Effective as of January 1, 2020.
We provide important information for individuals located in the European Union here.
Table of Contents
Personal Information We Collect
Information you give us
Personal information that you may provide through the Site or otherwise communicate with us, including via our pages on social networks, includes:
- Contact information, such as your first name, last name, mailing address, phone number, and email address
- Username and password that individuals may choose to establish with the Site
- Feedback and correspondence, such as information you provide when you contact us with questions, feedback, or otherwise correspond with us online
- Demographic information, such as your city, state, country, and postal code
- Usage information, such as information about how you use the Site and interact with us, including any information that you submit to us through the Site
- Marketing information, such as your preferences for receiving marketing communications, details about how you engage with marketing communications, and your responses to our marketing research
- Other personal information you submit to us through the Site or our pages on social networks, such as information you may provide when interacting with us through our site or comments features, or on Facebook, LinkedIn, Twitter, Google+, YouTube, Instagram, and any other social network
Information we obtain from social media networks
Information we obtain from third-party sources
We may obtain information about you from third-party sources. For example, we may obtain your personal information from third-parties who you have granted permission to share your information with us, from partner organizations, and, where permitted by law, from data vendors.
Information automatically collected
When you access our Site, we, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and activity on our Site. The information that may be collected automatically includes your computer or mobile device operating system type and version number, manufacturer and model, device identifier, browser type, screen resolution, IP address, the website you visited before browsing to our Site, general location information such as city, state or geographic area; and information about your use of and actions on our Site, such as pages you viewed, how long you spent on a page, navigation paths between pages, information about your activity on a page, access times, and length of access. Our service providers and business partners may collect this type of information over time and across third-party websites. This information is collected using cookies and similar technologies. Please refer to the Cookies and Similar Technologies section for more details.
Sensitive Personal Information
We ask that you not send us, and you not disclose, any sensitive personal information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on the Site, or otherwise to us.
Cookies and Similar Technologies
What are cookies?
Cookies are small data files stored on your computer or mobile device by a website. Our Site may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience on our Site.
We use two broad categories of cookies: (1) first party cookies, served directly by us to your computer or mobile device, which we use to recognize your computer or mobile device when it revisits our Site; and (2) third party cookies, which are served by service providers or business partners on our Site, and can be used by such service providers or business partners to recognize your computer or mobile device when it visits other websites.
Cookies we use
Our Site uses the following types of cookies for the purposes set out below:
Type of cookie
These cookies are essential to provide you with services available through our Site and to enable you to use some of its features. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services.
These cookies allow our Site to remember choices you make when you use our Site. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-select your preferences every time you visit our Site.
Analytics and Performance Cookies
These cookies collect information about traffic to our Site and about how individuals use our Site. The information gathered may include the types of information described above in the section titled “Information automatically collected.” We use this information to help operate our Site more efficiently, to gather broad demographic information, monitor the level of activity on our Site, and improve the Site.
We use Google Analytics for this purpose. Google Analytics uses its own cookies. You can find out more information about Google Analytics cookies here and about how Google protects your data here. You can prevent the use of Google Analytics relating to your use of our Site by downloading and installing the browser plugin available here.
Social Media Cookies
These cookies are used when you share information using a social media sharing button or “like” (or similar) button on our Site or you link your account or engage with our content on or through a social networking website such as Facebook or Twitter. The social network will record that you have done this. Social networks use their own cookies.
Targeted and advertising cookies
These cookies track your browsing habits to enable us and third-party advertising networks to deliver ads that may be of interest to you. These cookies use information about your browsing history to group you with other users who have similar interests or browsing behavior. Based on the cookies that the third-party advertising network sets on our Site and other sites, advertisers can display advertisements that may be relevant to your interests on our Site and while you are on third party websites.
You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings,” “help” “tools” or “edit” menus). Many browsers are set to accept cookies until you change your settings.
For further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org.
If you do not accept our cookies, you may experience some inconvenience in your use of our Site. For example, we may not be able to recognize your computer or mobile device and you may need to log in every time you visit our Site.
In addition to cookies, our Site may use other technologies, such as Flash technology to pixel tags to collect information automatically.
We may also use pixel tags (which are also known as web beacons and clear GIFs) on our Site and in our HTML formatted emails to track the actions of users on our Site and interactions with our emails. Unlike cookies, which are stored on the hard drive of your computer or mobile device by a website, pixel tags are embedded invisibly on webpages or within HTML formatted emails. Pixel tags are used to demonstrate that a webpage was accessed or that certain content was viewed, typically to measure the success of our marketing campaigns or engagement with our emails and to compile statistics about usage of the Site, so that we can manage our content more effectively.
Do Not Track Signals
Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not currently respond to do not track signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
How We Use Your Personal Information
To provide our Site
If you use our Site, we use your personal information to:
- Operate, maintain, administer and improve the Site
- Provide information about our offerings
- Manage and communicate with you regarding your account with us, if you have one, including by sending you service announcements, technical notices, updates, security alerts, and support and administrative messages
- Process and manage registrations you make through the Site, including for features or events that we organize or host and to administer contests and other promotions
- Better understand your needs and interests, and personalize our content on the Site and in our communications
- Offer commenting and interactive features on our websites, such as our blog
- Provide support and maintenance for the Site
- Respond to your requests, questions and feedback
To communicate with you
If you request information from us (such as signing up for our newsletter or marketing emails), register on the Site, register for a course or event that we organize or host, or participate in our contests or promotions, we may send you Next Echo-related marketing communications as permitted by law. You will have the ability to opt out of such communications.
To comply with law
We use your personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests and legal process, such as to respond to subpoenas or requests from government authorities.
With your consent
We will request your consent to use your personal information where required by law. If we request your consent to use your personal information, you have the right to withdraw your consent any time in the manner indicated when we requested the consent or by contacting us. If you have consented to receive marketing communications from our third party partners, you may withdraw your consent by contacting those partners directly.
To create anonymous data for analytics
We may create anonymous data from your personal information and other individuals whose personal information we collect. We make personal information into anonymous data by excluding information that makes the data personally identifiable to you, and use that anonymous data for our lawful business purposes.
For compliance, fraud prevention and safety
We use your personal information as we believe necessary or appropriate to (a) enforce the terms and conditions that govern the Site; (b) protect our rights, privacy, safety or property, and/or that of you or others; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.
How We Share your Personal Information
Users of the Site
If you submit public comments via the Site, such as via the commenting features on our blog, your comments and the associated personal information you have provided to us (such as your name, username, and the geographic location you provide) may be displayed publicly on the Site.
We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.
Compliance with Laws and Law Enforcement; Protection and Safety
Next Echo may disclose information about you to government or law enforcement officials or private parties as required by law, and disclose and use such information as we believe necessary or appropriate to (a) comply with applicable laws and lawful requests and legal process, such as to respond to subpoenas or requests from government authorities; (b) enforce the terms and conditions that govern the Site; (d) protect our rights, privacy, safety or property, and/or that of you or others; and (e) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.
In this section, we describe the rights and choices available to all users. Users who are located within Member States of the European Union, countries in the European Economic Area, and the United Kingdom (collectively, “Europe” or “European”) may read additional information about their rights below.
Access, Update, Correct or Delete Your Information
You may also contact us as described below to access, update or correct the personal information that Next Echo maintains about you, or if you have additional requests or questions.
You may opt out of marketing-related emails by logging in and changing your account settings, by clicking on a link at the bottom of each such email, or by contacting us at firstname.lastname@example.org. You may continue to receive service-related and other non-marketing emails.
Targeted online advertising
Some of the business partners that collect information about users’ activities on our Site may be members of organizations or programs that provide choices to individuals regarding the use of their browsing behavior or mobile application usage for purposes of targeted advertising.
Users may opt out of receiving targeted advertising on websites through members of the Network Advertising Initiative by clicking here or the Digital Advertising Alliance by clicking here. European users may opt out of receiving targeted advertising on websites through members of the European Interactive Digital Advertising Alliance by clicking here, selecting the user’s country, and then clicking “Choices” (or similarly-titled link). Please note that we also may work with companies that offer their own opt-out mechanisms and may not participate in the opt-out mechanisms that we linked above.
If you choose to opt-out of targeted advertisements, you will still see advertisements online but they may not be relevant to you. Even if you do choose to opt out, not all companies that serve online behavioral advertising are included in this list, and so you may still receive some cookies and tailored advertisements from companies that are not listed.
Choosing not to share your personal information
Where we are required by law to collect your personal information, or where we need your personal information in order to provide services or the Site to you, if you do not provide this information when requested (or you later ask to delete it), we may not be able to provide you with our services. We will tell you what information you must provide to receive the services by designating it as required in or on the Site or through other appropriate means.
The security of your personal information important to us. We take a number of organizational, technical and physical measures designed to protect the personal information we collect, both during transmission and once we receive it. However, no security safeguards are 100% secure and we cannot guarantee the security of your information.
Our Site are not directed to children under 16. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us. We will delete such information from our files as soon as reasonably practicable.
Next Echo is headquartered in the United States and has service providers in other countries, and your personal information may be transferred to the United States or other locations outside of your state, province, country or other governmental jurisdiction where privacy laws may not be as protective as those in your jurisdiction.
European Union users should read the important information provided here about transfer of personal information outside of the European Economic Area.
Other Site and Services
The Site may contain links to other websites and services, including to educational institutions that offer or use our educational material. These links are not an endorsement, authorization or representation that we are affiliated with that third party. We do not exercise control over third party websites or services, and are not responsible for their actions. Other websites and services may follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies of the other websites you visit and services you use.
Your California Privacy Rights
Notice to California Residents
This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS supplements the information contained in Privacy Statement of Global Education Media Studios, Inc. and its subsidiaries (collectively, “we,” “us,” or “our”) and applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this notice.
Personal Information that We Collect, Use and Share
Here is a summary of how we currently collect, use and share personal information, and how we have collected, used and shared the information within the last 12 months.
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:
|A. Identifiers.||Real name, alias, postal address, unique personal identifier, online identifier Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.||YES|
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.||YES|
|C. Protected classification characteristics under California or federal law.||Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).||YES|
|D. Commercial information.||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||YES|
|E. Biometric information.||Physiological, biological and behavioral characteristics, including DNA, that can be used to establish individual identity, such as iris or retina images, fingerprints, faceprints, and voiceprints, keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data.||NO|
|F. Internet or other similar network activity.||Browsing history, search history, information regarding a consumer’s interaction with an Internet website, application, or advertisement.||YES|
|G. Geolocation data.||Precise location, e.g., derived from GPS coordinates or telemetry data.||YES|
|H. Sensory information.||Audio, electronic, visual, thermal, olfactory, or similar information.||NO|
|I. Professional or employment-related information.||Past or current employment history and performance evaluations.||NO|
|J. Non-public personally identifiable information (as defined by FERPA).||Name, address, social security number, biometric record, other indirect identifiers such as date and place of birth or mother’s maiden name, and other information that is linked or linkable to a student sufficient to enable a third party to identify the student.||YES|
|K. Inferences drawn from other personal information.||Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||YES|
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.
We obtain the categories of personal information listed above from the following categories of sources:
- Directly and indirectly from our clients or their agents.
- Directly and indirectly from consumers, such as prospective or current students. For example, through information we collect from our clients in the course of providing services to them.
- Directly and indirectly through business partners, such as colleges and universities we work with.
- Directly and indirectly from activity on our websites (www.culturaldaily.com or www.nextecho.org). For example, from submissions through our website portal or website usage details collected automatically.
- From third parties that interact with us in connection with the services we perform, such as data brokers.
Use of Personal Information
We may use or disclose the personal information we collect for one or more of the following business purposes:
- To fulfill or meet the reason for which the information is provided.
- To provide you with information, products or services that you request from us.
- To provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
- To improve our website and present its contents to you.
- For testing, research, analysis and product development.
- As necessary or appropriate to protect the rights, property or safety of us, our clients or others.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- As described to you when collecting your personal information or as otherwise set forth in the CCPA.
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Sharing Personal Information
We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
In the last 12 months, we have disclosed the following categories of personal information for a business purpose:
Category A: Identifiers.
Category B: California Customer Records personal information categories.
Category C: Protected classification characteristics under California or federal law.
Category I: Professional or employment-related information.
We disclose your personal information for a business purpose to the following categories of third parties:
- Potential students.
- Our affiliates.
- Service providers.
- Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.
In the last months, we have not sold any personal information, other than sharing learner information with our academic partner institution if needed for enrollment or transcript purposes. Please note that the CCPA defines sale broadly; thus, for example, the fact that we use analytics tools on our websites may be considered a sale under current California law. As a result, even when we do not get paid for the information and the recipient uses the information for its own purposes, the mere disclosure of the personal information to the recipient may be considered a sale under the CCPA.
Your Privacy Rights
You have the following rights under the CCPA:
Access to Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
- 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 or selling 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 (also called a data portability request).
- If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
- sales, identifying the personal information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. 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 exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service providers to:
- Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion is likely to render impossible or seriously impair the achievement of this research, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
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.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Changes to Our Privacy Notice
We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you by email or through a notice on our website homepage.
If you have any questions or comments about this notice, our Privacy Statement, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:
Postal Address: Next Echo Foundation, 215 S. Santa Fe Ave., Studio 19, Los Angeles, CA 90012
Attn: Adam Leipzig
Additional Information for European Users
Next Echo Foundation is the controller of your personal information for purposes of European data protection legislation. See the Contact Us section above for contact details.
Legal bases for processing
We use your personal information only as permitted by law. We are required to inform you of the legal bases of our processing of your personal information, which are described in the table below. If you have questions about the legal basis of how we process your personal information, contact us at email@example.com.
Processing purpose (click link for details)
To provide our Site
Processing is necessary to perform the contract governing our provision of the Services or to take steps that you request prior to signing up for the Services.
To communicate with you
These processing activities constitute our legitimate interests. 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).
To comply with law
Processing is necessary to comply with our legal obligations
With your consent
Processing is based on your consent. Where we rely on your consent you have the right to withdraw it anytime in the manner indicated in the Service or by contacting us.
Use for new purposes
We will only retain your personal information for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
When we no longer require the personal information we have otherwise collected about you, we will dissociate such information from the information attached to your content. In some circumstances we may anonymize your personal information (so that it can no longer be associated with you), in which case we may use this information indefinitely without further notice to you.
European data protection laws give European Union users certain rights regarding their personal information. If you are located within the European Union, you may ask us to take the following actions in relation to your personal information that we hold:
- Opt-out. Stop sending you direct marketing communications. You may continue to receive service-related and other non-marketing emails.
- Access. Provide you with information about our processing of your personal information and give you access to your personal information.
- Correct. Update or correct inaccuracies in your personal information.
- Delete. Delete your personal information.
- Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice.
- Restrict. Restrict the processing of your personal information.
- Object. Object to our reliance on our legitimate interests as the basis of our processing of your personal information.
You can submit these requests by email to firstname.lastname@example.org. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or response to your requests regarding your personal information, you may contact us or submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator here.
Cross-Border Data Transfer
Whenever we transfer your personal information out of Europe to countries not deemed by the European Commission to provide an adequate level of personal information protection, the transfer will be based:
- Pursuant to the recipient’s compliance with standard contractual clauses, EU-US Privacy Shield (or Swiss-US Privacy Shield, as applicable), or Binding Corporate Rules
- Pursuant to the consent of the individual to whom the personal information pertains
- As otherwise permitted by applicable European requirements.
You may contact us if you want further information on the specific mechanism used by us when transferring your personal information out of Europe.