What does this Privacy Statement cover?

This Privacy Statement explains the way Boundless Learning collects, uses, maintains and discloses information collected in connection with the Programs. This Privacy Statement applies only to Boundless Learning services and Boundless Learning web pages/sites (“Webpages”) related to the Programs, including online contact forms that you may complete to request information about the Programs. Other websites and programs, including the Institution’s websites linked from Webpages, may have their own privacy policies and practices. The Institution’s privacy policies and practices, and not this Privacy Statement, will govern the Institution’s collection and use of applicant and student data.

What personal information does Boundless Learning collect through the Programs? How does Boundless Learning use that personal information?

Information Requests. If you complete a contact form on a Webpage or otherwise request help or information from us, we will collect personal information so that we can contact and communicate with you, address your requests and provide information and messages to you about Programs that may be available. This information may include contact information, such as your name, email address and phone number, together with your question or request.

Cell Phone – Text Messaging and Calls. If you provide your cell phone number to us and indicate that we may contact you by phone or text message, we may call you and send you text messages to share information related to the Programs and to provide enrollment and educational program support to you. Message, call and data rates of your carrier may apply. You may opt out of receiving these calls or text messages at any time by telling us in a phone call or following the opt-out instructions contained in the text message.

Enrollment Support. If you contact or work with an enrollment advisor, we may collect personal information so that we can help you explore eligible educational options and apply for enrollment in eligible Programs. The personal information may include information about your employment history and educational background, such as employers, work experience, schools, areas of study, grades, transcripts and other educational records, together with any information that you may choose to share or that may be requested in the application and enrollment process for eligible Programs.

Educational Program Support. If you enroll in an eligible Program, we may receive personal information from the Institution for the purpose of providing Program support services to you. These support services may include course selection and registration assistance, degree audits and assistance to help you be successful and stay on track to complete a Program. The personal information may include information about your coursework, grades and other educational records. We may also receive any other personal information that you may choose to share or that may be requested to enable us to provide appropriate support.

Feedback. Boundless Learning may provide you with the opportunity to respond to surveys and to evaluate and provide feedback on the Programs. Boundless Learning may use that information to respond to you about your feedback and to address any issues that you may identify.

De-Identified Data. Boundless Learning may de-identify and aggregate information collected in connection with the Programs and use it to maintain, support and evaluate the efficacy of the Programs; conduct educational research; develop new products and services; and for other purposes. Unless required to do so by law, Boundless Learning will not attempt to re-identify such de-identified data.

Does Boundless Learning use personal information for marketing purposes?

Boundless Learning may use personal information in order to send you messages and information, and to identify other individuals who may be interested in receiving information, about eligible educational programs, products and services that may be available from the Institution, Boundless Learning, or other institutions of higher education. If you do not want to receive further emails from us, you may unsubscribe at any time by following the opt-out instructions contained in an email from us.

How does Boundless Learning protect personal information?

We use appropriate commercially reasonable data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of personal information.

Does Boundless Learning share or disclose personal information?

Except as specifically stated in this Privacy Statement, it is our policy not to share or disclose personal information collected through the Programs with third parties other than affiliates of Boundless Learning and other companies and organizations who perform work for or with us under contract and are committed to protect the privacy of personal information in a manner consistent with this Privacy Statement. This work may also include marketing services on our behalf to help us identify individuals who may benefit from the services and educational programs, products and services that may be available from the Institution’s educational offerings. These affiliates, companies and organizations may also contact and communicate with you, address your requests and provide information and messages to you, on our behalf, about other educational programs, products, or services that may be available.

Our service providers may include consultants, vendors and companies that perform marketing services on our behalf to help us identify individuals who may benefit from the services and educational offerings the Institution, or its affiliates provide. We require our service providers to protect your personally identifiable information and to use or disclose it only for the work they are performing for us, or as permitted by law.

We may disclose personal information: (a) with your consent; (b) to the Institution; (c) to your employer; (d) in response to a subpoena, court order or legal process, to the extent permitted or required by law; (d) as otherwise required or permitted by law; (e) to protect the security and safety of you and other persons, our systems and the data we hold, consistent with applicable law; (f) in connection with a sale, joint venture or other transfer of some or all of our company or its assets; (g) to address actual or suspected fraud or other illegal activities; or (h) in order to enforce the Institution’s Terms of Service or any contract that we or the Institution may have with you.

Can personal information be corrected?

To correct or update any information you previously provided to us, please call or email the enrollment advisor or student support coach you are working with.

Do Boundless Learning Webpages for the Programs collect additional information or use cookies? Do they respond to “do not track” signals?

Cookies and Related Technologies. Our Webpages related to the Programs may use cookies to personalize content, measure traffic patterns, personalize content, control security and provide interest-based messages and advertising. You have a variety of tools to control the use of cookies, web beacons and similar technologies, including browser controls to block and delete cookies. You may choose to disable or block these technologies, but that may prevent or limit the functionality of the Webpages.

Application and System Logs. Boundless Learning may automatically collect log data related to interactions with our Webpages in order to ensure availability and security. This log data may include browser type, type of computer/device and technical information about the means of connection to the Webpages, such as operating system, internet service provider and IP address. Log data is collected and used to monitor the health of the websites, detect unauthorized access and fraudulent activity, prevent and address security issues and appropriately scale computing resources.

Web Analytics. Boundless Learning may use third party web analytical services, including Google Analytics and Adobe Analytics, to collect anonymous visitor information. Such information may include IP addresses, browser types, referring pages, pages visited, and time spent on a particular site. While these analytical services collect and report information on an anonymous basis, they may use cookies and collect IP addresses to gather web trend information. Boundless Learning may use web trend information for system administration, to identify problems and to improve service.

Do Not Track. Do Not Track (DNT) is a proposed mechanism for allowing website visitors to control the collection of certain usage data. Although there has been research into the development of a standard to support the use of DNT signals, there is no adopted standard to follow. The Webpages do not currently respond to Do Not Track signals.

Nevada – Do Not Sell

We do not monetize personal information. Even though we do not sell personal information for financial consideration, Nevada residents may submit a request that we not do so by emailing us at dataprivacy@boundlesslearning.com.

Supplemental Privacy Statement

If you are a resident of California, Colorado, or Virginia, please also read our Supplemental Privacy Statement below, which provides information about your state-specific privacy rights and additional information required by the laws of these jurisdictions.

Is this Privacy Statement subject to change?

This Privacy Statement may be revised from time to time through an updated posting. Boundless Learning will identify the effective date of the revision in the posting. Updates may be made to provide greater clarity or to comply with changes in regulatory requirements. If Boundless Learning reasonably believes the updates involve material changes to the collection, protection, use or disclosure of your personal information, Boundless Learning will endeavor to notify you by email or another appropriate way.

What is Boundless Learning’s contact information?

To contact us about this Privacy Statement, please email us at dataprivacy@boundlesslearning.com.

Supplemental Privacy Statement

Effective Date: May 6TH, 2024

Introduction
Definitions
Personal Information Collected and Disclosed within the Last 12 Months
How long will Boundless Learning retain my personal information?
Sale or Sharing of Personal Information
Privacy Rights
How to Make a Request under the Right to Know and Right to Deletion
Changes to this Supplemental Privacy Statement
Contact Information

Introduction

This Privacy Statement explains Boundless Learning’s commitment to comply with California, Colorado, and Virginia law and applies to personal information collected in connection with providing services referenced on this site (the Services). Please read this Supplemental Privacy Statement in conjunction with the Privacy Notice that that linked here.

Definitions

Business Purposes includes the following:

Audit means auditing compliance with this Privacy Statement and applicable law. It also means auditing current interaction with a User and concurrent interactions with others, such as auditing access to particular content or features.
Debugging means identifying and repairing errors that impair existing intended functionality.
Evaluation means undertaking internal research to assess the effectiveness of the Services and for technological development and demonstration.
Maintenance and Improvement means undertaking activities to verify or maintain the quality or safety of the Services, and to improve, upgrade or enhance the Services.
Provide the Services means delivering and providing the Services, including, but not limited to, providing educational content and learning services, maintaining accounts, providing customer service, fulfilling orders and verifying customer information.
Security means detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and taking appropriate action for those responsible for that activity.
Short-Term Use means short-term, transient use related to a current interaction with a California resident, such as the contextual customization of ads shown as part of the same interaction. In Short-Term Use, the personal information is not disclosed to another third/ party and is not used to build a profile about a consumer or otherwise alter an individual consumer’s experience outside the current interaction.

Personal Information means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or their household. Categories of Personal Information include the following:

Identifiers means information used to identify a particular user, such as name, email address, username, IP address or another online identifier.
Customer Records means categories of customer personal information described in California Civil Code 1798.80, including name, address, and education information.
Protected Class Characteristics means characteristics identified under California and/or federal law such as race, ethnicity, national origin, disability, veteran, or military status.
Commercial Information means information about products or services purchased, used, or considered by a User.
Biometric Information means genetic or biological characteristics, such as information derived from fingerprint, iris, or retina scans.
Internet or Other Similar Network Activity means information generated from interaction with a website or the internet.
Geolocation Data means information about the geographic location from where a user accessed the Services.
Sensory Data includes audio, electronic and visual information.
Professional or Employment-Related Information means current or past job history.
Non-Public Education Information means personally identifiable Education Information that is not publicly available, as defined in the Family Educational Rights and Privacy Act (FERPA).
Inferences Drawn from Other Personal Information means inferences that create a profile about User’s preferences, characteristics, intelligence, abilities, and aptitudes.
Sensitive Personal Information means Personal information that reveals certain information about a consumer that are generally considered to be sensitive in nature, including:
1. Any communications you have with a third party (i.e., somebody outside our business)
2. Biometric data processed to identify an individual
3. Data about sexual orientation or sex life
4. Financial account details in a combination (for example card number and password) that gives access to an account
5. Genetic data
6. Government-issued numbers (such as a social security number or a number on a passport, or driver's license)
7. Health data
8. Philosophical or religious beliefs
9. Precise geolocation
10. Racial or ethnic origin
11. Union membership
12. Information from a known child

Personal Information Collected and Disclosed within the Last 12 Months

Within the last 12 months, Boundless Learning collected and disclosed categories of Personal Information through the Services, as follows:

Category	Source	Purpose	Disclosures to Third-Party Businesses
Identifiers	Users, Educators, and Institutions.	Provide the Services.	Service Providers, Educators, and Institutions for auditing, debugging, evaluation, maintenance, and improvement, providing the services, security, and short-term use. Law Enforcement in very limited circumstances, when required for security.
Customer Records	Users, Educators, and Institutions.	Audits, Evaluation, Provide the Services, Security, and Short-Term Use.	Service Providers, Educators, and Institutions for auditing, debugging, evaluation, maintenance, and improvement, providing the services, security, and short-term use. Law Enforcement in very limited circumstances, when required for security.
Protected Classes Characteristics	Users (only certain Career Success products)	Provide the Services.	Service Providers in order to provide the Services.
Commercial Information	Users	Audit, Evaluation, Maintenance and Improvement, Provide the Services, Security, Short-Term Use.	Service Providers, Educators, and Institutions for auditing, debugging, evaluation, maintenance, and improvement, providing the services, security, and short-term use. Law Enforcement in very limited circumstances, when required for security.
Biometric Information	Not applicable	Not applicable	Not applicable
Internet or Other Similar Network Activity	Users	Audit, Debugging, Evaluation, Maintenance and Improvement, Provide the Services, Security, and Short-Term Use.	Service Providers, Educators, and Institutions for auditing, debugging, evaluation, maintenance, and improvement, providing the services, security, and short-term use. Law Enforcement in very limited circumstances, when required for security.
Geolocation Data	Users (Country of location)	Audit, Debugging, Evaluation, Maintenance and Improvement, Provide the Services, Security, and Short-Term Use.	Service Providers for auditing, debugging, evaluation, maintenance, and improvement, providing services, security, and short-term use. Law Enforcement in very limited circumstances, when required for security.
Sensory Data	Users	Debugging, Evaluation, Maintenance and Improvement, Provide Services and Security.	Service Providers for debugging, evaluation, maintenance, and improvement, providing the services, and security.
Professional or Employment-Related Information	Users	Provide Services, Evaluation.	Service providers. Educators and Institutions to provide the Services and for evaluation.
Non-Public Education Records	Users, Educators, and Institutions.	Provide the Services. Evaluation.	Service providers. Educators and Institutions to provide the Services.
Inferences	Users, Student Users’ Instructors and Educational Institutions.	Provide the Services. Security. Evaluation.	Service Providers, Educators, and Institutions for providing Services, security, and evaluation. Law Enforcement in very limited circumstances, when required for security.
Sensitive Personal Information	Users, Student Users’ Instructors and Educational Institutions.	Provide the Services.	Service Providers, Educators, and Institutions for providing the Services.

How long will Boundless Learning hold onto my personal information?

We will keep each category of your personal information, as identified in the table above, only for as long as necessary to fulfil the purposes for which we are processing that category of your personal information and to meet legal and audit requirements, or as long as you continue to engage with the Services, or longer with your consent.

We do not sell or share, and have not sold or shared, any Personal Information collected through the Services within the last twelve (12) months.

Privacy Rights

Where Boundless Learning is a service provider to an educational institution, your request for access, deletion or correction of your education records or course data should be directed to your school or University. Boundless Learning cannot modify or delete education records or other records collected or processed by, or on behalf of, an educational institution unless directed to do so by the educational institution directly.

FERPA Privacy Rights. FERPA provides students with privacy rights and protection for educational personally identifiable information collected and processed on behalf of educational institutions receiving government funding from the U.S. Department of Education. FERPA provides students with rights to obtain from these educational institutions access to their educational records, as well as correction and amendment of their educational records, even though the CCPA does not apply to non-profit and public educational institutions.

Residents of California, Colorado and Virginia have certain rights related to their personal information collected by and on behalf of a business. Depending on where you live and Boundless Learning’s role in collecting and/or processing your personal information, you may have the following rights:

To request access to your information including a request to receive a written report of the categories and sources of information and/or the specific personal information held by Boundless Learning. Your request may be limited to information collected within the previous twelve (12) months;
to update or correct your personal information;
to ask that we remove or delete your personal information with some exceptions. For example, your request for deletion of your personal information may not interfere with an in-process transaction, investigation, or legal obligation;
to appeal a decision in response to a request regarding your personal information;
to withdraw your consent to the processing of your personal information;
to ask that we limit or restrict the processing of your personal information;
to ask that we transfer your information to another service provider;
to object to our processing of your personal information;
to opt out of automated processing which has a significant impact (such as profiling);
To opt out of the sale or sharing of their Personal Information or to require affirmation authorization to sell or share personal information if you are under the age of 16;
To limit the use or disclosure of sensitive personal information which is not necessary for the Services provided;
to complain to a regulator about the handling of your personal information; and
To not be discriminated against for exercising any of your rights related to your data.

Boundless Learning will not use or disclose your Sensitive Personal Information, collected through the Services, without your consent. Boundless Learning does not use or disclose Sensitive Personal Information for any purpose other than that which is necessary to perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services, or as otherwise permitted by law.

How to Make a Request to exercise your rights

To request access to a report of your data or deletion of your personal information, please send an email here for additional information: dataprivacy@boundlesslearning.com.

We will not require a California resident to set up an account in order to make a request or receive the requested information. In order to respond to a request, however, we must be able to reasonably verify, understand and fulfill the request. We will not be able to respond to the request if we are unable to verify identity or the authority to make the request. In conducting verification, we generally will use personal information previously collected by us. If the request is made on behalf of another individual, we may require additional verification and documentation of the individual’s authority to make the request. In responding to requests, we may limit the information provided for privacy and security reasons, as permitted by law.

We will process your request within the time required by the law or inform you of the basis for any unexpected delays.

To request correction of incorrect information associated with you, please contact dataprivacy@boundlesslearning.com.

For any other questions about your rights associated with your personal information or to appeal a decision in response to a request to exercise any of the above privacy rights, contact dataprivacy@boundlesslearning.com.

Changes to this Supplemental Privacy Statement

We may update this Privacy Statement from time to time in the same way that we update the Privacy Notice that is linked to it.

Contact Information

If you have any questions or comments about this Privacy Statement or your rights under California law, please contact us at dataprivacy@boundlesslearning.com.

Alice Chen