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Aurora Institute

Privacy Statement

North American Council for Online Learning, Ltd., (trading as Aurora Institute) (“Aurora Institute”) is governed as a 501(c)(3) non-profit by organizationally approved bylaws. We ask you to review our Privacy Statement and adhere to our Terms of Use.

Last Updated: January 22, 2020

North American Council for Online Learning (“Aurora Institute,” “we,” “us,” or “our”) is a 501(c)(3) non-profit, non-governmental organization. Our headquarters’ address is 1934 Old Gallows Road, Suite 350, Vienna, VA 22182.  This Privacy Statement contains our commitment to our users (“you” or “your”) concerning your privacy and how Aurora Institute may use information you provide through our website, found at http://www.aurora-institute.org/, as well as all affiliated URLs and mobile applications (collectively, the “Site”), as well as information collected by other means such as e-mail or telephone.

 


Purpose of this Privacy Statement

This Privacy Statement aims to give you information on how Aurora Institute collects and processes your personally identifiable data or information (“Personal Information”) through your use of this website or Personal Information you provide us with or we collect online, via electronic communication, or otherwise.

It is important that you read this Privacy Statement together with any other privacy statement or fair processing notice we may provide on specific occasions when we are collecting or processing Personal Information about you so that you are fully aware of how and why we are using your Personal Information. This Privacy Statement supplements the other notices and is not intended to override them.

 


Children Under the Age of 16

Our Site is not intended for children under 16 years of age.  We do not knowingly collect Personal Information from children under 16.  If you are under 16, do not use or provide any information on the Site or on or through any of its features, register on the Site, use any of the interactive features of the Site or provide any information about yourself to us. If you believe we might have any information from or about a child under 16, please contact us at [email protected].

 


Information We Collect

As is true of most websites, we automatically collect some information about your computer or mobile device when you visit the Site.  For example, we may collect information about your IP address, web browser, Internet Service Providers (“ISPs”), referring and exit pages, operating systems, time and duration of visits to our pages, etc. (“Non-Identifying Information”).  This information is used to administer the Site, track usage, improve our services, and gather information about referring websites.  We may also collect information about your online activity.  This Non-Identifying Information is used only on an anonymous basis and is not used with, or linked to, any Personal Information.

We receive Personal Information from you when you register for an account on the Site, e-mail us or respond to any of our e-mails, connect or link to the Site via social networking sites, post in our Members Forum, or register for one of our events.  Personal Information collected may include:

  • Identity Data, which includes first name, last name, date of birth, organization, title and ethnicity.
  • Contact Data, which includes postal address, email address and phone number.
  • Participation Data, which includes details of your participation or involvement with Aurora Institute or any of its events or activities.
  • Transaction Data, which includes which includes membership registration and renewal, contact us form submission, webinar registration and newsletter sign up.
  • Technical Data, which includes unique device identifiers.
  • Usage Data, which includes information about how you use our Site and products and services.
  • Marketing and Communications Data, which includes your preferences in receiving marketing from us, your communication preferences and information in connection with the fulfilment of your request for our marketing information.

We do not collect or process any financial data such as bank or credit or debit card details. When an online payment is required from you, you will be directed to Authorize.net who will collected and process such data. You can find information on Authorize.net and how they process personal data at [https://www.authorize.net/payments/]

We collect and process “Special Categories” of Personal Information, such as your ethnicity, if you provide it voluntarily. Provision of this information by you is optional. Aurora institute requests that you identify your race or ethnicity to better inform us of the diversity of our audience, which helps us with event programming and resource development.

By providing details of your ethnicity, you consent to our processing of such information for such purpose. You can ask us to stop processing details of your ethnicity by contacting us.

You may choose not to provide some or all of the foregoing Personal Information to us, but, in general, some Personal Information about you is required for you to register for an account, ask us a question, or initiate other transactions on the Site.

 


If You Fail to Provide Personal Information

Where we need to collect Personal Information by law, or under the terms of a contract we have with you, or when we have to deal with your request or enquiries, and you fail to provide that Personal Information when requested, we may not be able to perform the contract we have or are trying to enter into with you or deal with your request or enquiries or provide you with any support you are seeking from us. In this case, we may have to cancel the contract or not provide you with the support you have requested or subscribed to or need from us but we will notify you if this is the case at the time.

 


Cookies

We, as well as our vendors who assist us with event organization, registration and scheduling (“Conference Vendors”), use cookies and similar technologies (such as device identifiers) to help us recognize you, analyze usage of the Site, and customize your experience.  “Cookies” are text files placed on a computer’s hard drive by a web server.  Most cookies we use are deleted from your hard drive at the end of the browser session (session cookies).  Other cookies remain on your computer to allow us to recognize you the next time you visit the website (long-term cookies).  Web browsers allow some control of most cookies through the browser settings.  You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our Site may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.

 


Purposes for Which We Collect and Use Personal Information and Lawful Basis

We have set out below, in a table format, a description of all the ways Aurora Institute uses Personal Information and Non-Identifying Information it collects, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

 


Lawful Basis

We may process your Personal Information on the following bases:

Legitimate Interest

“Legitimate Interest” means the interest of our organization in conducting and managing our business and affairs to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Information for our legitimate interests. We do not use your Personal Information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract

“Performance of contract” means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Legal Obligation

Complying with a legal obligation means processing your Personal Information where it is necessary for compliance with a legal obligation that we are subject to.

Note that we may process your Personal Information for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your Personal Information where more than one ground has been set out in the table below.

Purpose/Activity

Type of Personal Information

Lawful basis for processing

To open your account, to process and maintain your membership, enable purchases and process payments, and communicate with you

(a) Identity Data
(b) Contact Data
(c) Usage Data
(d) Transaction Data
(e) Marketing and Communications Data
(f) Participation Data

(a) Performance of a contract with you
(b) Legitimate interest

Assist you with registration for conferences, symposia, webinars and other events hosted by us or our associates

(a) Identity Data
(b) Contact Data
(e) Marketing and Communications Data
(f) Participation Data

(a) Performance of a contract with you
(b) Consent
(c) Legitimate interest

Enable you to share content with others through our Site

(a) Identity Data
(b) Contact Data
(c) Technical Data

(a) Performance of a contract with you
(b) Legitimate interest

Host our Site, authenticate your visits, provide customized content and information, and track your usage of the Site

(a) Identity Data

(a) Performance of a contract with you
(b) Legitimate interest

Conduct analytics to improve and enhance our Site

(a) Identity Data

(a) Performance of a contract with you
(b) Legitimate interest

Notify you about news and opportunities that may be of interest to you

(a) Identity Data
(b) Contact Data
(c) Marketing and Communications Data
(d) Participation Data

(a) Consent
(b) Legitimate interest

To send you marketing materials, newsletters or other information about educational developments and activities or to receive or participate in our blogs

(a) Identity Data
(b) Contact Data
(c) Marketing and Communications Data
(d) Participation Data

(a) Consent
(b) Legitimate interest

Enable us to comply with applicable law or regulatory requirements

(a) Identity Data
(b) Contact Data
(c) Marketing and Communications Data
(d) Participation Data

(a) Consent
(b) Compliance with the law

Conform with the requirements of the law, including national security or law enforcement requirements or prevention or detection of crime, or to comply with legal process served on us

(a) Identity Data
(b) Contact Data
(c) Marketing and Communications Data
(d) Participation Data

Compliance with the law

Protect our legal rights or property or of our members

(a) Identity Data
(b) Contact Data
(c) Marketing and Communications Data
(d) Participation Data

(A) Performance of contract ith you
(b) Legitimate interest

For any other purpose for which we obtain your permission.

To deal with any sale or re-organization/restructuring or dissolution of the whole or any parts of our business, assets or affairs.

Legitimate interest

How We Share Information

Except as otherwise provided herein, Aurora Institute will not share, sell or trade any Personal Information with third parties without your consent.  We assume that members are interested in distance education and online initiatives. Therefore, as a member we will provide you with information on products, services, and research that we feel have value to Aurora Institute’s membership.

Service Providers: We may share your Personal Information and/or Non-Identifying Information with our business associates who assist us in administering our services or our Site, including hosting providers, payment processors, and Google Analytics.  We also share Personal Information with our vendors who assist us with organizing our symposia, conferences, and other events.  We may also share Personal Information with our attorneys, accountants or other agents if it is reasonably necessary for them to perform services for us.

Future Business Transactions:  As our business is constantly changing, we may transfer your Personal Information as part of a merger, sale of assets, acquisition, etc.  Also, if any bankruptcy or reorganization proceeding is brought by or against us, all such information may be considered an asset of ours and may be sold or transferred to third parties to the extent permitted by applicable law.

Legal Authorities:  We may disclose any Personal Information or Non-Identifying Information about you if we are required to do so by law, or if we believe that such action is necessary to:  (1) fulfill a government request; (2) conform with the requirements of the law or legal process; (3) protect or defend our legal rights or property, including the Site; or (4) in an emergency to protect the health and safety of our users or the general public.

Commonly Owned Entities:  We may share some or all of your information with other companies under common ownership or control of Aurora Institute, which may include subsidiaries, corporate parents, or any other subsidiaries owned by a corporate parent in order to provide you better service and improve your experience.

Public Posts: Please note that if you share Personal Information in our Members Forum, that information is publicly available and is shared with all other Aurora Institute members.  We may, but are not required to, monitor public postings, and we are not responsible for the access, use or disclosure of any information that you post publicly in our forum.

Each of our employees, board of directors, and authorized members and users consent to, or acknowledge and accept, this Privacy Statement, and only authorized employees have access to our users’, visitors’ and members’ Personal Information.  We will always give you an opportunity to choose to opt out before your Personal Information is disclosed to a third party other than an agent or a third-party service provider doing work at our direction, or as otherwise disclosed in this Privacy Statement.

We require all third parties to respect the security of your Personal Information and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Information for their own purposes and only permit them to process your Personal Information for specified purposes and in accordance with our instructions.

 


UNITED STATES SITE AND INTERNATIONAL DATA TRANSFERS

The Site is hosted in the United States. Personal Information that is voluntarily provided on or via our Site or online, via electronic communication, or otherwise to us, will be maintained or accessed in servers or files located in the United States, which the European Commission has not deemed to provide “adequate” privacy safeguards. If you do not consent to having your Personal Information processed and stored in the United States, please do provide it to us or visit our Site. By voluntarily providing your Personal Information to us, including via our Site, you consent to its transfer, processing and storage in the United States.

Any Personal Information you may provide to us may be shared with third parties who are based outside the United Kingdom and the European Economic Area in connection with support services provided to us.

 


Limitations on use of Personal Information

The Personal Information we collect is used primarily for purposes of helping you engage with other educators and like-minded organizations, as discussed above.  We only collect and retain Personal Information that is relevant to the purposes for which it is collected, and we will not use it in a way that is materially different from those purposes unless such use has been authorized by you.  We will take reasonable steps to ensure that Personal Information is reliable for its intended use, accurate, complete and current, which may include occasionally contacting you to determine that your Personal Information is still current.

 


Data Retention

We will only retain your Personal Information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal (statutory or contractual), accounting, any legitimate administrative or operational purposes, your requirements, or reporting requirements. In determining Personal Information retention periods, we take into consideration local laws, contractual obligations, our legitimate business interests and your expectations and requirements.

Unless you object to our retention of your Personal Information, we may retain your Personal Information for a period of up to [12] months following our last communication with you or such other longer period necessary to satisfy any legal, accounting or any legitimate administrative or operational purposes.

If you request that we stop sending you marketing materials, we will continue to keep a record of your contact details and appropriate information to enable us to comply with your request not to be contacted by us.

When it is no longer necessary to retain your Personal Information, we will securely delete or in some circumstances we may anonymise your Personal Information (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

 


Legal Rights Applicable to United Kingdom and the European Economic Area

Under the relevant privacy laws of the European Economic Area (including European Union’s General Data Protection Regulation) in respect of your Personal Information you may have a number of important rights. In summary, those may include rights to:

  • access to your Personal Information and to certain other supplementary information that this Privacy Statement is already designed to address,
  • require us to correct any mistakes in your Personal Information which we hold,
  • require the erasure of Personal Information concerning you in certain situations,
  • receive the Personal Information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations,
  • object at any time to processing of Personal Information concerning you for direct marketing,
  • object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you,
  • object in certain other situations to our continued processing of your Personal Information, and
  • otherwise restrict our processing of your Personal Information in certain circumstances.

If you would like to exercise any of those rights, please contact:

Full name of legal entity: North American Council for Online Learning, Ltd
Email address: [email protected]

Postal address: 1934 Old Gallows Road
Suite 350
Vienna, VA 22182
(703) 752-6216
Fax: (703) 752-6201

When contacting us, please ensure that you:

  • let us have enough information to identify you,
  • let us have proof of your identity and address (a copy of your driving license or passport and a recent utility or credit card bill), and
  • let us know the information to which your request relates.

 


How to Access or Update Your Information

Members may request to view, edit, or have their Personal Information deleted (including requesting confirmation of whether we process Personal Information about you) by contacting Aurora Institute at the physical and electronic addresses listed below under “Contact Us”.  We try to respond to all legitimate requests within 30 days. Occasionally it could take us longer than 30 days if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.  In some circumstances, if warranted, we may request confirmation of your identity and may charge a reasonable fee for access to such information or refuse your request if your request is clearly unfounded, repetitive or excessive.

 


Links to Other Sites

Aurora Institute does not have control of content, accuracy, or copyrights to sites that are linked outside of the Aurora Institute web site. We do not endorse, recommend, or authenticate the accuracy of information at linked sites. They are provided as an informational or service resource to Aurora Institute members and users of the web site and individuals must evaluate linked sites for any usefulness or purpose.  This Privacy Statement does not apply to your use of third party websites, and Aurora Institute is not responsible for the information practices on such linked sites.  We recommend that you carefully read the policies, including terms and conditions of use, of each site that you visit.

 


Managing “Do Not Track” Signals

Some browsers have a Do Not Track (“DNT”) feature that lets you tell websites that you do not want your online activities tracked.  When you choose to turn on the DNT setting in your browser, your browser sends a special signal to websites, ad networks, plug-in providers, and other web services you encounter while browsing to stop tracking your activity via cookies or other tracking technologies.  Our Site does not respond to DNT signals at this time.

 


Additional Provisions Applicable to California Residents

If you are a California resident under 18 years of age and have an account with us or have linked to us through social media, you can request that we remove content or information that you have posted to our website or other online services under our control.  Note that fulfillment of the request may not ensure complete or comprehensive removal (e.g., if the content or information has been reposted by another member).  To request removal of content or information, please e-mail or call us using the contact information below.

 


Jurisdiction

The contents of our Site are intended for the sole use of Aurora Institute’s members, associates, and guests for the purposes of promoting the goals, services, and products of Aurora Institute. Disputes or litigation resulting from use of our Site will be under the jurisdiction of state or federal courts located in the Commonwealth of Virginia, without regard to choice of law principles.

 


Security

We want you to feel confident about using our Site to register with us and use our services.  We are committed to protecting the Personal Information we collect.  While no website can guarantee security, we use commercially reasonable physical, technical and administrative safeguards to assist us in preventing unauthorized access, use and/or disclosure of your Personal Information. We have put in place procedures to deal with any suspected personal information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

 


Change of Purpose

We will only use your Personal Information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose to do so.

Please note that we may process your Personal Information without your knowledge or consent where this is required or permitted by law.

 


Changes to this Privacy Statement

Aurora Institute may from time to time make changes to this Privacy Statement to reflect changes in legal or regulatory obligations or changes in the manner in which we deal with Personal Information.  We will post any revised version of this Privacy Statement on the Site.  Any changes will be effective on the date stated in the revised Privacy Statement.  If we significantly change how we handle your Personal Information, we may provide more prominent notice or obtain your consent as required by law.  If you do not wish to accept the changes, you should cease using the Site.  Your continued use of the Site after we have posted a revised Privacy Statement indicates your agreement to the revisions.

 


Contact Us

We look forward to any comments, suggestions, recommendations, or questions you might have about our policies. You may contact us by email, phone, fax, or mail at the following:

Aurora Institute
1934 Old Gallows Road
Suite 350
Vienna, VA 22182
(703) 752-6216
Fax: (703) 752-6201
Send an email to Aurora Institute membership services at:

[email protected]
https://aurora-institute.org/