Privacy Policy

African American University


 

1. Introduction

This website is owned and operated by African American University, and AAU is committed to protecting the privacy of your personal information. As part of that commitment, we provide this policy to explain our privacy and data protection practices, including what information we collect, how we use it, and what choices you have about collection and use of your personal information. We urge you to review this entire policy. By using one of our sites, you agree to the collection, use and disclosure of your personal information as described in this statement. If you do not agree to the terms of this statement, then please do not use our sites.

Data protection is of a particularly high priority for the management of AAU. The use of the AAU websites is possible without any indication of personal data; however, if you want to use services via our website, collection and processing of personal data could become necessary. We will always obtain your consent to the collection of any personal data.

AAU is a United States company based in Florida, and as such is subject to US privacy laws. By using the site, you agree to our collection, use and maintenance of your information in the United States. However, as an international education marketing company, AAU also strives to provide the privacy and data protection that visitors around the world expect, and therefore we have updated our privacy policy and data processing to be compliant for all visitors with the principles outlined in the General Data Protection Regulation (GDPR) promulgated by the EU and effective May 25, 2018.

This privacy policy covers all AAU sites, including those listed here . We invite you to contact us if you have questions about this policy. You may write to us at:
African America University
30, Zone 2, Paradise Estate, Itamaje Ota, Ogun State,
Nigeria
USA

You may also email us at privacy@africanamericanuniversity.org. This email address is monitored regularly by a team of AAU employees trained in this privacy policy, AAU process regarding data privacy and your rights under the GDPR and other applicable data privacy laws.

As the controller, AAU has implemented numerous technical and organizational measures to ensure the most complete protection of personal data processed through the AAU websites. However, Internet-based data transmissions may in principle have security gaps, so absolute protection cannot be guaranteed.

2. Overview of AAU General Principles

To ensure compliance with the GDPR and to inform you of all of your rights, this policy is long and detailed. We believe a short summary of our most important policies is helpful, while all of the detail is available below.

We do not collect, process or share user data without your clear consent, which is generally given through a check-box that clearly identifies the purpose of the data collection and directs you to this policy.
We do not direct our sites to, nor do we knowingly collect any personal information from, children under thirteen.
We use cookies, but only in a limited way, and not in any manner that can personally identify the data subject.
We collect personal data when you want to use one of our services – registering on one of our sites to search for or inquire to a college or university or to search for scholarships; signing up to receive a newsletter or other related offers from us; requesting services or offers from one of our affiliates; quoting or purchasing an insurance policy through us; or contacting us through a form on one of our sites. In each such instance, we ask for consent as part of the collection process. Each of these types of collection and processing of personal data is addressed in greater detail below.
Our processing of personal data, such as the name, address, email address, or telephone number of a data subject, shall always be in line with the principles of the GDPR, and in accordance with the country-specific data protection regulations applicable to the AAU network.
We comply with all data subject rights provided under applicable US law and the GDPR, including the rights to confirmation, access, rectification, erasure, restriction of processing, and data portability, and the right to object and right to withdraw consent.
AAU is a member of the BBB Online Reliability Program. If you are not able to resolve questions or concerns you have about this policy or our privacy practices by reading this policy or contacting us directly at privacy@africanamericanuniversity.org, you can also contact the Better Business Bureau.

3. Definitions

The privacy policy and data protection declaration of AAU is based on the terms used by the European legislator for the adoption of the GDPR. Our data protection declaration should be legible and understandable for the general public, as well as our customers and business partners. In furtherance of this goal, we would like to first explain the terminology used.

In this data protection declaration, we use, inter alia, the following terms:

Personal data

Personal data means any information relating to an identified or identifiable natural person (“data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Data subject

Data subject is any identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing.
Processing

Processing is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Restriction of processing

Restriction of processing is the marking of stored personal data with the aim of limiting their processing in the future.
Profiling

Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.
Controller or controller responsible for the processing

Controller or controller responsible for the processing is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
Processor

Processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
Recipient

Recipient is a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with European Union (“EU”), EU Member State, US or other applicable law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.
Third party

Third party is a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.
Consent

Consent of the data subject is any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her. Typically on the AAU sites, consent is given by checking a box that describes the proposed use of the data and directs the data subject to this policy.

 

4. Name and Address of the controller

Controller for the purposes of the GDPR and other laws related to data protection is:
Envisage International Corporation
30, Zone 2, Paradise Estate, Itamaje Ota, Ogun State,
Nigeria
Phone: (+234) 08173175540
Email: privacy@africanamericanuniveristy.org
Website: www.africanamericanuniveristy.org

5. Cookies

The Internet pages of the AAU network use cookies. Cookies are text files that are stored in a computer system via an Internet browser.

Many Internet sites and servers use cookies. Many cookies contain a so-called cookie ID. A cookie ID is a unique identifier of the cookie. It consists of a character string through which Internet pages and servers can be assigned to the specific Internet browser in which the cookie was stored. This allows visited Internet sites and servers to differentiate the individual browser of the data subject from other Internet browsers that contain other cookies. A specific Internet browser can be recognized and identified using the unique cookie ID.

Through the use of cookies, the AAU network can provide the users of these websites with more user-friendly services that would not be possible without the cookie setting.

By means of a cookie, the information and offers on our websites can be optimized with the user in mind. Cookies allow us, as previously mentioned, to recognize our website users. The purpose of this recognition is to make it easier for users to utilize our website. The website user that uses cookies, e.g. does not have to enter access data each time the website is accessed, because this is taken over by the website, and the cookie is thus stored on the user’s computer system. Another example is the cookie of a shopping cart in an online shop. The online store remembers the articles that a customer has placed in the virtual shopping cart via a cookie.

The data subject may, at any time, prevent the setting of cookies through our websites by means of a corresponding setting of the Internet browser used, and may thus permanently deny the setting of cookies. Furthermore, already set cookies may be deleted at any time via an Internet browser or other software programs. This is possible in all popular Internet browsers. If the data subject deactivates the setting of cookies in the Internet browser used, not all functions of our websites may be entirely usable.

6. Collection of insurance application and purchase information

Users can purchase international travel and health insurance policies directly through AAU sites, and can apply for international major medical policies. AAU passes the collected data directly through to our insurance company partners for processing. AAU retains Personal Information which includes name, address, email, phone number, date of birth, policy number, travel dates and destinations, home country and citizenship, which information is necessary for AAU to provide its services to you. AAU will collect Confidential Information necessary for processing your application, like credit card numbers, passport numbers or health history information, to pass on to its insurance partners for processing, but AAU does not retain any Confidential Information. As a general matter and applicable to all of its websites, AAU does not collect, store or retain any Confidential Information for its own use in any way. AAU’s insurance partners have each confirmed their compliance with HIPAA, GDPR and any other applicable data privacy laws, and their privacy policies are all freely available from their websites. Here are the privacy policies of our primary carrier partners:

Tokio Marine HCC Medical Insurance Services: https://www.hccmis.com/about-hccmis/privacy-policy/

International Medical Group: https://www.imglobal.com/legal/privacy-policy

Seven Corners, Inc.: https://www.sevencorners.com/about/legal/privacy-policy

7. Collection of general data and information

The websites of the AAU network collects a series of general data and information when a data subject or automated system calls up the website. This general data and information are stored in the server log files. Collected may be (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our website (so-called referrers), (4) the sub-websites, (5) the date and time of access to the Internet site, (6) an Internet protocol address (IP address), (7) the Internet service provider of the accessing system, and (8) any other similar data and information that may be used in the event of attacks on our information technology systems.

When using these general data and information, AAU does not draw any conclusions about the data subject. Rather, this information is needed to (1) deliver the content of our websites correctly, (2) optimize the content of our websites as well as its advertisement, (3) ensure the long-term viability of our information technology systems and website technology, and (4) provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack. Therefore, the AAU network analyzes anonymously collected data and information statistically, with the aim of increasing the data protection and data security of our enterprise, and to ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files are stored separately from all personal data provided by a data subject.

8. Registration on our websites

The data subject has the possibility to register on AAU websites by entering personal data which can include name, address, email, home country, country of citizenship, highest education level achieved, degree sought and area of study.

By registering on the websites of the controller, the IP address assigned by the Internet service provider (ISP) and used by the data subject date, and time of the registration are also stored. The storage of this data takes place against the background that this is the only way to prevent the misuse of our services, and, if necessary, to make it possible to investigate committed offenses. Insofar, the storage of this data is necessary to secure the controller. This data is not passed on to third parties unless there is a statutory obligation to pass on the data, or if the transfer serves the aim of criminal prosecution.

The registration of the data subject, with the voluntary indication of personal data, is intended to enable the controller to offer the data subject contents or services that may only be offered to registered users due to the nature of the matter in question. Registered persons are free to change the personal data specified during the registration at any time, or to have them completely deleted from the data stock of the controller.

In addition, AAU offers a “school search” through which users can search, sort and select which colleges and universities they may be interested in inquiring to. Upon request of the data subject, AAU will deliver the inquiry, including the personal data, to the selected college or university on behalf of the data subject. Personal data will never be shared or delivered to colleges, universities or other partners without the clear consent of the data subject.

AAU shall, at any time, provide information upon request to each data subject as to what personal data are stored about the data subject. In addition, AAU shall correct or erase personal data at the request or indication of the data subject, insofar as there are no statutory storage obligations. Please send any data requests to privacy@africanamericanuniversity.org for prompt handling.

9. Subscription to our newsletters

On the websites of the AAU network, users are given the opportunity to subscribe to AAU’s newsletters. The input mask used for this purpose determines what personal data are transmitted, as well as when the newsletter is ordered from the controller.

The AAU network informs its customers and business partners regularly by means of newsletters and other emails about AAU and partner resources and offers. AAU’s newsletters may only be received by the data subject if (1) the data subject has a valid email address and (2) the data subject registers for the newsletter delivery.

During the registration for the newsletter, we also store the IP address of the computer system assigned by the Internet service provider (ISP) and used by the data subject at the time of the registration, as well as the date and time of the registration. The collection of this data is necessary in order to understand the (possible) misuse of the email address of a data subject at a later date, and it therefore serves the aim of the legal protection of the controller.

The personal data collected as part of a registration for the newsletters will only be used to send our newsletters and other relevant email communications regarding resources and offers related to the AAU network. There will be no transfer of personal data collected by the newsletter service to third parties, except to the email service provider used by AAU for the purpose of managing the email list and sending emails. AAU’s current ESP is YesMail, which has confirmed its compliance with the GDPR. The subscription to our newsletters may be terminated by the data subject at any time. For the purpose of unsubscribing to the newsletter, a corresponding link is found in each newsletter and other email. Once unsubscribed, AAU and its email service provider retains limited personal data to retain the record of the unsubscribe. However the consent to the storage of this limited personal data related to the unsubscribe may be revoked at any time. To completely remove any personal data from any AAU mailing lists, including the record of your unsubscribe, please send an email request to privacy@africanamericanuniversity.org.

10. Newsletter and Email Tracking

The newsletters and emails of the AAU network contains so-called tracking pixels. A tracking pixel is a miniature graphic embedded in such emails, which are sent in HTML format to enable log file recording and analysis. This allows a statistical analysis of the success or failure of online marketing campaigns. Based on the embedded tracking pixel, the AAU network may see if and when an email was opened by a data subject, and which links in the email were called up by data subjects.

Such personal data collected in the tracking pixels contained in the newsletters and emails are stored and analyzed by the controller in order to optimize the shipping of the newsletters and emails, as well as to adapt the content of future newsletters even better to the interests of the data subject. These personal data will not be passed on to third parties. Data subjects are at any time entitled to revoke the declaration of consent to newsletter and email receipt and tracking by unsubscribing through the link found on each newsletter or email or by sending a request to privacy@africanamericanuniversity.org.

11. Contact possibility via the website

The websites of the AAU network contain electronic contact forms which generate an instant communication to AAU. If a data subject contacts the controller by email or via a contact form, the personal data transmitted by the data subject are automatically stored. Such personal data transmitted on a voluntary basis by a data subject to the data controller are stored for the purpose of processing or contacting the data subject. There is no transfer of this personal data to third parties.

13. Routine erasure and blocking of personal data

The data controller shall process and store the personal data of the data subject only for the period necessary to achieve the purpose of storage, or as far as this is granted by the European legislator, US law or other applicable law.

If the storage purpose is not applicable, or if a storage period prescribed by applicable law expires, the personal data are routinely blocked or erased in accordance with legal requirements.

14. Rights of the data subject

Right of confirmation

Each data subject shall have the right granted by the European legislator to obtain from the controller the confirmation as to whether or not personal data concerning him or her are being processed. If a data subject wishes to avail himself of this right of confirmation, he or she may, at any time, send an email request to privacy@africanamericanuniversity.org.
Right of access

Each data subject shall have the right granted by the European legislator to obtain from the controller free information about his or her personal data stored at any time and a copy of this information. Furthermore, the European directives and regulations grant the data subject access to the following information:
The purposes of the processing;
The categories of personal data concerned;
The recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
Where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
The existence of the right to request from the controller rectification or erasure of personal data, or restriction of processing of personal data concerning the data subject, or to object to such processing;
The existence of the right to lodge a complaint with a supervisory authority;
Where the personal data are not collected from the data subject, any available information as to their source;
The existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the data subject.

Furthermore, the data subject shall have a right to obtain information as to whether personal data are transferred to a third country or to an international organisation. Where this is the case, the data subject shall have the right to be informed of the appropriate safeguards relating to the transfer.

If a data subject wishes to avail himself of this right of access, he or she may, at any time, send a request to privacy@africanamericanuniversity.org.
Right to rectification

Each data subject shall have the right granted by the European legislator to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

If a data subject wishes to exercise this right to rectification, he or she may, at any time, send a request to privacy@africanamericanuniversity.org.
Right to erasure (Right to be forgotten)

Each data subject shall have the right granted by the European legislator to obtain from the controller the erasure of personal data concerning him or her without undue delay, and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies, as long as the processing is not necessary:
The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.
The data subject withdraws consent to which the processing is based according to point (a) of Article 6(1) of the GDPR, or point (a) of Article 9(2) of the GDPR, and where there is no other legal ground for the processing.
The data subject objects to the processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) of the GDPR.
The personal data have been unlawfully processed.
The personal data must be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.
The personal data have been collected in relation to the offer of information society services referred to in Article 8(1) of the GDPR.

If one of the aforementioned reasons applies, and a data subject wishes to request the erasure of personal data stored by the AAU network, he or she may, at any time, send a request to privacy@africanamericanuniversity.org. An employee of AAU network shall promptly ensure that the erasure request is completed.

Where the controller has made personal data public and is obliged pursuant to Article 17(1) to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform other controllers processing the personal data that the data subject has requested erasure by such controllers of any links to, or copy or replication of, those personal data, as far as processing is not required. An employees of AAU will arrange the necessary measures in individual cases.
Right of restriction of processing

Each data subject shall have the right granted by the European legislator to obtain from the controller restriction of processing where one of the following applies:
The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data.
The processing is unlawful and the data subject opposes the erasure of the personal data and requests instead the restriction of their use instead.
The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims.
The data subject has objected to processing pursuant to Article 21(1) of the GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject.

If one of the aforementioned conditions is met, and a data subject wishes to request the restriction of the processing of personal data stored by the AAU network, he or she may at any time contact any employee of the controller. The employee of AAU will arrange the restriction of the processing.
Right to data portability

Each data subject shall have the right granted by the European legislator, to receive the personal data concerning him or her, which was provided to a controller, in a structured, commonly used and machine-readable format. He or she shall have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, as long as the processing is based on consent pursuant to point (a) of Article 6(1) of the GDPR or point (a) of Article 9(2) of the GDPR, or on a contract pursuant to point (b) of Article 6(1) of the GDPR, and the processing is carried out by automated means, as long as the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

Furthermore, in exercising his or her right to data portability pursuant to Article 20(1) of the GDPR, the data subject shall have the right to have personal data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others.

In order to assert the right to data portability, the data subject may at any time contact AAU by sending an email to privacy@africanamericanuniversity.org.
Right to object

Each data subject shall have the right granted by the European legislator to object, on grounds relating to his or her particular situation, at any time, to processing of personal data concerning him or her, which is based on point (e) or (f) of Article 6(1) of the GDPR. This also applies to profiling based on these provisions.

AAU shall no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defence of legal claims.

If the AAU network processes personal data for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing. This applies to profiling to the extent that it is related to such direct marketing. If the data subject objects to the AAU network to the processing for direct marketing purposes, the AAU network will no longer process the personal data for these purposes.

In addition, the data subject has the right, on grounds relating to his or her particular situation, to object to processing of personal data concerning him or her by the AAU network for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

In order to exercise the right to object, the data subject may contact any employee of the AAU network. In addition, the data subject is free in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to use his or her right to object by automated means using technical specifications.
Automated individual decision-making, including profiling

We do not use automatic decision-making or profiling. However, in offering insurance products that vary in their eligibility based on country of residence, travel destination and age, our insurance partners will make automated decisions as to your eligibility for their products. When they make and automated decision about you, you have the right to contest the decision, express your point of view, and to require a human review of the decision. Contact the appropriate insurance partner directly for additional information.
Right to withdraw data protection consent

Each data subject shall have the right granted by the European legislator to withdraw his or her consent to processing of his or her personal data at any time.

If the data subject wishes to exercise the right to withdraw the consent, he or she may, at any time, contact any employee of the AAU network.

15. Legal basis for the processing

Art. 6(1) lit. a GDPR serves as the legal basis for processing operations for which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is party, as is the case, for example, when processing operations are necessary for the supply of goods or to provide any other service, the processing is based on Article 6(1) lit. b GDPR. The same applies to such processing operations which are necessary for carrying out pre-contractual measures, for example in the case of inquiries concerning our products or services. Is our company subject to a legal obligation by which processing of personal data is required, such as for the fulfillment of tax obligations, the processing is based on Art. 6(1) lit. c GDPR. In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or of another natural person. This would be the case, for example, if a visitor were injured in our company and his name, age, health insurance data or other vital information would have to be passed on to a doctor, hospital or other third party. Then the processing would be based on Art. 6(1) lit. d GDPR. Finally, processing operations could be based on Article 6(1) lit. f GDPR. This legal basis is used for processing operations which are not covered by any of the abovementioned legal grounds, if processing is necessary for the purposes of the legitimate interests pursued by our company or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data. Such processing operations are particularly permissible because they have been specifically mentioned by the European legislator. He considered that a legitimate interest could be assumed if the data subject is a client of the controller (Recital 47 Sentence 2 GDPR).

16. The legitimate interests pursued by the controller or by a third party

Where the processing of personal data is based on Article 6(1) lit. f GDPR our legitimate interest is to carry out our business in favor of the well-being of all our employees and the shareholders.

17. Period for which the personal data will be stored

The criteria used to determine the period of storage of personal data is the respective statutory retention period. After expiration of that period, the corresponding data is routinely deleted, as long as it is no longer necessary for the fulfillment of the contract or the initiation of a contract.

18. Changes to this Policy

We may need to modify this privacy policy from time to time to reflect our current privacy practices, so please check back to view any changes. When you register or submit your email address on any AAU site, you acknowledge receipt of this privacy policy and agree to receive future notices about it online. We make this policy continuously available online. We will inform you of material modifications to this policy in the future by posting changes on the AAU sites and/or sending you email where appropriate.

19. Data Privacy and Protection Provisions From Web Service Companies Like Google and Facebook

AAU uses generally-available third party services on its websites, like Google Analytics, AdSense, AdWords, and Google Remarketing. AAU also includes links or integrates with Facebook, Instagram, LinkedIn and other social media platforms, as well as other web services companies like SalesForce, YesMail and others. Each of these third parties has its own data protection and privacy provisions, and detailed descriptions of each third-party, the service they provide and links to their data privacy and protection provisions are available on this page.

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