Appendix A – California Specific Privacy Notice

Last Updated: December 31, 2021

Our California Specific Privacy Notice supplements the information in our Privacy Policy. The following material applies only to residents of California¹. We have adopted this notice to comply with the California Consumer Privacy Act of 2018 ("CCPA"). Any terms defined in the CCPA have the same meaning when used in this notice. This notice does not apply to our privacy obligations under the Family Educational Rights and Privacy Act (FERPA) or other similar state laws. If at any time you have questions about this information, please contact privacymatters@aiuniv.edu or call toll-free (844)783-8627.

YOUR RIGHTS UNDER THE CCPA

Except as otherwise provided by applicable California law, note that for purposes of these requests under this "Your Rights Under the CCPA" Section of this Notice, personal information does not include information about job applicants, employees and other of our personnel; information about employees and other representatives of third-party entities we may interact with; or information we have collected as a service provider. California residents may designate an authorized agent to make a request on their behalf. When submitting the request, please ensure the authorized agent is identified as an authorized agent.

Your Right to Request Information About Personal Information We Collected.

You have the right to request the following about personal information we collected about you over the past 12 months:

1. The categories of your personal information we collected.
2. The categories of sources from which we collected the personal information.
3. Our business or commercial purpose for collecting or selling the personal information.
4. The categories of third parties² with whom we shared the personal information.
5. The specific pieces of personal information we have collected about you.

Your Right to Request Disclosure of Personal Information We Sold³ or Disclosed for a Business Purpose.

You have the right to request that we disclose:

1. The categories of your personal information that we sold and the categories of third parties to whom we sold the personal information.
2. The categories of your personal information that were disclosed for a business purpose.

Your Right to Request Deletion of Certain Personal Information We Collected.

You have the right to request that we delete your personal information that we maintain about you, subject to certain exceptions.

Your Right to Request Opt-Out/Do Not Sell My Personal Information. You have the right, at any time, to direct us not to sell your personal information to third parties, as defined under the CCPA by clicking Do Not Sell My Personal Information. This is also referred to as your right to opt-out. For purposes of this Privacy Policy, “sell” means the sale of your personal information to an outside party for monetary or other valuable consideration, subject to certain exceptions set forth in applicable California law.

You have the right to opt-out of sales, within the meaning of the CCPA, of certain information subject to the CCPA. You are not required to have an account with us to exercise your right to opt-out of the sale of your personal information to third parties. Please submit your request to privacymatters@aiuniv.edu. If you do not have an account, please include your name, address and e-mail address. You may also submit this request online by visiting the following site: DO NOT SELL MY PERSONAL INFOMATION. We do not sell the personal information of consumers we actually know are less than 16 years of age.

We use tracking tools, including cookies, on our websites. Third parties also use cookies on our sites. Your browser may give you the ability to control cookies. How you do so depends on the type of cookie. Cookies are small files that download when you access certain websites. To learn more, visit here. Certain browsers can be set to reject browser cookies. These pages also explain how you can manage and delete cookies. To control flash cookies, which we may use on certain websites from time to time, you can go here. Why? Because flash cookies cannot be controlled through your browser settings. Our website offers users the convenience of a tool that will allow the user to set their tracking preferences for this website. To learn about cookies, tracking tools, and how you can manage these tools, please see About Our Ads.

Your Right to Nondiscrimination. We do not discriminate if you choose to opt-out or exercise any of your rights under the CCPA. This includes, but is not limited to (i) charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties, (ii) providing a different level or quality of goods or services, or (iii) suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services. If we offer you a financial incentive permitted under the CCPA and not prohibited by other applicable laws and regulations, we will notify you of the material terms of the incentive or incentive program. You will be given the opportunity to provide prior opt-in consent (which you may revoke at any time).

CATEGORIES OF PERSONAL INFORMATION

We have collected the following categories (as enumerated in the CCPA) of personal information from consumers within the last twelve (12) months:

CATEGORIES OF SOURCES

We obtain the categories of personal information listed above in the "Categories of Personal Information" section of this Notice from the following categories of sources:

• Direct interactions. We collect personal information when you request information about our products and services or sign up for an event. We might also collect information when, for example, you sign up to receive communications from us. You may give us your information by filling in forms or by corresponding with us by e-mail, phone, fax, mail or in-person. This includes, but is not limited to, personal data you provide when you:
  • Purchase our products or services or request information;
  • Discuss your interest in and/or your eligibility for our services with our staff, including but not limited to, personnel in Admissions, Academics, Financial Aid, Registrar’s Office, Student Advising, Faculty, Career Services or Student Accounts;
  • Apply for financial aid, scholarships, grants or other types of financial aid (e.g., military tuition assistance, employer tuition assistance, etc.);
  • Create or register for a user account on our website, virtual campus, mobile application or job/hiring information site;
  • Subscribe to our publications such as newsletters, alumni communications, career services information, investor updates or webinars;
  • Request marketing be sent to you such as by e-mail, mail, phone, live chat or text messaging;
  • Interact with our website such as through our application center, FA calculator, live chat, or providing your contact information;
  • Interact with our social media pages, commenting on or liking posts;
  • Enter a competition, sweepstakes, or promotion;
  • Complete a survey or other assessment tool;
  • Provide information in-person at industry events, school events or other venues, or by phone, fax, online chat, text message, or e-mail; or
  • Provide information or apply for a position on our job information website.
• Automated technologies or interactions. As you interact with our website or mobile applications, we may automatically collect data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We may also receive technical information about you if you visit other websites employing our cookies. Please see About Our Ads for further details.
• Vendors we engage to provide services on our behalf.
• Other parties or publicly available sources. We may receive personal information about you from various other parties and public sources.
• We may combine information that we have collected offline with information we collected online. Or we may combine information we get from another party with information we already have.

USE OF YOUR PERSONAL INFORMATION

We may use and/or disclose the categories of personal information we collect about you in the "Categories of Sources" Section of this Notice for one or more of the following business or commercial purposes described in Clause 2 of the Privacy Policy.

DISCLOSURE AND SALE OF PERSONAL INFORMATION

CATEGORIES OF THIRD PARTIES

1. We may disclose your personal information for a business purpose to the following categories of third parties:
   • Entities owned in whole or in part by us or our parent company and/or its shareholders.
   • Government agencies, regulators, accreditors, law enforcement, and other authorities entitled to such personal information pursuant to law or regulation.
   • Authorized distributors of our organizations’ products and/or services.
   • A third party with a legitimate educational interest pursuant to FERPA or similar applicable state regulation.
   • Service providers fulfilling a business purpose for us, such as:
     • Professional advisers including, but not limited to, auditors, bankers, insurers, legal counsel, and professional subject matter experts.
     • Organizations we contract with for articulation (e.g., transfer of credit agreements) and affiliation purposes (e.g., internship/externship agreements).
     • Organizations we contract with to improve our platform, products, and services, improve student retention, our internal inquiry model system, and overall user experience.
     • Organizations we contract with for employee benefit purposes.
     • Background check providers for job candidates and/or students.

SUBMITTING A REQUEST

To exercise your access, disclosure, and deletion rights, as a California resident, you must submit a verifiable consumer request to us. We have outlined the procedure below.

1. You may submit your request⁶ online at: Privacy Data Request. This is the most efficient way to make your request. You may also contact us via our toll-free number (844) 783-8627 or at privacymatters@aiuniv.edu.

2. You will be asked to provide certain personal information that we will review against our records to validate your identity.

3. We will respond to a verifiable consumer request within forty-five (45) days of its receipt.

4. For a disclosure request, once we receive and confirm your verifiable consumer request, we will provide you with:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you in the previous twelve (12) months.
• If we disclosed your personal information for a business purpose, the personal information categories that each recipient was provided.
• You are permitted to make two (2) disclosure requests in a 12-month period.

5. For a deletion request, once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exemption(s) applies.

6. For disclosure requests, we will provide your personal information in a format that is readily useable and can be transmitted to another organization or business without difficulty.

HOW TO CONTACT US

If you have any questions about our privacy practices, contact us at privacymatters@aiuniv.edu or by telephone at 847-781-3600. You may also write to us at the following address:

¹ A California resident, referred to as a Consumer, is anyone who meets the definition of resident as defined under the California Tax provisions. (Section 17014 of Title18 of the California Code of Regulations).
² Under the CCPA, the term “third party” is limited to a person who is not any of the following: 1.The business that collects personal information from consumers under this title. 2. A person to whom the business discloses a consumer’s personal information for a business purpose pursuant to a written contract.
³ Our organization does not sell personal information for monetary gain. The CCPA defines “Sell,” “selling,” “sale,” or “sold,” as meaning selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to another business or a third party for monetary or other valuable consideration.
⁴ Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code.
⁵ Personal information does not include: • Publicly available information from government records.
• De-identified or aggregated consumer information.
• Information excluded from the CCPA's scope, like: health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; • Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.
⁶ Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.