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Privacy

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Purpose

The purpose of this Privacy Policy is to describe how Creative Associates, Inc. (“Creative,” “us,” “we,” or “our”) collects, uses and shares information of visitors and users of our products and services through our U.S. online interfaces (e.g., websites and mobile applications) owned and controlled by us, including www.CreativeU.com (collectively referred to herein as the “Site”). Please note that the primary purpose of our Site and the Services is to allow you to enroll in and take online courses on a variety of topics.  Please read this notice carefully to understand what we do. If you do not understand any aspects of our Privacy Policy, please feel free to contact us. Your use of our Site is also governed by our Terms of Use.  By using the Site, Services or Courses you consent to the collection, use and disclosure of your information, in accordance with this Privacy Policy. 

What Information this Privacy Policy Covers

This Privacy Policy covers information we collect from you through our Site. Some of our Site’s functionality can be used without revealing any personal information, though for features or services such as the Online Courses, personal information is required. If you do not use these specific features or services on the Site, then the only information we collect will be “Non-Personal Information” (i.e., information that cannot be used to identify you). Non-Personal Information includes information such as the web pages that you have viewed. In order to access certain features and benefits on our Site, you may need to submit “Personally Identifiable Information” (i.e., information that can be used to identify you). Personally Identifiable Information can include information such as your name and email address, among other things. You are responsible for ensuring the accuracy of the Personally Identifiable Information you submit to Creative. Inaccurate information may affect your ability to use the Site, the information you receive when using the Site, and our ability to contact you. For example, your email address should be kept current because that is one of the primary manners in which we communicate with you.

What You Consent to by Using Our Site

Please understand that by submitting any Personally Identifiable Information to us, you consent and agree that we may collect, use and disclose such Personally Identifiable Information in accordance with this Privacy Policy and our Terms of Use, and as permitted or required by law. If you do not agree with these terms, then please do not provide any Personally Identifiable Information to us. If you choose not to provide us with any required Personally Identifiable Information, we may not be able to provide you with the services that can be offered on our Site.

What Information We Collect

We gather two types of information about users through the Site:

Non-Personal Information. When users come to our Site, we may track, collect and aggregate Non-Personal Information indicating, among other things, which pages of our Site were visited, the order in which they were visited, when they were visited, and which hyperlinks were “clicked.” We also collect information from the URLs from which you linked to our Site. Collecting such information may involve logging the IP address, operating system and browser software used by each user of the Site. Although such information is not Personally Identifiable Information, we may be able to determine from an IP address a user’s Internet Service Provider and the geographic location of his or her point of connectivity.

We also use or may use cookies and/or web beacons to help us determine and identify repeat visitors, the type of content and sites to which a user of our Site links, the length of time each user spends at any particular area of our Site, and the specific functionalities that users choose to use. Essentially, cookies are a user’s identification card for the Creative servers. Web beacons are small graphic files linked to our servers that allow us to track your use of our Site and related functionalities. Cookies and web beacons allow Creative to serve you better and more efficiently, and to personalize your experience at our Site. Cookies and web beacons are not used to retain Personally Identifiable Information. From time to time we may also use additional typical methods of collecting data.

You should be able to control how and whether cookies will be accepted by your web browser. Most browsers offer instructions on how to reset the browser to reject cookies in the “Help” section of the toolbar. If you reject our cookies, many functions and conveniences of this Site may not work properly.

Personally Identifiable Information. We collect Personally Identifiable Information that you provide to us when you register for an account, update or change information for your account, purchase products or services, complete a survey, sign-up for email updates or Online Courses, participate in our public forums, send us email messages, and/or participate in Online Courses or other services on our Site. We may use the Personally Identifiable Information that you provide to respond to your questions, provide you the specific course and/or services you select, send you updates about Online Courses offered by Creative or other Creative events, and send you email messages about Site maintenance or updates.

Account Registration. If you register for an account on our Site, you may be required to provide us with Personally Identifiable Information such as your name and email address

Updates. Creative may offer you the ability to receive updates either via email or by posting on portions of the Site only accessible to registered users. In order to subscribe to these services, you may be required to provide us with Personally Identifiable Information such as your name and email address.

Forums. Creative may offer public forums from time to time (the “Forums”) where you can share comments and thoughts. In order to participate in the Forums, you may be required to register with us and/or provide us with Personally Identifiable Information such as your name and email address. Personally Identifiable Information shall not include any information posted or sent by or to you via any public Forum. Please keep in mind that information you post or make available in Forums will be publicly available. Accordingly, you should be careful when posting any personal or sensitive information. Please also reference our Terms of Use for our Rules for Online Conduct and additional information about proper use of our Forums.

Participation in Online Courses. Creative offers users the opportunity to participate in an Online Course on or through the Site. If you desire to participate in a course, you will be asked to provide us with certain information necessary to conduct such a course. This information may include, among other things, your name and email address.

If you participate in an online course, we may collect from you certain learner-generated content, such as assignments and discussions in course forums. We also collect course data, such as student responses to in-video quizzes, standalone quizzes, exams and surveys.

Communications with Creative. We may receive Personally Identifiable Information when you send us an email message or otherwise contact us.

Third Party Sites. We may receive Personally Identifiable Information when you access or log-in to a third party site, e.g., Facebook, from our Sites. This may include the text and/or images of your Personally Identifiable Information available from the third party site.

Surveys. We may receive Personally Identifiable Information when you provide information in response to a survey operated by us.

Partner sites providing Online Course related tools and services to Creative users may collect nonfinancial individual level user data regarding the individual’s use of that partner site while engaged with such Online Course related activities, and the partner sites may share that data with Creative for the purpose of improving Creative’s services, the partner site’s services, and the individual’s education experience. This data includes information such as the amount of time spent on the partner site and pages viewed.

Third Party Credit Card Processing. Creative provides you with the ability to pay for Online Courses and other services using a credit card through a third party payment processing service provider. Please note that our service provider – not Creative – collects and processes your credit card information.

International Privacy Practices

Creative’s websites, including websites directed to residents in countries and jurisdictions outside of the United States, are operated and managed on servers located and operated within the United States and other countries. By using and accessing our Sites, residents and citizens of countries and jurisdictions outside of the United States agree and consent to the transfer to and processing of personal information on servers located in the United States and in other countries, and that the protection of such information may be different than required under the laws of your residence or location.

How We Use the Information

Non-Personal Information. We use Non-Personal Information to build higher quality, more useful services by performing statistical analyses of the collective characteristics and behavior of our users, and by measuring demographics and interests regarding specific areas of our Site. We may also use it for other business purposes.

Personally Identifiable Information. Except as set forth in this Privacy Policy, Creative will not disclose any Personally Identifiable Information we gather from you. In addition to the other uses set forth in this Privacy Policy, we may disclose and otherwise use Personally Identifiable Information as described below. We may also use it for research and business purposes, including improving and customizing the Site and the products and services we offer.

Updates. We use Personally Identifiable Information collected when you sign-up for our various email or update services to send you the messages in connection with the Site or an Online Course. We may also archive this information and/or use it for future communications with you.

Forums. To facilitate your use of the Forums, we use Personally Identifiable Information collected during your use of the Forums. In addition, we may publish this information via extensions of our Platform that use third-party services, like mobile applications. We also reserve the right to reuse Forum posts containing Personally Identifiable Information in future versions of the courses we offer, and to enhance future course offerings. We may archive this information and/or use it for future communications with you and/or your designee(s), and/or provide it to the institutions associated with the courses you have taken. We may also use or publish posts submitted on the Forums without using Personally Identification Information.

Participation in Online Courses. We use the Personally Identifiable Information that we collect from you when you participate in an Online Course through the Site for processing purposes, including but not limited to tracking attendance, progress, scores and completion of an Online Course. We may also share your Personally Identifiable Information and your performance in a given Online Course with the instructor or author of the course to assist with the creation, modification or operation of the course, and with the institution or institutions with which they may be affiliated. Also, we may archive this information and/or use it for future communications with you.

Identity Verification. For services that require identity verification, we use the Personally Identifiable Information that we collect for verifying your identity, and for authenticating that submissions made on the Site were made by you.

Communications with Creative. When you send us an email message or otherwise contact us, we may use the information provided by you to respond to your communication. We may also archive this information and/or use it for future communications with you.

Communications with Creative Business Partners. We may share your Personally Identifiable Information with University partners and other business partners of Creative so that Creative University partners and other business partners may share information about their products and services that may be of interest to you.

Research. We may share general course data (including quiz or assignment submissions, grades, and forum discussions), information about your activity on our Site, and demographic data from surveys operated by us with our University partners and other business partners so that our University partners and other business partners may use the data for research related to online education.

Disclosure to Creative Operations and Maintenance Contractors. We use various service providers, vendors and contractors (collectively, “Contractors”) to assist us in providing our products and services to you. Our Contractors may have limited access to your Personally Identifiable Information in the course of providing their products or services to us, so that we in turn can provide our products and services to you. These Contractors may include vendors and suppliers that provide us with technology, services, and/or content related to the operation and maintenance of the Site or the Online Course. Access to your Personally Identifiable Information by these contractors is limited to the information reasonably necessary for the contractor to perform its limited function for us.

Government Authorities, Legal Rights and Actions. Creative may share your Personally Identifiable Information with various government authorities in response to subpoenas, court orders, or other legal process; to establish or exercise our legal rights or to protect our property; to defend against legal claims; or as otherwise required by law. In such cases we reserve the right to raise or waive any legal objection or right available to us. We also may share your Personally Identifiable Information when we believe it is appropriate to investigate, prevent, or take action regarding illegal or suspected illegal activities; to protect and defend the rights, property, or safety of Creative, the Site, our users, customers, or others; and in connection with our Terms of Use and other agreements.

Disclosure to Acquirers. Creative may disclose and/or transfer your Personally Identifiable Information to an acquirer, assignee or other successor entity in connection with a sale, merger, or reorganization of all or substantially all of the equity, business or assets of Creative to which your Personally Identifiable Information relates.

External Links

We may use the Personally Identifiable Information collected from third party websites for internal purposes.  To the extent such Personally Identifiable Information contains images of you, you grant Creative a limited, non-exclusive right to use, reproduce, distribute, prepare derivative works of or publicity display such images and/or your likeness.  Such links to third party websites do not constitute an endorsement by Creative of the external websites, the content displayed therein, or the persons or entities associated.   You acknowledge that Creative is only providing these links as a convenience, and cannot be responsible for the content of such external web sites.

Confidentiality & Security of Personally Identifiable Information

We consider the confidentiality and security of your information to be of the utmost importance. We will use commercially reasonable efforts to keep your Personally Identifiable Information confidential and secure and will not share it with third parties, except as otherwise provided in this Privacy Policy, or unless we have good faith belief that such disclosure is necessary in special cases. Please note that we do not guarantee the security of Personally Identifiable Information, and there is some risk that an unauthorized third party may find a way to circumvent our security systems or that transmission of your information over the Internet will be intercepted. It is your responsibility to protect the security of your login information. Please note that e-mails and other communications you send to us through our Site are not encrypted.

Updating or Deleting Your Personally Identifiable Information

We maintain a procedure in order to help you confirm that your Personally Identifiable Information remains correct and up-to-date or choose whether or not you wish to receive material from us or some of our partners. 

You may unsubscribe from certain email communications by contacting us. You may also update your Personally Identifiable Information by logging into the Website and visiting your user account or profile page.  Keep in mind, however, that even after updates to your Personally Identifiable Information, we may maintain and store older versions of such information within our databases, access logs and other records. 

If you have any privacy-related questions, unresolved problems, or complaints you may contact us.

Changing Our Privacy Policy

Please note that we review our privacy practices from time to time, and that these practices are subject to change. Any change, update, or modification will be effective immediately upon posting on our Site. We will take reasonable steps to notify you of any material change to this Privacy Policy.  We will also change the effective date (located at the bottom of this page). Be sure to return to this page periodically to ensure familiarity with the most current version of this Privacy Policy. No Information from Children Under 13

Creative strongly believes in protecting the privacy of children.  This Site is not intended for children under the age of 13 and we will not knowingly collect Personally Identifiable Information from persons under 13 years of age. If we become aware that a child under 13 has provided us with personal information, we take steps to remove such information and terminate the child's account. Creative targets its Services and this Site to adults and not to children under 13.