Pearson Online Learning Services Privacy Statement

Pearson Online Learning Services Privacy Statement
Effective Date: 2019-12-23

Who is Pearson Online Learning Services?

Pearson Online Learning Services is a division of Pearson Education, Inc. (“Pearson”, “we” or “us”) that partners with George Washington University (“Institution”) to provide this site and support select online educational programs (“Programs”). Pearson 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 Pearson collects, uses, maintains and discloses information collected in connection with the Programs. This Privacy Statement applies only to Pearson services and Pearson 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 Pearson collect through the Programs? How does Pearson 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 and text messages at any time by telling us in a phone call or following the opt-out instructions contained in the text message. You are not required to provide your cell phone number or consent to receiving phone or text messages in order to receive information about the Programs.

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

De-Identified Data. Pearson 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, Pearson will not attempt to re-identify such de-identified data.

Does Pearson use personal information for marketing purposes?

Pearson may use personal information in order to provide messages and information about eligible educational programs, products and services that may be available from the Institution, Pearson, 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 Pearson 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 Pearson 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 Pearson 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. 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.

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 you are working with regarding your Program of interest.

Do Pearson 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. Pearson 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. Pearson 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. Pearson 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 NevadaDesignatedRequest@pearson.com.

California Supplemental Privacy Statement

If you are a California resident, please also read our Supplemental Privacy Statement for California Residents, which provides information about your California privacy rights and additional information required by California law.

Is this Privacy Statement subject to change?

This Privacy Statement may be revised from time to time through an updated posting. Pearson 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 Pearson reasonably believes the updates involve material changes to the collection, protection, use or disclosure of your personal information, Pearson will endeavor to notify you by email or another appropriate way.

What is Pearson’s contact information?

To contact us about this Privacy Statement, please email us at mpm@onlinegwu.com.

Supplemental Privacy Statement for California Residents

Effective Date:  January 1, 2020

Introduction

This Privacy Statement supplements the Pearson Online Learning Services Privacy Policy.  It explains Pearson’s commitment to comply with California law and applies to personal information of California residents collected in connection with providing services referenced on this site (the Services).  Please read this Supplemental Privacy Statement for California Residents in conjunction with our Privacy Policy.

Definitions

Business Purposes includes the following:

  • Audit means auditing compliance with this Privacy Statement, our Privacy Policy, relevant contracts/terms and applicable law. It also means auditing current interaction with a User and concurrent interactions with others, such as auditing number of ad impressions or 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-related 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 information 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 an individual or otherwise alter an individual’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 California resident or their household.

User means an individual who uses this site or the Services.

Personal Information Collected and Disclosed within the Last 12 Months

Within the last 12 months, we may have collected and disclosed categories of Personal Information collected in connection with the Services, as follows:

  1. Identifiers
    • Description. Information used to identify a User, such as name, email address, user name, IP address or other online identifier.
    • Collection. Yes.
      • Source. Users. Online Education Directories (where a User has requested degree program or Educational Institution information from such a Directory).  Educational Institutions.
      • Collection Business Purpose. Provide the Services.
    • Disclosure to Third Parties. Yes.
      • Categories of Third Parties. Service Providers, Educational Institutions.
      • Disclosure Business Purpose. Audit, Debugging, Evaluation, Maintenance and Improvement, Provide the Services, Security and Short-Term Use.
  2. Customer Records
    • Description. Categories of customer personal information described in California Civil Code 1798.80, including name, address and education information.
    • Collection. Yes.
      • Source. Users.
      • Collection Business Purpose. Audit, Evaluation, Provide the Services, Security, Short-Term Use.
    • Disclosure to Third Parties. Yes.
      • Categories of Third Parties. Service Providers, Educational Institutions.
      • Disclosure Business Purpose. Audit, Evaluation, Provide the Services, Security, Short-Term Use.
  3. Protected Class Characteristics
    • Description. Protected classifications characteristics under California or federal law, such as race, ethnicity, national origin, disability, veteran or military status
    • Collection. Yes.
      • Source. Users.
      • Collection Business Purpose. Provide the Services.
    • Disclosure to Third Parties. Yes.
      • Categories of Third Parties: Service Providers, Educational Institutions.
      • Disclosure Business Purpose. Provide the Services.
  4. Commercial Information
    • Description. Information about products or services purchased, used or considered by a User.
    • Collection. Yes.
      • Source. Users. Online Education Directories (where a User has requested degree program or Educational Institution information from such a Directory).  Educational Institutions.
      • Collection Business Purpose. Audit, Evaluation, Maintenance and Improvement, Provide the Services, Security, Short-Term Use.
    • Disclosure to Third Parties. Yes
      • Categories of Third Parties. Service providers, Educational Institutions.
      • Disclosure Business Purpose. Audit, Evaluation, Maintenance and Improvement, Provide the Services, Security, Short-Term Use.
  5. Biometric Information
    • Description. Genetic or biological characteristics, such as information derived from fingerprint, iris or retina scans.
    • Collection. No.
    • Disclosure to Third Parties. No.
  6. Internet or Other Similar Network Activity
    • Description. Information from interaction with a website and the internet.
    • Collection. Yes.
      • Source. Users.
      • Collection Business Purpose. Audit, Debugging, Evaluation, Maintenance and Improvement, Provide the Services, Security and Short-Term Use.
    • Disclosure to Third Parties. Yes.
      • Categories of Third Parties. Service Providers. Educational Institutions.
      • Disclosure Business Purpose. Audit, Debugging, Evaluation, Maintenance and Improvement, Provide the Services, Security and Short-Term Use.
  7. Geolocation Data
    • Description. Information about the geographic location from where a user accessed this site.
    • Collection. Yes.
      • Source. Users.
      • Collection Business Purpose. Audit, Debugging, Evaluation, Maintenance and Improvement, Provide the Services, Security and Short-Term Use.
    • Disclosure to Third Parties. Yes
      • Categories of Third Parties. Service Providers.
      • Disclosure Business Purpose. Audit, Debugging, Evaluation, Maintenance and Improvement, Provide the Services, Security and Short-Term Use.
  8. Sensory Data
    • Description. Sensory data includes audio, electronic and visual information.
    • Collection. Yes.
      • Source. Users.
      • Collection Business Purpose. Debugging, Evaluation, Maintenance and Improvement, Provide the Services and Security.
    • Disclosure to Third Parties. Yes.
      • Categories of Third Parties. Service providers, Educational Institutions.
      • Disclosure Business Purpose. Debugging, Evaluation, Maintenance and Improvement, Provide the Services and Security.
  9. Professional or Employment-Related Information
    • Description. Current or past job history
    • Collection. Yes.
      • Source. Users.
      • Collection Business Purpose. Provide the Services, Evaluation.
    • Disclosure to Third Parties.
      • Categories of Third Parties. Service providers.  Users, Educational Institutions.
      • Disclosure Business Purpose. Provide the Services, Evaluation.
  10. Non-Public Education Information
    • Description. Education Information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 USC 1232g, 34 CFR, Part 99 (FERPA).
    • Collection. Yes.
      • Source. Users, Educational Institutions.
      • Collection Business Purpose. Provide the Evaluation.
    • Disclosure to Third Parties.
      • Categories of Third Parties. Service providers, Educational Institutions.
      • Disclosure Business Purpose. Provide the Services.
  11. Inferences Drawn from Other Personal Information
    • Description. Inferences that create a profile about User’s preferences, characteristics, intelligence, abilities and aptitudes.
    • Collection. Yes.
      • Source. Users, Educational Institutions.
      • Collection Business Purpose. Provide the Services. Evaluation.
    • Disclosure to Third Parties.
      • Categories of Third Parties. Service providers, Educational Institutions.
      • Disclosure Business Purpose. Provide the Services, Security.

Sale of Personal Information

We do not monetize Personal Information.  We do not sell, and have not sold, within the last twelve (12) months, any Personal Information collected through the Services, except to the extent that third party targeted advertising cookies and related technologies are ultimately determined to be a “sale” for purposes of the California Consumer Privacy Act.  The following categories of personal information may have been collected and shared through such cookies and related technologies during the past 12 months within the digital advertising ecosystem:   Identifiers (limited to a numeric identifier, such as an IP address) Commercial Information, Internet or Similar Network Activity, Geolocation Data and Inferences drawn from other Personal Information.

Privacy Rights

Under the California Consumer Privacy Act (CCPA), California residents have certain rights related to their personal information collected by and on behalf of a business subject to the law.   Students also have certain privacy rights under U.S. Family Educational Rights and Privacy Act (FERPA).

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.

CCPA Right to Know. California residents may request a business to disclose the following information about the business’ collection and use of their personal information over the past twelve (12) months, provided that such requests are made no more than twice within a twelve (12) month period:

  • The categories of personal information collected;
  • The categories of sources for the personal information collected;
  • The business or commercial purpose for collecting, and, if applicable, selling, personal information;
  • The specific pieces of personal information collected;
  • If the personal information has been disclosed, the categories of personal information disclosed and the categories of third parties receiving the personal information;
  • If the personal information has been sold, the categories of personal information sold and the categories of third parties to whom the personal information was sold.

CCPA Deletion Right.  California residents may request a business to delete the personal information that the business collected and has been retained by the business or its service providers.  This right is limited, and the business may deny a deletion request if it is necessary for the business or a service provider to maintain the personal information in order to:

  • Complete the transaction for which the personal information was collected, provide a good or service requested by the individual, or reasonably anticipated within the context of a business’ ongoing business relationship with the individual, or otherwise perform a contract between the business and the individual.
  • 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 individual to exercise his or her right of free speech, or exercise another right provided for by law.
  • Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code;
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest, where the businesses’ deletion of the information is likely to render impossible or seriously impair the achievement of such research, if the individual has provided informed consent;
  • Enable solely internal uses that are reasonably aligned with the expectations of the individual based on the individual’s relationship with the business;
  • Comply with a legal obligation;
  • Otherwise use the individual’s personal information, internally, in a lawful manner that is compatible with the purpose for which the individual provided the information.

CCPA Right to No Sale of Personal Information.  A California resident has the right to opt-out of the sale of their Personal Information by a business subject to the CCPA.  In addition, a business subject to the CCPA must have affirmative authorization in order to sell the Personal Information of a California resident who it knows is under the age of 16.  As explained above, we do not sell Personal Information, except to the extent that third party advertising cookies are ultimately determined to be a “sale” under the California Consumer Privacy Act.  Additional information is available on our  Do Not Sell My Info page, including information about how to manage or block these cookies. We do not engage in targeted advertising to individuals who we know are under the age of 16.

CCPA Right to Non-Discrimination. A business subject to the CCPA may not discriminate against a California resident for exercising any of their CCPA privacy rights.

How to Make a Request under the Right to Know and Right to Deletion

Beginning January 1, 2020, California residents may submit a Right to Know and Right to Deletion request to us by using the online form or calling the toll-free phone number on the Pearson Rights Request page.

Note:  Please direct any access, deletion or correction requests related to education records and to course data directly to the educational institutions.  As a service provider, POLS cannot delete or modify education records or other records collected or processed for, or on behalf of, an educational institution, unless it is directed to do so by the educational institution.

Under California law, we will only respond to verifiable requests that are made either: (a) by a California resident; (b) by a person registered with the California Secretary of State who a California resident has authorized to act on their behalf; or (c) by a parent or legal guardian, if the California resident is a minor.

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.

Our goal is to respond to requests within 45 days.  If we need another 45 days, we will advise the requester within 45 days after receiving the request.

We will not charge a fee to respond to a request, unless it is excessive, repetitive or unfounded.  If a fee will apply, we will advise the requester before completing the request, explain why a fee applies and provide an estimate of the fee.

Changes to this California Supplemental Privacy Statement

We may update this Privacy Statement from time to time in the same way that we update our Privacy Policy.

Contact Information

If you have any questions or comments about this Privacy Statement, please contact us at mpm@onlinegwu.com.