PRIVACY POLICY – “Wharton White Label” Wharton Online Professional Ed
Wharton Online Professional Education offers courses via online platforms. We care about the confidentiality and security of your personal information, and we will use commercially reasonable effortsto keep your Personal Information secure, in compliance with this Privacy Policy."Personal Information" is defined below. As used in this Privacy Policy, "we," "us," and "our" refer to Wharton Online Professional Education.
PRIVACY POLICY
This Privacy Policy applies to information that we collect through the Wharton Online Professional Education site (the "Site," which consists of all content and pages
located within the whartononline.upenn.edu web domain), as well as information that
we may collect from you in other ways (for example, information that you may provide
to us via email, mail, phone, fax, social media, or other means). In addition, please note
that your education records are protected by the Family Educational Rights and Privacy
Act ("FERPA") to the extent FERPA applies.
USERNAMES AND POSTINGS
Comments or other information posted by you to our forums, wikis, or other areas of
the Site designed for public communications or communications among registered
class members may be viewed and downloaded by others who visit the Site. For this
reason, we encourage you to use discretion when deciding whether to post to those
forums (or to other public or classwide areas) any information that can be used to
identify you.
CONSENT TO PROCESSING OUTSIDE HOME COUNTRY
By using our Site, or providing information to us, you understand and affirmatively
consent to the collection, use, disclosure, and retention of information for the purposes
set forth in this Privacy Policy and the Wharton Online Professional Education
Terms of Service. You hereby consent to the collection, use, disclosure, and retention by
us of your Personal Information as described under this Privacy Policy, including but
not limited to the transfer of your personal data between us and Participants, as
defined in the Terms of Service. For further certainty, any consent relating to a right to
transfer information referred to in this paragraph shall be deemed to include your
consent to the transfer of the applicable Personal Information to a jurisdiction which
may provide a different level of privacy protection from that available in your own
country.
If you do not agree with these terms, then please do not access, browse, or register for
the Site. If you choose not to provide us with certain information required to provide
you with various services offered on our Site, you may not be able to establish a user
account and we may not be able to provide you with those services.
PERSONAL INFORMATION
As used in this Privacy Policy, "Personal Information" means any information about
yourself that you may provide to us when using the Site, such as when you sign up for a
user account or enter into a transaction through the Site, which may include (but is not
limited to) your name, contact information, gender, date of birth, and occupation.
INFORMATION WE COLLECT AND HOW WE USE IT
We collect information, including Personal Information, when you sign up for a user
account, participate in online courses, register for a paid certificate, send us email
messages, and/or participate in our public forums and social media. We also collect
certain usage information about student performance and patterns of learning. In
addition, we track 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 and other user interface controls were used.
We may log the IP address, operating system, and browser software used by each user
of the Site, and 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. Various
web analytics tools are used to collect this information. Some of the information is
collected through cookies (small text files placed on your computer that store
information about you, which can be accessed by the Site). 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.
We currently collect financial information from individual registrants; however, when
you register and pay for a course, you will be directed to our third party payment
processor and the submission of your payment information will be subject to the terms
of that third party processor’s privacy statement.
USE AND DISCLOSURE TO THIRD PARTIES
Among other things, we may use the information about you collected through the Site
(including your Personal Information) as follows:
To enable us to provide, administer, and improve our courses.
To help us improve Wharton Online Professional Education offerings, both
individually (e.g., by course staff when working with a student) and in aggregate,
and to individualize the experience and to evaluate the access and use of the Site
and the impact of Wharton Online Professional Education on the worldwide
educational community.
For purposes of scientific research, particularly, for example, in the areas of
cognitive science and education.
For the purpose for which you specifically provided the information, for example,
to respond to a specific inquiry or provide you with access to the specific course
content and/or services you select.
To track both individual and aggregate attendance, progress and completion of
an online course, and to analyze statistics on student performance and how
students learn.
To monitor and detect violations of the Honor Code and the Terms of Service, as
well as other misuses and potential misuses of the Site.
To publish information, but not Personal Information, gathered about Wharton Online Professional Education’s access, use, impact, and student performance.
To send you updates about online courses offered by Wharton Online Professional Education
or other events, to send you communications about products or
services of Wharton Online Professional Education, affiliates, or selected
business partners that may be of interest to you, or to send you email messages
about Site maintenance or updates.
To archive this information and/or use it for future communications with you.
To maintain and improve the functioning and security of the Site and our
software, systems, and network.
For purposes described elsewhere in this Privacy Policy (including, e.g., sharing
with third parties).
As otherwise described to you at the point of collection or pursuant to your
consent.
To authenticate your identity when you register for a course.
To process refunds, as applicable.
We will share information we collect (including Personal Information) with third parties
as follows:
With service providers or contractors that perform certain
functions on our behalf, including processing information that you provide to us
on the Site, processing purchases via third party providers, and other
transactions through the Site, operating the Site or portions of it, providing or
administering courses, or in connection with other aspects of Wharton Online Professional Education services.
With other visitors to the Site, to the extent that you submit comments, course
work, or other information or content (collectively, "Postings") to a portion of the
Site designed for public communications; and with other members of a Wharton Online Professional Education class of which you are a member, to the extent you submit Postings to a portion of the Site designed for viewing by those class members. We may provide your Postings to students who later enroll in the same classes as you, within the context of the forums, the courseware, or otherwise. If we do re-post your Postings originally made to non-public portions
of the Site, we will post them without your real name and email (except with your
express permission), but we may use your username without your consent.
For purposes of scientific research, particularly, for example, in the areas of
cognitive science and education. However, we will only share Personal
Information about you for this purpose to the extent doing so complies with
applicable law and is limited to the Personal Information required to fulfill the
purposes stated at the time of collection.
To provide opportunities for you to communicate with other users who may have
similar interests or educational goals. For instance, we may recommend specific
study partners or connect potential student mentees and mentors. In such cases,
we may use all information collected about you to determine who might be
interested in communicating with you, but we will only provide other users your
username, and not disclose your real name or email address, except with your
express permission.
To respond to subpoenas, court orders, or other legal process; to investigate,
prevent, or take action regarding illegal activities, suspected fraud, or security or
technical issues, or to enforce our Terms of Service, our Honor Code, or this
Privacy Policy; as otherwise may be required by applicable law; or to protect our
rights, property, or safety or those of others.
As otherwise described to you at the point of collection or pursuant to your
consent.
To support integration with third party services. For example, videos and other
content may be hosted on YouTube and other websites not controlled by us.
In cases where we share or disclose your Personal Information: (1) the third party
recipients are required to handle the Personal Information in a confidential manner
and to maintain adequate security to protect the information from loss, misuse,
unauthorized access or disclosure, alteration, and destruction; and (2) we will only
disclose and share the Personal Information that is required by the third party to fulfill
the purpose stated at the time of collection. In addition, we may share aggregated
information that does not personally identify you with the public and with third parties,
including but not limited to researchers and business partners.
USE FOR PERSONALIZATION AND PEDAGOGICAL IMPROVEMENTS
Our goal is to provide current and future visitors with the best possible Wharton Online-based
educational experience. To further this goal, we sometimes present different users with
different versions of course materials and software. We do this to personalize the
experience to the individual learner (assess the learner's level of ability and learning
style, and present materials best suited to the learner), to evaluate the effectiveness of
our course materials, to improve our understanding of the learning process, and to
otherwise improve the effectiveness of our offerings. We may publish or otherwise
publicize results from this process, but, unless otherwise permitted under this Privacy
Policy, those publications or public disclosures will not include Personal Information.
LINKS TO OTHER WEBSITES
The Site contains links to websites published by third parties, including other content
providers and certain service providers and those who process payments
on behalf of Wharton Online Professional Education. These other websites are not
under our control, and you acknowledge and agree that we are not responsible for the
collection and use of your information by such websites, unless we have otherwise
indicated in this Privacy Policy. We encourage you to be aware when you are redirected
to a third party website and review the privacy policies of each website you visit and
use.
SECURITY
Wharton Online Professional Education is designed to protect Personal
Information in its possession or control. This is done through a variety of privacy and
security policies, processes, and procedures, including administrative, physical, and
technical safeguards that reasonably and appropriately protect the confidentiality,
integrity, and availability of the Personal Information that it receives, maintains, or
transmits. Nonetheless, no method of transmission over the Internet or method of
electronic storage is 100% secure, and therefore we do not guarantee its absolute
security.
CHANGING OUR PRIVACY POLICY
Please note that we review and may make changes to this Privacy Policy from time to
time. When changes are made, the Privacy Policy link will include a notation "Revised
(date)." indicating that you should review the new terms, which will be effective
immediately upon posting on this page, with an updated effective date. The notation
will be included in the Privacy Policy link for at least seven (7) days after the update has
been made. By accessing the Site after any changes have been made, you signify your
agreement on a prospective basis to the modified Privacy Policy. Please return to this
page periodically to ensure familiarity with the most current version of this Privacy
Policy.
MINORS
Our Site is not intended for use by individuals under the age of 13, and we do not
knowingly collect personal data from those in this age group. If we become aware that
someone under the age of 13 has registered, we will expunge any related Personal
Information from our records.
PRIVACY CONCERNS
If you have privacy concerns, have disclosed data you would prefer to keep private, or
would like to access the information we maintain about you, please contact us at
whartononline@wharton.upenn.edu.