California Privacy Notice and Policy


Effective Date: September 29, 2021

This is the PRIVACY NOTICE AND POLICY FOR CALIFORNIA RESIDENTS for the Wake Forest website (https://professionalcourses.wfu.edu; the “Site”) which is operated by Kaplan North America, LLC (“KNA”) on behalf of Wake Forest (both Wake Forest and KNA referred collectively as, “we,” “us,” or “our”) and applies solely to residents of the State of California (“consumers” or “you”).

California Consumer Privacy Act (“CCPA”)

Any terms defined in the CCPA and the proposed regulations have the same meaning when used in this disclosure.

Information We Collect

We collect offline and online personal information that you provide us. Personal information means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. (“personal information”, “PI”).

We have collected the following categories of personal information within the last twelve (12) months and may use or disclose the personal information for one or more business or commercial purposes:

Category Examples of Personal Information Categories of Sources From Which the PI Is Collected Business or Commercial Purpose Categories of Third Parties and Service Providers with Whom Your PI Is Shared
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.
  • From you
  • From your devices when you interact with our websites or mobile apps
  • From Kaplan Professional employees when you interact with them and provide PI
  • To fulfill or meet the reason for which the information is provided.
  • To provide the services you requested
  • To evaluate your potential fit for employment opportunities.
  • Manage payments, fees and charges.
  • For testing, analytics, research, analysis, and product development, including to develop and improve our website, products, and services.
  • To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
  • To personalize your website experience and to deliver content and product and service offerings relevant to your interests, through our website, third- party sites, and via email or text messages.
  • To provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • Co-Marketing Partners
  • Advertising Platforms
  • Social Media Platforms
  • Analytics Providers
  • Marketing Companies
Personal information categories listed in 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. Some personal information included in this category may overlap with other categories.
  • From you
  • From your devices when you interact with our websites or mobile apps
  • From Kaplan Professional employees when you interact with them and provide PI
  • To fulfill or meet the reason you provided the information
  • To evaluate your potential fit for employment opportunities.
  • To carry out our obligations and enforce our rights arising from any contracts entered between you and us, including for billing and collections
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our website users is among the assets transferred.
  • To provide you with information, products or services that you request from us.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
 
Protected classification characteristics under California 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).
  • From you
  • From your devices when you interact with our websites or mobile apps
  • From Kaplan Professional employees when you interact with them and provide PI
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations, such as tracking data on applicants' protected class status for use in measuring the success of our EEO or affirmative action efforts.
  • To carry out our obligations and enforce our rights arising from any contracts entered between you and us.
  • To evaluate your potential fit for employment opportunities.
 
Commercial information Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
  • From you
  • From your devices when you interact with our websites or mobile apps
  • From Kaplan Professional employees when you interact with them and provide PI
  • To carry out our obligations and enforce our rights arising from any contracts entered between you and us for product or services purchased.
  • To provide you with information, products or services that you request from us.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
 
Biometric information Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, other physical patterns and health, or exercise data.      
Internet or other similar network activity Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.
  • From you when you interact with our website
  • To help maintain the safety, security, and integrity of our website, services, databases and other technology assets, used to support our business.
  • For testing, research, analysis, and product development, including to develop and improve our website and services.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
 
Geolocation data Physical location or movements.
  • From a GPS enabled device
  • To monitor the location of vehicles.
 
Sensory data Audio, electronic, visual, thermal, olfactory, or similar information.
  • From you
  • From observation
  • Responding to your audio or voice recordings.
 
Professional or employment-related information Current job history or performance evaluations, Professional Membership information, certifications, licenses or credentials
  • From you
  • From recruiters
  • To evaluate your potential fit for employment opportunities.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
 
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 or prior student maintained by an educational institution or party acting on its behalf, such as grades, transcripts.
  • From you
  • From an education institution or provider
  • To evaluate your potential fit for employment opportunities.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
 
Inferences drawn from other personal information Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
  • From observations
  • To provide career development feedback and guidance to employees.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
 

Sharing Personal Information

We may disclose your personal information to a third party, our affiliates, or agent, service providers for a business purpose as described above. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to keep that personal information confidential and not use it for any purpose except for fulfilling requirements and services being performed under contract.

We do not sell personal information and in the preceding twelve (12) months, we have not sold any personal information.

Your Rights

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes those rights.

Request to Access Your Personal Information (Right to Know)

You have the right to request that we disclose certain information to you about our collection, use, and disclosure of your personal information over the past 12 months.

As part of our verification process of your request we ensure reasonable measures are in place to detect fraudulent requests and prevent unauthorized access to your personal information. We are required to verify your identity, and the identity of your authorized agent, if the request is submitted via an agent by associating the information provided in the request to any personal information previously collected by us or use a third-party identity verification service.

Once we confirm your verifiable request we will disclose to you, consistent with your request:

  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business purpose for collecting that personal information.
  • The categories of third parties with whom we share that personal information.
  • Specific pieces of personal information we collected about you, if requested.

Requests to Delete Your Personal Information (Right to Request Deletion)

You have the right to request that we delete any of your personal information that we have collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

If we deny your deletion request, we will notify you in writing of the reason.

Submitting Request to Know or Delete

To exercise the rights described above, you can contact us by submitting your request by either:

Only you or your authorized agent may make a verifiable consumer request related to your personal information. If you use an authorized agent to submit a request on your behalf, we may require that you (1) provide the authorized agent written permission to do so, and (2) provide a copy of the authorization or provide a copy of a power of attorney that complies with California Probate Code sections 4000 to 4465 so that we can verify the identity of the authorized agent.

In verifying requests, we employ reasonable measures to detect fraudulent requests and prevent unauthorized access to your personal information. To meet our obligations, we are required to verify your identity, and the identity of your authorized agent, if the request is submitted via an agent, by associating the information provided in your request to personal information previously collected by us.

If we suspect fraudulent or malicious activity on or from the password-protected account, we may decline a request or request that you provide further verifying information.

You may only make a verifiable consumer request twice within a 12-month period. The verifiable consumer request must:

  • Provide sufficient information that allows us to verify you are the person about whom we collected personal information and, if applicable, provide necessary documentation about your authorized agent.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify your identity or authority to make the request.

Responding to Requests

Upon receiving your request to know or a request to delete, we will process your request or notify you if the request requires an extension or will be denied. If we only comply with your response in part, we will explain the reasons why. We attempt to process requests within 45 days after receipt. If we require additional time beyond 45 days, we will inform you of the reason and the extension period.

If you have an account with us, we may deliver our response to that account. If you do not have an account with us, we will deliver our response by mail or electronically, at your option.

Generally, we do not charge a fee to process or respond to your requests. However, if we determine that a request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Financial Incentives

We offer gift cards, sponsor contests and sweepstakes to incent individuals to provide their personal information, which we then use for marketing purposes. You must opt-in to receive the incentive and will have the right to subsequently opt-out.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights.

“Shine the Light Law”

While we do not provide your personal information to third parties for their use in marketing, under California law, California residents have the right to opt-out of such use of your personal information if it occurred.

Changes to this Privacy Notice and Policy

We reserve the right to amend this privacy notice and policy at our discretion and at any time. When we make changes to this privacy notice and policy, we will notify you through a notice on our website homepage.

Contact Information

If you have any questions or comments about this Privacy Notice & Policy the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, or need this disclosure in another format, please do not hesitate to contact us at: kp.dataprivacy@kaplan.com.