- Key Terms Used in this Policy
- Information that Saylor Academy collects from You
- Legal Basis for Processing Personal Information
- Your Rights to Your Personal Information
- Cookies and Tracking Technologies on the Saylor Academy Sites
- How Your Information is Used
- How Your Information is Shared
- How to Manage Your Personal Information
- Access and correct your Personal Information
- Restrict or object to the processing of Personal Information
- Delete account and Personal Information
- Data Retention
- Usage of Sites by Children & Personal Information
- Data Storage & Security
- Security Breach Notifications
- California Privacy Rights
- International Privacy Practices
- Contact Information
Key Terms Used in this Policy
Cookies are unique identifiers usually in the form of small data files placed on your device that send certain information about your activity on the Saylor Academy Sites or in an email communication back to Saylor Academy or the authorized third party that served the cookie. Saylor Academy or third parties may also use Flash cookies.
Saylor Academy Sites consists of all content and pages located within the www.saylor.org web domain, including its Moodle instance found at learn.saylor.org, its Discourse Forums and any Saylor Academy mobile applications.
Personal Information is information that specifically identifies you or that, when combined with other information, could be used to identify you, such as your name, location, IP address or other similar identifiers specific to you.
Tracking Technologies are web beacons, pixels, and similar technologies that are also unique identifiers used to track your online activity.
Information Saylor Academy Collects from You
Saylor Academy directly collects information when you:
- sign up for an Saylor Academy user account and create an Saylor Academy user profile;
- enroll and participate in online courses;
- send email messages to Saylor Academy (including messages to our help desk email: [email protected]);
- participate in user surveys; and
- participate in public forums, webinars, and other interactive experiences on the Saylor Academy Sites.
Saylor Academy also indirectly collects usage information about your visit to the Saylor Academy Sites, as explained in the section below titled Cookies and Tracking Technologies. Saylor Academy requires your Personal Information only in limited circumstances when you:
- sign up for an Saylor Academy user account (name, username, email address);
- earn and claim a course completion certificate so that Saylor Academy’s third-party vendor can authenticate your identity or prepare the certificate for use and display by you;
- participate in remote proctoring or other course facilitation processes (so that Saylor Academy’s third-party vendor can monitor and assess the integrity of your course activity); or
- request an academic transcript.
To the extent that Saylor Academy associates the information that Saylor Academy collects directly or indirectly with an individual (for example, you), the association is based on Personal Information in your account profile. You may voluntarily choose to share additional Personal Information on the Saylor Academy Sites, for example:
- in your Saylor Academy account profile (and you may display a limited or full profile to other Saylor Academy Sites users); or
- when participating in a course, forum, webinar, or other interactive experience on the Saylor Academy Sites (noting that in some cases, this information is shared with a third party that provides tools or other assistance for the Saylor Academy Sites or a course).
Saylor Academy encourages you to use discretion before voluntarily sharing additional Personal Information on the Saylor Academy Sites. (If you later choose to delete your Saylor Academy account, deletion of your Personal Information will be subject to the process and limits outlined below.)
Legal Basis for Processing Personal Information
- we need to perform a contract with you;
- you have given us consent to do so;
- the processing is in our vital or legitimate interests, such as properly identifying students for course certificates and transcripts, and it’s not overridden by your rights;
- to comply with applicable law
Your Rights to Your Personal Information
You have certain rights in relation to your Personal Information. You can access your Personal Information provided in your profile and confirm that it remains correct and up-to-date or choose whether or not you wish to receive material from us or some of our partners by logging into the Sites and visiting your user account. If you would like further information in relation to your rights or would like to exercise any of them, you may also contact us via [email protected]. If you reside or are located in the European Union (“EU”), you also have the right to request that we:
- provide access to any Personal Information we hold about you;
- prevent the processing of your Personal Information for direct-marketing purposes;
- update any Personal Information which is out of date or incorrect;
- delete any Personal Information which we are holding about you;
- restrict the way that we process your Personal Information;
- provide your Personal Information to a third party provider of services; or
- provide you with a copy of any Personal Information which we hold about you.
We try to answer every email promptly where possible, and provide our response within the time period stated by applicable law. Keep in mind, however, that there will be residual information that will remain within our databases, access logs and other records, which may or may not contain your Personal Information. Please also note that certain Personal Information may be exempt from such requests in certain circumstances, which may include if we need to keep processing your Personal Information to comply with a legal obligation. When you email us with a request, we may ask that you provide us with information necessary to confirm your identity.
Cookies and Tracking Technologies
- based on your cookie settings, Saylor Academy may track information indicating, among other things, which pages of the Saylor Academy Sites were visited, the order in which they were visited, when they were visited, and which hyperlinks and other user interface controls were used;
- Saylor Academy may log the IP address, operating system, and browser software (including mobile use and device type when you use Saylor Academy native mobile apps) you used when accessing the Saylor Academy Sites, and Saylor Academy may be able to determine from an IP address your Internet Service Provider and the geographic location of your point of connectivity; and
- Saylor Academy may track and collect information from emails that Saylor Academy sends to you, for example whether you opened the email or clicked on any links from the email.
- when necessary for system administration, security, and integrity to ensure the Saylor Academy Sites works properly for you. Without these technologies, the Saylor Academy Sites may not function correctly;
- to enable analytics, performance and functionality, to help Saylor Academy gather information about how visitors use the Saylor Academy Sites and monitor Saylor Academy Sites performance, and to enhance your experience by recognizing and remembering whether you have visited the Saylor Academy Sites before and may have any personal preferences; and
- to support marketing by enabling Saylor Academy to deliver content relevant to your interests on the Saylor Academy Sites and third-party Sites based on how you interact with Saylor Academy, its advertisements or content. Saylor Academy may use “first-party” cookies, which means cookies served by Saylor Academy, and also “third-party” cookies, which means cookies served by third parties that help Saylor Academy track this information.
You have some options for managing Cookies and other Tracking Technologies. These include:
- Modifying your browser settings: You should be able to control how and whether your web browser accepts Cookies by adjusting its privacy and security settings. The “help” feature of the menu bar on most browsers will tell you how to stop accepting new Cookies, how to receive notification of new Cookies, and how to disable existing Cookies. If you reject Saylor Academy’s Cookies, some functions and conveniences of the Saylor Academy Sites may not work properly.
- Opting-out of certain third-party tracking and advertising: Some of the third parties used by Saylor Academy for Cookies and Tracking Technologies offer the ability to opt-out from their tracking by following processes described on their websites. A list of some such third parties is maintained and available on this page: https://www.saylor.org/privacy-policy/third-parties. Saylor Academy is not responsible for the effectiveness of any third-party opt-out options.
How Your Information is Used
Saylor Academy uses information, including Personal Information, to carry out the following purposes:
- Operate and improve the Saylor Academy Sites – This includes creating and improving features that support the Saylor Academy community and enable Saylor Academy Sites usage at scale. This also may include personalizing the Saylor Academy Sites, so your learning experience is tailored to your interests and needs.
- Create, administer, provide, and teach courses – This includes creating and improving the delivery of our courses and programs on the Saylor Academy Sites. This may also include personalizing courses, so your learning experience is tailored to your interests and needs, and assessing your performance and awarding certificates.
- Offer and improve products and services – This includes enabling you to navigate the Saylor Academy Sites, to enroll and participate in courses and programs on the Saylor Academy Sites, to learn effectively in such courses and programs, and to purchase or obtain products and services on the Saylor Academy Sites such as Accredible Certificates or our exam proctor partner ProctorU.
- Develop and maintain the security and performance of the Saylor Academy Sites – This includes tracking Saylor Academy Sites outages and creating software solutions, detecting violations of the Honor Code and Terms of Service, and monitoring uses, misuses, and potential misuses of the Saylor Academy Sites.
- Communicate with you – This includes answering your questions, notifying you of Saylor Academy Sites maintenance and updates, marketing to you about course offerings, programs, news, and related products and services of Saylor Academy.
- Track Saylor Academy Sites usage against goals and mission – This includes performing analytics to evaluate access to and performance in courses and course-related products and services and to report aggregate usage information (not Personal Information) to business partners and external audiences.
- Exercise, enforce, and comply with legal rights and obligations – This includes responding to subpoenas, court orders, or other legal process; and investigating, preventing, or taking action regarding illegal activities, suspected fraud, security or technical issues, or to protect the rights, property, or safety of Saylor Academy, or others, and as otherwise required by applicable law.
Saylor Academy may also seek your consent for additional uses of information, including Personal Information, and will use it only for the purpose described to you. All use of Personal Information is subject to applicable law.
How Your Information is Shared
Saylor Academy shares information, including Personal Information, with third parties for the following purposes:
- With other learners in courses that you take and with other visitors to the Saylor Academy Sites, to create an interactive learning environment, support class participation, and share course information – This includes sharing comments, coursework, or other information or content that you submit to a portion of the Saylor Academy Sites, such as our Discourse Forums designed for viewing by other class members or for public communication. This also includes providing opportunities for you to communicate with other users who may have similar interests or educational goals, for instance, recommending specific study partners or connecting potential student mentees and mentors. In such cases, Saylor Academy may use all information collected about you to determine who might be interested in communicating with you, but will only provide others your username as you elect for it to be displayed (for clarity, unless part of the username you choose to display, we do not disclose your real name or email address for these purposes).
- With employers, government programs, institutions, or other enterprises that sponsor your enrollment in a course for training or other educational purposes – If an entity partners with Saylor Academy or otherwise sponsors your course participation, Saylor Academy will share information with the entity as needed to confirm your enrollment, participation, progress, and completion status in that course.
Saylor Academy may also seek your consent for additional disclosures of information, including Personal Information, and will share it only as described to you. In addition, Saylor Academy may share with the public and with third parties, including but not limited to researchers and business partners, information and Personal Information that is anonymized or aggregated in a manner that does not personally identify you.
How to Manage Your Personal Information
You can manage your Personal Information through learner features on the Saylor Academy Sites and requests to the Saylor Academy learner support team. Saylor Academy will provide support to the extent required by applicable law (for example, learners in the European Union) and more broadly when possible, as a courtesy in our sole discretion.
Access and correct your Personal Information
Much of your Personal Information is available in your Saylor Academy account. Your name, email address, and other identifiable profile information is editable through the profile settings in your Saylor Academy account except as noted below. Your account dashboard lists all current and archived courses in which you have enrolled and includes links to any course certificates you may have earned. The dashboard also contains copies of your answers and other participation and performance in courses. Please contact Saylor Academy learner support to access and update this or other information. Exceptions: Saylor Academy does not track or index every time or every place on the Saylor Academy Sites when or where a learner may volunteer Personal Information, so Saylor Academy may not be able to help you locate or manage all such instances. Saylor Academy encourages you to use discretion before volunteering Personal Information on the Saylor Academy Sites.
Restrict or object to the processing of Personal Information
If you want to manage emails and other communications to you, you may update your preferences in your Saylor Academy account dashboard, follow the steps described in links at the bottom of email messages, or contact Saylor Academy support. You may object to, or request that Saylor Academy stop, its use of your Personal Information for other purposes by contacting Saylor Academy. Please note that if you choose to restrict Saylor Academy’s ability to process Personal Information, and the processing is otherwise required to provide you with various services and products offered on the Saylor Academy Sites, you may not be able to establish or maintain a Saylor Academy user account or enroll for a courses or earn certificates.
Delete account and Personal Information
To request deletion of your Saylor Academy account and Personal Information, you should send us an email requesting deletion or cancellation. Because deletion on the Saylor Academy system is a permanent action and cannot be reversed, Saylor Academy may ask you to complete a process that aims to confirm your authority to manage the Saylor Academy account affected by your request. With respect to your Saylor Academy account, Saylor Academy will permanently:
- deactivate your Saylor Academy account;
- remove the active profile;
- anonymize or delete forum posts;
- delete certificates from provider site;
- retire your username; and
- remove you from Saylor Academy email lists.
With respect to your Personal Information, Saylor Academy will permanently delete your Saylor Academy account profile Personal Information from the Saylor Academy Sites. As noted above, to the extent that Saylor Academy associates the information that Saylor Academy collects directly or indirectly with an individual (for example, you), the association is based on Personal Information in your Saylor Academy account profile. By erasing the Personal Information in your Saylor Academy account profile, the remaining information about your activity on the Saylor Academy Sites will no longer be associated with you, except as noted below. These changes will be applied to data stores that are used for operation of the Saylor Academy Sites including for course administration and completion records. Exceptions: Deletion will not apply to historical activity logs or archives unless and until these logs and data naturally “age-off” the Saylor Academy system. Saylor Academy does not track or index every time or every place on the Saylor Academy Sites when or where a learner may volunteer Personal Information, so Saylor Academy may not be able to help you locate or manage all such instances. Saylor Academy encourages you to use discretion before voluntarily sharing your Personal Information on the Saylor Academy Sites. We will make reasonable efforts to delete information, however, Saylor Academy cannot always delete all records of past interactions and transactions. Saylor Academy will retain and use Personal Information as necessary to comply with its legal obligations, resolve disputes, enforce its agreements, and as otherwise permitted by applicable law.
Saylor Academy will retain your Personal Information for as long as your account is active or as needed to provide you with services; to maintain a record of your transactions for financial reporting, audit, and compliance purposes; and to comply with Saylor Academy’s legal obligations, resolve disputes, enforce its agreements, and as otherwise permitted by applicable law. Upon your request that Saylor Academy deactivate your account and delete your information we will follow the process described herein.
Usage of Sites by Children & Personal Information
Data Storage & Security
Saylor Academy may store information, including Personal Information, on its own servers and also on servers of companies that Saylor Academy hires to provide services. In each case, information may be stored in the United States and in other countries where Saylor Academy operates. If you are in the European Union, Switzerland, or other regions with laws governing data collection and use, you acknowledge that Saylor Academy may transfer, process and store your personal information in the United States and other countries, the privacy laws of which may be considered less strict than those of your region. Saylor Academy utilizes reasonable administrative, physical, and technical safeguards that attempt to reasonably and appropriately protect the confidentiality, integrity, and availability of the information that it collects, receives, stores, or transmits. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure; and therefore, Saylor Academy cannot guarantee its absolute security. While Saylor Academy works hard to ensure the integrity and security of its network and systems, Saylor Academy cannot guarantee that its security measures will prevent “hackers” or other unauthorized persons from illegally accessing or obtaining information.
Security Breach Notifications
If Saylor Academy learns of a security breach involving its copy of your Personal Information, Saylor Academy may attempt to notify you electronically so that you may take appropriate protective steps. By using the Saylor Academy Sites or providing Personal Information to Saylor Academy, you agree that Saylor Academy can communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Saylor Academy Sites. If a security systems breach occurs, Saylor Academy may post a notice on the Saylor Academy homepage (www.saylor.org) or elsewhere on the Saylor Academy Sites and may send an email to you at the email address associated with your Saylor Academy account. Depending on where you are located, you may have a legal right to receive notice of a security breach, involving your Personal Information, in writing.
California Privacy Rights
California Civil Code Section 1798.83 permits our visitors who are California residents to request certain information regarding our disclosure of personally identifiable information to third parties for their direct marketing purposes.
International Privacy Practices
Saylor Academy’s Sites are primarily operated and managed on servers located and operated within the United States. In order to provide our products and services to you, we may send and store your Personally Identifiable Information (also commonly referred to as personal data) outside of the country where you reside or are located, including to the United States. Accordingly, if you reside or are located outside of the United States, your Personally Identifiable Information may be transferred outside of the country where you reside or are located, including to countries that may not or do not provide the same level of protection for your Personal Information. We are committed to taking reasonable steps to protect the privacy and confidentiality of Personal Information when it is transferred. If you reside or are located within the EU and such transfers occur, we strive to take appropriate steps to provide the same level of protection for the processing carried out in any such countries as you would have within the EU to the extent feasible under applicable law.
If you have privacy concerns, have disclosed data you would prefer to keep private, or would like to access the Personal Information that Saylor Academy maintains about you, please contact us at [email protected].
Effective Date: July 22 2020