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Privacy Policy

NOTICE: On May 25, 2018, AULASNEO adopted an amended Privacy Policy, providing as follows:

AULASNEO and each Member that provides courses through the AULASNEO Site care about the confidentiality and security of your information. This Privacy Policy applies to information that AULASNEO collects through the AULASNEO Site when you interact with AULASNEO, with Members, with other users, and generally with the AULASNEO Site.

Your information is received and controlled by AULASNEO according to this Privacy Policy when you sign up for an AULASNEO account or otherwise use the AULASNEO Site.

- AULASNEO is solely and independently responsible for its own privacy practices. No Member is responsible for AULASNEO’s privacy practices.

If you enroll in a course offered by a Member through the AULASNEO Site, information about you and your activity in the course is received and controlled also by that Member as described in this Privacy Policy.

- Each Member is solely and independently responsible for its own privacy practices. No Member is responsible for another Member’s privacy practices. Also, AULASNEO is not responsible for any Member’s privacy practices.

If you do not accept the terms of this Privacy Policy, then please do not access, browse, or register for the AULASNEO Site or enroll in any courses. If you choose not to provide certain information required to provide you with various products and services offered on the AULASNEO Site, then you may not be able to establish a user account or obtain those products or services.

Any version of this Privacy Policy in a language other than English is provided for convenience and you understand and agree that the English language version will control if there is any conflict.

This Privacy Policy is organized as follows:

  • Information that AULASNEO collects from you (including Personal Information)

  • Cookies and Tracking Technologies on the AULASNEO Site

  • How your information is used

  • How your information is shared

  • How to manage your Personal Information

  • Storage & Security

  • Privacy Policy updates

  • Contact information

  • Glossary

INFORMATION THAT AULASNEO COLLECTS FROM YOU (INCLUDING PERSONAL INFORMATION)

AULASNEO directly collects information when you:

  • sign up for an AULASNEO user account and create an AULASNEO user profile;

  • enroll and participate in online courses;

  • purchase a product or service;

  • send email messages to AULASNEO (including messages to learner support);

  • participate in user surveys; and

  • participate in public forums, webinars, and other interactive experiences on the AULASNEO Site.

AULASNEO also indirectly collects usage information about your visit to the AULASNEO Site, as explained in the section below titled Cookies and Tracking Technologies.

AULASNEO does not itself collect or store financial account numbers or identification issued by a governmental entity, employer, or other authority. Instead, if you choose to make a purchase on the AULASNEO Site, for example a Verified Certificate, you will be directed to AULASNEO’s third-party payment processor and AULASNEO’s third-party ID verification service provider. If you do not wish to submit the required authentication or payment information, then you will not be able to obtain a certificate via the AULASNEO Site.

AULASNEO requires your Personal Information only in limited circumstances when you:

  • sign up for an AULASNEO user account (name, username, email address);

  • purchase a course (so that AULASNEO’s third-party vendor can authenticate your identity) or other product or service (so that AULASNEO’s third-party vendor can process payment);

  • participate in remote proctoring or other course facilitation processes (so that AULASNEO’s third-party vendor can monitor and assess the integrity of your course activity); or

  • earn a Certificate (the certificate will have your name on it).

To the extent that AULASNEO associates the information that AULASNEO 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 AULASNEO Site, for example:

  • in your AULASNEO account profile (and you may display a limited or full profile to other AULASNEO Site users);

  • in applying for financial assistance; or

  • when participating in a course, forum, webinar, or other interactive experience on the AULASNEO Site (noting that in some cases, this information is shared with a third party that provides tools or other assistance for the AULASNEO Site or a course).

AULASNEO encourages you to use discretion before voluntarily sharing additional Personal Information on the AULASNEO Site. (If you later choose to delete your AULASNEO account, deletion of your Personal Informationwill be subject to the process and limits outlined below.)

Members do not receive your Personal Information unless and until you enroll in a course. If you enroll in a course, the Member that offers the course will receive Personal Information from your AULASNEO account profile plus the information that AULASNEO collects about your activity and performance in the course in which you enrolled.

COOKIES AND TRACKING TECHNOLOGIES ON THE AULASNEO SITE

Like many companies, AULASNEO uses Cookies and other common Tracking Technologies on the AULASNEO Site and in email communications to help AULASNEO better understand your use and needs of the AULASNEO Site, current and future AULASNEO-related products and services, and how AULASNEO and Members can improve. For example:

  • based on your cookie settings, AULASNEO tracks information indicating, among other things, which pages of the AULASNEO Site were visited, the order in which they were visited, when they were visited, and which hyperlinks and other user interface controls were used;

  • AULASNEO may log the IP address, operating system, and browser software (including mobile use and device type when you use AULASNEO native mobile apps) you used when accessing the AULASNEO Site, and AULASNEO may be able to determine from an IP address your Internet Service Provider and the geographic location of your point of connectivity; and

  • AULASNEO may track and collect information from emails that AULASNEO sends to you, for example whether you opened the email or clicked on any links from the email.

AULASNEO also partners with third parties to help us track and understand your activity on the AULASNEO Site, how you interact with AULASNEO’s social media, and how you find or may be referred to the AULASNEO Site. Individual Members may separately use Tracking Technologies within their courses and email communications to understand your activity within a course and how you find or may be referred to a course on the AULASNEO Site.

AULASNEO and Members use Cookies and other Tracking Technologies for the following purposes:

  • when necessary for system administration, security, and integrity to ensure the AULASNEO Site works properly for you. Without these technologies, the AULASNEO Site may not function correctly;

  • to enable analytics, performance and functionality, to help AULASNEO and Members gather information about how visitors use the AULASNEO Site and monitor AULASNEO Site performance, and to enhance your experience by recognizing and remembering whether you have visited the AULASNEO Site before and may have any personal preferences; and

  • to support marketing by enabling AULASNEO and Members to deliver content relevant to your interests on the AULASNEO Site and third-party sites based on how you interact with AULASNEO or Member advertisements or content. AULASNEO and Members use “first-party” cookies, which means cookies served by AULASNEO or an individual Member, and also “third-party” cookies, which means cookies served by third parties that help AULASNEO and Members 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 AULASNEO’s Cookies, many functions and conveniences of the AULASNEO Site may not work properly.

  • Opting-out of certain third-party tracking and advertising : Some of the third parties used by AULASNEO or a Member 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 at the AULASNEO learner Help Center and includes, for some, links to applicable opt-out processes. Neither AULASNEO nor any Member is responsible for the effectiveness of any third-party opt-out options.

HOW YOUR INFORMATION IS USED

AULASNEO and Members use information, including Personal Information, to carry out the following purposes:

  • Operate and improve the AULASNEO Site – This includes creating and improving features that support the AULASNEO community and enable AULASNEO Site usage at scale. This also includes personalizing the AULASNEO Site, 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 massive open online courses and programs on AULASNEO. This also includes 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 AULASNEO Site, to enroll and participate in courses and programs on the AULASNEO Site, to learn effectively in such courses and programs, and to purchase or obtain products and services on the AULASNEO Site such as Verified Certificates.

  • Develop and maintain the security and performance of the AULASNEO Site – This includes tracking AULASNEO Site outages and creating software solutions, detecting violations of the Honor Code and Terms of Service, and monitoring uses, misuses, and potential misuses of the AULASNEO Site.

  • Communicate with you – This includes answering your course and platform questions, notifying you of course and AULASNEO Site maintenance and updates, marketing to you about course offerings, programs, news, and related products and services of AULASNEO or AULASNEO affiliates, and as permitted under applicable law, sending you communications about products or services of selected business partners that may be of interest to you.

  • Support scientific research including, for example, in the areas of cognitive science and education – This includes collaborating to enable and conduct research about how learners access and master course materials online, with the goal of improving course outcomes.

  • Track AULASNEO Site 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 AULASNEO, Members, or others, and as otherwise required by applicable law.

AULASNEO or a Member 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

AULASNEO and Members share information, including Personal Information, with third parties for the following purposes:

  • With service providers, contractors, and other third parties that help carry out the uses described above – AULASNEO requires third parties to: (1) abide by this Privacy Policy and applicable law; (2) handle Personal Information in a confidential manner and maintain adequate security; and (3) use Personal Information only as needed to fulfill the relevant purpose(s). In some cases, the AULASNEO Site and individual courses are integrated with third-party services or contain links to websites published by third parties, including other content providers as well as service providers. These third parties are responsible for their own privacy practices, so you should pay attention anytime you are redirected to a third-party website and be sure to review its privacy policy.

  • With other learners in courses that you take and with other visitors to the AULASNEO Site, 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 AULASNEO Site 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, AULASNEO and each Member that offers a course in which you enrolled may use all information collected about you to determine who might be interested in communicating with you, but will only provide others your username (for clarity, no disclosure of your real name or email address).

  • With employers, government programs, institutions, or other enterprises that sponsor your enrollment in a course for training or other educational purposes – If an entity pays for or otherwise sponsors your Verified Certificate or course participation, AULASNEO will share information with the entity as needed to confirm your enrollment, participation, progress, and completion status in that course.

  • With affiliates of AULASNEO or a Member, or with successors in the event of a merger, acquisition, or reorganization, for their use consistent with this Privacy Policy.

AULASNEO or a Member may also seek your consent for additional disclosures of information, including Personal Information, and will share it only as described to you. In addition, AULASNEO or a Member may share with the public and with third parties, including but not limited to researchers and business partners, information and Personal Information that is de-identified 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 AULASNEO Site and requests to the AULASNEO learner support team. If your request involves information controlled by a Member, AULASNEO learner support will notify and coordinate with the appropriate Member to address your request. AULASNEO 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. AULASNEO will notify you in the event that AULASNEO is unable to meet a request that is not legally required. Similarly, Members will only be obligated to comply with requests to the extent legally required, but may choose to comply with other requests in their sole discretion.

  • Access and correct your Personal Information

Much of your Personal Information is available in your AULASNEO account. Your name, email address, and other identifiable profile information is editable through the profile settings in your AULASNEO account except as noted below. Your account dashboard lists all current and archived courses in which you have enrolled and includes links to any Verified Certificates you may have earned. The dashboard also contains copies of your answers and other participation and performance in courses. Please contact AULASNEO learner support to access and update this or other information. If your request involves information controlled by a Member, AULASNEO learner support will notify the appropriate Member of your request.

Exceptions:

- Usernames cannot ever be changed. This is an AULASNEO system restriction. Because usernames identify you in courses and elsewhere on the AULASNEO Site, AULASNEO encourages you to use discretion in choosing your username. If you want to protect your identity, do not use your real name or a name identifiable to you as your username.

- AULASNEO does not track or index every time or every place on the AULASNEO Site when or where a learner may volunteer Personal Information, so neither AULASNEO nor Members will be able to help you locate or manage all such instances. AULASNEO encourages you to use discretion before volunteering Personal Information on the AULASNEO Site.

  • 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 AULASNEO account dashboard, follow the steps described in links at the bottom of email messages, or contact AULASNEO learner support. You may object to, or request that AULASNEO or a Member stop, its use of your Personal Information for other purposes by contacting the AULASNEO learner support team. If your request involves information controlled by a Member, AULASNEO learner support will notify the appropriate Member of your request. Please note that if you choose to restrict AULASNEO’s or a Member’s ability to process Personal Information, and the processing is otherwise required to provide you with various services and products offered on the AULASNEO Site, you may not be able to establish an AULASNEO user account or enroll for a course, and AULASNEO or a Member may not be able to provide you with those services or products.

  • Delete account and Personal Information

To request deletion of your AULASNEO account and Personal Information, you should click the button labeled “Delete my account” in your AULASNEO account settings. Because deletion on the AULASNEO system is a permanent action and cannot be reversed, AULASNEO may ask you to complete a process that aims to confirm your authority to manage the AULASNEO account affected by your request.

With respect to your AULASNEO account, AULASNEO will permanently :

  • deactivate your AULASNEO account,

  • remove the active profile,

  • retire your username, and

  • remove you from AULASNEO email lists.

With respect to your Personal Information, AULASNEO will permanently delete your AULASNEO account profile Personal Information from the AULASNEO Site.

As noted above, to the extent that AULASNEO associates the information that AULASNEO collects directly or indirectly with an individual (for example, you), the association is based on Personal Information in your AULASNEO account profile. By erasing the Personal Information in your AULASNEO account profile, the remaining information about your activity on the AULASNEO Site 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 AULASNEO Site including course administration by Members. If you enrolled in any courses on the AULASNEO Site, the AULASNEO learner support team will share your request with the Members that offered those courses.

Exceptions:

- Deletion will not apply to historical activity logs or archives unless and until these logs and data naturally “age-off” the AULASNEO system.

- AULASNEO does not track or index every time or every place on the AULASNEO Site when or where a learner may volunteer Personal Information, so neither AULASNEO nor Members will be able to help you locate or manage all such instances. AULASNEO encourages you to use discretion before voluntarily sharing your Personal Information on the AULASNEO Site.

- AULASNEO will archive course data (in a manner and to the extent permitted under applicable law) to serve its mission to enable scientific research on cognitive science and education. These archives are used to produce encrypted research data packages for Members, and Personal Information may not be deleted from research data packages retained by Members.

- AULASNEO and each applicable Member cannot always delete records of past interactions and transactions. For example, records relating to previous purchases on the AULASNEO Site must be retained for financial reporting, audit, and compliance reasons.

- AULASNEO and each Member 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.

  • Data retention

AULASNEO 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 AULASNEO’s legal obligations, resolve disputes, enforce its agreements, and as otherwise permitted by applicable law. If you enroll in a Member’s course, such Member will also retain your Personal Information for as long 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 its legal obligations, resolve disputes, enforce its agreements, and as otherwise permitted by applicable law. Upon your request that AULASNEO deactivate your account and delete your information, AULASNEO will follow the process described above, including without limitation archiving your course data (in a manner and to the extent permitted under applicable law) to serve its mission to enable scientific research on cognitive science and education. These archives will be used to produce encrypted research data packages for Members, and each such Member may also keep and use course data for scientific research.

STORAGE & SECURITY

AULASNEO stores information, including Personal Information, on its own servers and also on servers of companies that AULASNEO hires to provide services. Each Member also stores information, including Personal Information, on its own servers and/or on servers of companies that the Member hires to provide services. In each case, information may be stored in the United States and in other countries where AULASNEO or a Member operates, and in countries where AULASNEO and each Member’s respective service providers operate. If you are in the European Union, Switzerland, or other regions with laws governing data collection and use, you acknowledge that AULASNEO and each Member 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.

AULASNEO controls its own copy of information collected through the AULASNEO Site and has an information security program designed to protect information in its possession or control. This is done through a variety of privacy and security policies, processes, and procedures. AULASNEO uses administrative, physical, and technical safeguards that reasonably and appropriately protect the confidentiality, integrity, and availability of the information that it collects, receives, stores, or transmits. Nonetheless, no method of transmission over the Internet, or method of electronic storage, is 100% secure; and therefore, AULASNEO cannot guarantee its absolute security. While AULASNEO works hard to ensure the integrity and security of its network and systems, AULASNEO cannot guarantee that its security measures will prevent “hackers” or other unauthorized persons from illegally accessing or obtaining information.

If AULASNEO learns of a security breach involving its copy of your Personal Information, AULASNEO may attempt to notify you electronically so that you may take appropriate protective steps. By using the AULASNEO Site or providing Personal Information to AULASNEO, you agree that AULASNEO can communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the AULASNEO Site. If a security systems breach occurs, AULASNEO may post a notice on the AULASNEO homepage ( Open edX LMS and learning solutions ) or elsewhere on the AULASNEO Site and may send an email to you at the email address associated with your AULASNEO 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.

If a Member learns of a security breach involving that Member’s copy of your Personal Information, the Member may attempt to notify you electronically so that you may take appropriate protective steps. By enrolling in a Member’s course on the AULASNEO Site or providing Personal Information to the Member, you agree that the Member can communicate with you electronically regarding security, privacy, and administrative issues relating to your course enrollment and participation. If a security systems breach occurs, the affected Member may post a notice on the AULASNEO site and/or send an email to you at the email address associated with your enrollment in the Member’s course on the AULASNEO Site. 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.

PRIVACY POLICY UPDATES

This Privacy Policy will be reviewed and updated from time to time. When changes are made, the Privacy Policy will be labeled as "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. By accessing the AULASNEO Site after any changes have been made, you accept the modified Privacy Policy and any changes contained therein. In case you miss the notification referenced above, be sure to return to this page periodically to ensure familiarity with the most current version of this Privacy Policy.

CONTACT INFORMATION

If you have privacy concerns, have disclosed data you would prefer to keep private, or would like to access the Personal Information that AULASNEO maintains about you, please contact us at privacy@aulasneo.com.

GLOSSARY

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 AULASNEO Site or in an email communication back to AULASNEO or the authorized third party that served the cookie. AULASNEO or third parties may also use Flash cookies.

AULASNEO Site consists of all content and pages located within the https://aulasneo.com. web domain and all AULASNEO mobile applications.

Member is each educational institution or other leading global institution or entity that provides courses through the AULASNEO Site.

Personal Information is information that specifically identifies you or that, when combined with other information, could be used to identify you.

Tracking Technologies are web beacons, clear gifs, pixels, and similar technologies that are also unique identifiers used to track your online activity but are not stored on your device.

Verified Certificate is a virtual certificate that shows that you have successfully completed your AULASNEO course or program and verified your identity using your webcam and your acceptable form of photo ID.

Effective Date: May 25, 2018