Purpose

This Privacy Notice explains how IPEA (“IPEA,” “us,” “we,” or “our”) collects, uses, and shares your information through our online interfaces, including theipea.org (the “Site”). Please review this Notice to understand our practices. If you have any questions, please don’t hesitate to contact us. Your use of the Site is also subject to our Terms of Use. Terms not defined here are explained in the Terms of Use. If you are in the European Economic Area (“EEA”), IPEA is the data controller for Personal Data collected via the Site, except in cases such as degree or certificate programs where IPEA may act as a data processor, as communicated to you.

What Information Does This Privacy Notice Cover

This Privacy Notice applies to information we collect through our Site. Some features are available without providing Personal Data, but certain services require it. Personal Data includes information that identifies you, such as your name, email address, IP address, or device identifier. Please ensure your Personal Data is accurate, as incorrect information may affect your access to the Site and our ability to communicate with you.

Legal Bases for Collecting and Using Personal Data

We consider that the legal bases for using your Personal Data as set out in this Privacy Notice are as follows:

•     to perform our obligations under any contract with you (for example, to comply with the Terms of Use of our Site, which you accept by browsing our website, and/or to comply with our contract to provide Services to you, your academic institution, your employer, or other organization that may be providing you with access to our Services);
•     to comply with our legal obligations;
•     for our legitimate interests or the legitimate interests of others. Our legitimate interests are to:
• run, grow, and develop our business;
• operate our Site and provide our Services;
• select appropriately skilled and qualified suppliers;
• build relationships with partners and academic institutions;
• carry out research and statistical analysis;
• carry out marketing and business development; and
• for internal administrative and auditing purposes.
•     where you have given consent, for example, to send you certain communications, or where you submit certain information to us, or where required to rely upon consent by local law.

The legal basis applicable to a specific activity depends on the type of personal information used and the context in which it is being used.

If we rely on our (or another party’s) legitimate interests for using your personal information, we will undertake a balancing test to ensure that our (or the other party’s) legitimate interests are not outweighed by your interests or fundamental rights and freedoms which require protection of the personal information.

We may process your personal information in some cases for marketing purposes on the basis of your consent (which you may withdraw at any time as described below).

If we rely on your consent to use your personal information in a particular way, but you later change your mind, you may withdraw your consent by visiting your profile page and clicking the box to remove consent. We will then stop using your personal information in that way. If you withdraw your consent, this may impact our ability to provide some of our Services to you.

What Personal Data We Collect

We gather the following types of information about users through the Site:

1.  Information about how you use our Site. When you visit our Site, we may keep track of which pages you visit, the order and timing of your visits, and which links you click. We also collect information from the websites you visit to access our Site. This may include your IP address, the type of computer or device you use, and the web browser you are using. We may also find out who provides your internet service and where you are connecting from, based on your IP address. We use your location to send your connection to the closest server, which can make the Site work faster for you. We may use cookies and similar tools when you visit our Site. For more details, see our cookies policy. We also use tools that record how you interact with the Site, allowing us to review replays of your session. These replays show things like your mouse movements, which pages you visit, and how the Site performs. This helps us identify and resolve issues, making the Site better.
2.  Personal Data provided directly by you or via third parties. We collect Personal Data that you provide to us when you register for an account, update or change information for your account, purchase products or Services, complete a survey, sign up for email updates, participate in our public forums, send us email messages, and/or participate in Content Offerings or other Services on our Site. We may use the Personal Data that you provide to respond to your questions, provide you with the specific Content Offering and/or Services you select, send you updates about Content Offerings or other IPEA events, and send you email messages about Site maintenance or updates.

•     Account Registration. If you register for an account on our Site, you may be required to provide us with certain Personal Data such as your name and email address. You may also voluntarily provide us with additional Personal Data.
•     Updates. IPEA may offer you the option to receive updates via email or by posting on portions of the Site that are only accessible to registered users. To subscribe to these Services, you may be required to provide us with Personal Data, such as your name and email address.
•     Forums. IPEA may occasionally offer public forums (the “Forums”) where you can share your comments and thoughts. To participate in the Forums, you may be required to register with us and provide us with Personal Data, such as your name and email address. Please note that any information you post or make available in the Forums will be publicly accessible. You should not include any Personal Data or other information of a personal or sensitive nature, whether relating to you or another person, in a Forum post.
•     Participation in Content Offerings. IPEA offers users the opportunity to participate in Content Offerings on or through the Site. If you desire to participate in a Content Offering, you will be asked to provide us with certain information necessary to conduct such a Content Offering. This information may include, among other things, your name and email address.

If you participate in a Content Offering, we may collect certain user-generated content, such as assignments you submit, peer-graded assignments, and peer grading feedback. We also collect course data, such as responses to in-video quizzes, standalone quizzes, exams, and surveys. You should not include any Personal Data or other information of a personal or sensitive nature, whether relating to you or another person, on assignments, exams, or surveys, except for information required to participate in or submit such assignments, exams, or surveys.

•     Identity Verification. IPEA may offer you the ability to verify your identity for select Services. To enroll in these Services, you may be required to provide us or our third-party identity verification vendor with personal data, including your name, address, date of birth, a headshot taken using a webcam, and a photo identification document. Additionally, if you apply for financial aid in connection with these Services, you may be required to provide information regarding your income.
•     Communications with IPEA. We may receive and record Personal Data when you send us an email message or otherwise contact us, including through the use of an in-platform messaging/chat feature.
•     Third Party Sites. We may receive Personal Data when you access or log in to a third-party site, e.g., Facebook, from our Sites. This may include the text and/or images of your Personal Data available from the third-party site.
•     Surveys. We may receive Personal Data when you provide information in response to a survey operated by us or a Content Provider.
•     Partner sites. Partner sites providing Content Offering-related tools and services to IPEA users may collect nonfinancial individual-level user data regarding the individual’s use of that partner site while the partner sites provide those services to IPEA. The partner sites may share that data with IPEA for the purpose of improving our Services, the partner site’s services, and the individual’s education experience. This data includes information such as the amount of time spent on the partner site and the number of pages viewed.
•     Third Party Payment Processing. IPEA provides you with the ability to pay for Content Offerings and other Services using a credit card or other methods through a third-party payment processing service provider. Please note that our service provider, not IPEA, collects and processes your financial information. Our third-party payment processing service providers include Stripe, Braintree, Google Pay, Apple Pay, PayPal, and Cash App.

How We Use Personal Data

IPEA collects and uses Personal Data for the purposes described in this section. IPEA may share such Personal Data for these purposes with third parties, such as service providers, university and industry partners, and other commercial partners.

•     Providing the Site and our Services. We use the Personal Data that you provide to us to allow you to access and use the Site, and to provide any information, products, or Services that you request from us.
•     Technical support and security. We may use Personal Data to provide technical support to you, where required, and to ensure the security of our Services and the Site.
•     Updates. We use the Personal Data collected when you sign up for our various email or update services to send you messages related to the Site or Content Offerings. We may also archive this information and/or use it for future communications with you, where we are legally entitled to do so.
•     Analyzing and improving the Site and Services. We use Personal Data and may share it with companies that help us to see how people use the Site and our Services. We may use computer programs that can learn from data to help with this. We use what we learn to understand what people want, improve our Site and products, and make our Services better.
•     Forums. You should not post any personally identifiable information or other information of a personal or sensitive nature, whether relating to you or another person, within a Forum post. If you choose to post personally identifiable information, such personally identifiable information may be collected during your use of the Forums. We may publish this information through extensions of our platform that utilize third-party services, such as mobile applications. We reserve the right to reuse Forum posts that contain personally identifiable information in future versions of the Content Offerings and to enhance future Content Offerings. We may archive this information and/or use it for future communications with you and/or your designee(s), and/or provide it to the Content Provider, business partners, or the instructor(s) associated with the courses you have taken. We may also use or publish posts submitted on the Forums without using personally identifiable information.
•     Participation in Content Offerings. We use the Personal Data that we collect from you when you participate in a Content Offering through the Site for processing purposes, including but not limited to tracking attendance, progress, and completion of the Content Offerings. We may also share your Personal Data and your performance in a given Content Offering with the instructor or instructors who taught it, with teaching assistants or other individuals designated by the instructor or instructors to assist with the creation, modification, or operation of the Content Offering, and with the Content Provider(s) with which they are affiliated. We may also use the information generated when taking a Content Offering or using the Services for predictive analysis of your performance in the Content Offerings. Additionally, we may archive this information and use it for future communications with you, provided we are legally entitled to do so.
•     Use of Interactive/Personalized Site Features. We use Personal Data and may share it with other companies to enhance your experience on the Site, such as through the use of chatbots, automatic translation, grading, and recommendations. Some of these features may use computer programs that can learn from data. If needed, we will provide you with more information in advance about how your Personal Data is used in these features, including whether any decisions are made automatically.
•     Identity Verification. For Services that require identity verification, we may use the Personal Data that we collect to verify your identity and to authenticate that submissions made on the Site were made by you. This service may be provided through a third-party identity verification vendor. Your photo identification document will be deleted after your profile information has been successfully verified.
•     Communications with or from IPEA. When you send us an email message, use in-platform messaging/chat features (which may utilize technology provided by third party service providers contracted by IPEA) or otherwise contact us, we and our third-party service providers may record and use the information provided by you to respond to your communication and/or for other purposes described in this Privacy Notice or in other privacy information provided to you during your interaction with our communication systems. We and our third-party service providers may also archive this information and/or use it for future communications with you where we are legally entitled to do so. When we send you emails, we may track how you interact with them (such as when you open an email or click on a link inside an email). We use this information to optimize and tailor our communications to you more effectively.
•     Communications with IPEA Business Partners. We may share your Personal Data with Content Providers and other business partners of IPEA, so that they can share information about their products and services that may be of interest to you, where they are legally entitled to do so.
•     Research. We may share general course data (including quiz or assignment submissions, grades, and forum discussions), information about your activity on our Site, and demographic data from surveys operated by us with our Content Providers and other business partners so that our Content Providers and other business partners may use the data for research related to online education.
•     Marketing and Advertising. We use Personal Data to send marketing and serve advertising, to inform our marketing and advertising strategies and content, to gain a deeper understanding of our audiences, and to personalize our marketing and advertising, making them more relevant to specific audiences. We may share Personal Data with the providers of third-party tools and services for certain activities, particularly for online advertising purposes, including targeted advertising and custom audience activities (for example, we utilize advertising services from Meta, among others). Further information is available in our cookies policy.
•     Disclosure to IPEA Contractors. We use various third-party service providers, vendors, and contractors (collectively, “Contractors”) to support IPEA’s activities, including the purposes listed in this section of the Privacy Notice. Our Contractors will have access to Personal Data to the extent necessary for the provision of their services to IPEA. These Contractors may include vendors and suppliers that provide us with technology, services, and/or content related to the operation and maintenance of the Site or the Content Offerings, or related to IPEA’s other business activities. Access to your Personal Data by these Contractors is limited to the information reasonably necessary for the Contractor to perform its limited function for us.
•     Government Authorities: IPEA may share your Personal Data with various government authorities (such as regulatory bodies, law enforcement activities, and national security organizations) in response to lawful subpoenas, court orders, or other legal processes; to establish or exercise our legal rights or to protect our property; to defend against legal claims; or as otherwise required by law. In such cases, we reserve the right to raise or waive any legal objection or right that may be available to us.
•     Legal Rights and Actions: IPEA may share your Personal Data with government authorities, external advisors and other relevant or affected third parties when we believe it is appropriate: to investigate, prevent, or take action regarding illegal or suspected illegal activities; to protect and defend the rights, property, or safety of IPEA, the Site, our users, customers, or others; and in connection with our Terms of Use and other agreements.
•     Disclosure to Acquirers. IPEA may disclose and/or transfer your Personal Data to an acquirer, assignee, or other successor entity in connection with a sale, merger, or reorganization of all or substantially all of the equity, business, or assets of IPEA to which your Personal Data relates.
•     Devices. If we receive any Personal Data related to the extent to which you use designated e-Readers or other devices to access IPEA materials, we may archive it and use it for research, business, or other purposes.

External Links

For your convenience, we may provide links to sites operated by organizations other than IPEA (“Third Party Sites”) that we believe may be of interest to you. We do not disclose your Personal Data to these Third Party Sites unless we have a lawful basis on which to do so. We do not endorse and are not responsible for the privacy practices of these third-party sites. If you choose to click on a link to one of these Third Party Sites, you should review the privacy policy posted on the other site to understand how that Third Party Site collects and uses your Personal Data.

Retention of Personal Data

We retain your Personal Data only as long as necessary for the purposes for which it was collected, or as required by law, and to protect our legal rights.

Confidentiality & Security of Personal Data

We use industry-standard physical, technical, and administrative security measures to keep your Personal Data confidential and secure, and will not share it with third parties except as provided in this Privacy Notice or when disclosure is necessary in special cases, such as a physical threat to you or others, as permitted by law. Because the Internet is not completely secure, we cannot guarantee the security of your Personal Data. There is a risk that an unauthorized third party may circumvent our security systems or that your information may be intercepted during transmission. It is your responsibility to protect your login information. Please note that e-mail communications are typically not encrypted and should not be considered secure.

Your Rights

You have certain rights in relation to your Personal Data. You can access your Personal Data and confirm that it remains correct and up-to-date, choose whether or not you wish to receive material from us or some of our partners, and request that we delete or provide you with a copy of your Personal Data by logging into the Site, selecting ‘Settings’ from the dropdown in the top right, and scrolling down to find the appropriate option. The ability to delete an account may be disabled for some users, particularly those enrolled in for-credit offerings such as degrees, certificate programs, and other similar programs.

If you would like further information regarding your rights or wish to exercise any of them, you may also contact us. If you reside or are located in the EEA, United Kingdom, Switzerland, or other region that offers similar protections, you have the right to request that we:

•     provide access to any Personal Data we hold about you;
•     prevent the processing of your Personal Data for direct-marketing purposes;
•     update any Personal Data which is out of date or incorrect;
•     delete any Personal Data which we are holding about you;
•     restrict the way that we process your Personal Data;
•     provide your Personal Data to a third-party provider of services; or
•     provide you with a copy of any Personal Data which we hold about you.

We strive to respond to every request promptly, whenever possible, and provide our response within the time period specified by applicable law. Please note that when you delete your Personal Data, residual information may still be stored in our databases, access logs, and other records, which may or may not contain your Personal Data. Please also note that certain Personal Data may be exempt from such requests under specific circumstances, including when we need to retain your Personal Data to comply with a legal obligation. When you email us with a request, we may ask that you provide the necessary information to confirm your identity.

Questions, Suggestions, and Complaints

If you have any privacy-related questions, suggestions, or concerns, please don’t hesitate to contact us via email.