SUM BIble college and Theological Seminary
PRIVACY POLICY
Last Modified: March 17, 2022
Update Log: November 16, 2020 – previous version
OVERVIEW
SUM Bible College and Theological Seminary (the “Company” “we” or “us”) respects your (“User,” “you,” or “your”) privacy and is committed to protecting it through Company’s compliance with this privacy policy and cookie statement (collectively, this “Privacy Policy”). This Privacy Policy describes how Company may collect information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, Device (as defined below), or household (as defined in the CCPA, as defined below), as further described in the WHAT INFORMATION IS COLLECTED Section of this Privacy Policy (“Personal Information”) from the visitors to https://international.sum.edu/ and its various subpages and any other services or features made available through the same (the foregoing collectively defined herein as the “Website”), how Company may use it, with whom Company may share it, what choices you have regarding it, and how Company protects it. This Privacy Policy is incorporated into and is a part of the Terms of Service of Company, which can be found HERE (the “Terms”), and Company encourages you to become familiar with the terms and conditions contained herein and therein. In addition to this Privacy Policy, Company is governed by Family Educational Rights and Privacy Act under the United States Code (“FERPA”), which limits Company’s ability to share information related your student and education records. Nothing in this Privacy Policy limits the protections afforded you under FERPA with regard to Personal Information related to your education records.
CONSENT
By accessing and using the Website, you agree that you have read and understand this Privacy Policy, and that you accept and consent to Company’s privacy practices described in this Privacy Policy.
CHANGES TO PRIVACY POLICY
Company reserves the right to change the terms of this Privacy Policy at any time. Company may change this Privacy Policy and its privacy practices because of changes in relevant and applicable legal or regulatory requirements, the business or business practices of Company, in its attempts to better serve your needs, or for any other reason, in its discretion. Notice of such changes to the Privacy Policy or Company’s privacy practices and a revised Privacy Policy will be posted on the Website.
CONTROLLER
Company is the controller and responsible for your Personal Information. If you have any questions about this Privacy Policy, including any requests to exercise your Legal Rights (as set forth below), please contact Company using the details set out below.
WHAT INFORMATION IS COLLECTED?
Company may collect various types of information from or about you depending on how you use the Website and its various features. You supply Company with various types of information, including Personal Information that you choose to disclose and Company also collects information automatically regarding how you use the Website, which Company may collect as you interact with the Website.
Information you Provide to Company
With respect to Personal Information, you may provide Company with various types of information, including, without limitation, you and your name, address, telephone number, e-mail address, transaction information, as well as billing and payment information that you voluntarily provide through the Website. This information is generally entered into fields in the registration or subscription forms and enables you to take full advantage of the Website. Should you submit any purchase information on or for the Website, the information that you supply during the process may be used to track details about those purchases or uses. Company may collect email addresses from you and other Users, customers, and visitors to the Website for the purpose of communication. If at any time you wish to be removed from Company’s email database, you can request removal by contacting Company at [email protected]. Company reserves the right to contact you via postal mail, email, or telephone for the purpose of administering your account.
Company may also retain the content of and metadata regarding any correspondence you may have with Company or its customer service representatives or other employees or contractors, regardless of the mode of communication by which such correspondence occurred. This includes, without limitation, any information contained and consented to, as described in the Terms. This information helps Company to improve the Website and the materials, products, and services that are offered on the Website, and to more effectively and efficiently respond to both current and future inquiries.
Automatic Information Collection and Tracking
When you access and use the Website, it may use technology to automatically collect:
- Certain details of your access to and use of the Website, including traffic data, location data, logs, and other communication data, and the resources that you access and use on or through the Website.
- Information about your computer, tablet mobile phone, television, or any other device capable of accessing the Website (collectively, “Device”) and internet connection, including the Device’s unique device identifier, IP address, operating system, browser type, mobile network information, and the Device’s telephone number, if applicable.
- Stored information and files, metadata, and other information associated with other files stored on your Device, including, without limitation, photographs, audio and video clips, personal contacts, and address book information.
- Real-time information about the location of your device for analytics.
If you do not want Company to collect this information, do not access the Website. Company also may use these technologies to collect information about your activities over time and across third-party websites, apps, or other online services.
As with many other websites and mobile applications, the web servers used to operate the Website collect certain data pertaining to you and the equipment and communication methods that you use to access the internet and the Website. Without combining this data with other sources of information, the servers do not readily identify you. They do, however, reveal such things as the Internet protocol (“IP”) address assigned to your computer, pages you accessed on the Website or immediately prior to visiting the Website, and the length of time you accessed the Website. This information is collected to, among other things, facilitate Website operation and system administration, to generate aggregate, non-identifiable statistical information, and to improve content and content delivery with regard to the Website and the materials, products, and services that Company makes available on and through the Website.
USE OF COOKIES
Company uses “cookies” (small text files stored on your computer) to help track and customize your access and use of the Website. Cookies store and retain information that helps Company recognize you when you return to the Website following a previous visit. Cookies may also store any login or ID assigned to you by Company and the associated password, which information would be stored in encrypted form. Most popular internet browser packages allow you to configure the browser so as to not accept cookies if you so choose. However, setting your browser to reject cookies may prevent you from taking full advantage of the Website and the materials, products, and other Website that Company makes available on or through the Website.
Company may also use the following:
Flash Cookies. Certain features of the Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on the Web Website. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Company’s Use and Disclosure of your Information below.
Web Beacons. Pages of the Website and e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit Company to, for example, count Users who have visited those pages or opened an email and for other related statistics (for example, recording the popularity of certain content and verifying system and server integrity).
Google Analytics Cookies. Company may use Google Analytics cookies, which is a simple, easy-to-use tool that helps website owners measure how users interact with website content. As a user navigates between web pages, Google Analytics provides website owners JavaScript tags (libraries) to record information about the page a user has seen, such as the URL of the page. The Google Analytics JavaScript libraries use HTTP Cookies to “remember” what a user has done on previous pages / interactions with the website.
Third Party Use of Cookies and Other Tracking Technologies Like Google Analytics
Company may use Google Analytics cookies (see above) and may use these cookies with remarketing using Google Analytics to create ads for you and others. Some content or applications, including advertisements, on the Website may be served by third parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use the Website. The information they collect may be associated with your Personal Information or they may collect information, including Personal Information, about your online activities over time and across different websites and other online services. These third parties may use this information to provide you with interest-based (behavioral) advertising or other targeted content. Company does not control these third-parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.
Company may also collect data about your activities that does not identify you personally or indirectly when you use the Website, or other websites and online services where Company may display ads. This information may include content you view, the day, time, and manner in which you access the content, the products or services you purchase, and your location details associated with your IP address. Company may use this information that it collects to serve you more relevant advertisements. Company also may collect information about where you saw the advertisements it delivers to you and what ads you click on. Company may use remarketing to advertise across the internet and other websites. Please contact Company if you do not want to participate in these programs. You may opt out of Google’s use of cookies by visiting the Google advertising opt-out page at http://www.google.com/settings/Ads Settings page. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.
CHILDREN’S ONLINE PRIVACY PROTECTION ACT
Company does not attempt to collect Personal Information from children without the consent of their parent or legal guardian. Children under 18 years old (19 years old in Nebraska and Puerto Rico and 21 years old in Alabama or Mississippi) are not the target audience for the Website. To protect their privacy, Company prohibits the solicitation of Personal Information from these children or the use of the Services by these children. If you are under the age of 18 (and do not otherwise qualify as an emancipated minor entitled to the same rights as an adult pursuant to applicable law), do not access the Services or submit your email address or any other Personal Information through the Services without the express written consent of your parent or legal guardian.
COMPANY’S USE AND DISCLOSURE OF YOUR INFORMATION
Choices About How Company Uses and Discloses Your Information
Company strives to provide you with choices regarding the Personal Information you provide to it. It has created mechanisms to provide you with the following control over your information:
Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of the Website may then be inaccessible or not function properly.
Disclosure of Your Information for Third-Party Advertising. If you do not want Company to share your Personal Information with unaffiliated or non-agent third parties for promotional purposes, you can opt out by sending an email stating your request to [email protected].
Promotional Offers from Company. If you do not wish to have your email address or contact information used by Company to promote its own or third parties’ products or services, you can opt out by sending an email stating your request [email protected]. If Company has sent you a promotional email, you may send a return email asking to be omitted from future email distributions. This opt-out does not apply to information provided to Company as a result of a purchase made through the Website.
Targeted Advertising. If you do not want Company to use information that it collects or that you provide to it to deliver advertisements according to its advertisers’ target-audience preferences, you can opt out by visiting http://www.google.com/settings/Ads Settings page. Please note, Company does not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose to not have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative on the Network Advertising Initiative’s website.
ACCESSING AND CORRECTING YOUR INFORMATION
You can review and change your Personal Information by sending an email to [email protected] to request access to, correct, or delete any Personal Information that you have provided to Company. Company may be unable to delete your Personal Information without removing your access to and use of all or significant portions of the Website. Company may not accommodate a request to change information if it believes the change would violate any law or legal requirement or cause the information to be incorrect.
If you delete your User Contributions (as defined in the Terms), copies of your User Contributions may remain viewable in cached and archived pages or might have been copied or stored by other Users. Proper access and use of information provided on the Website, including User Contributions, is governed by the Terms.
California residents may have additional Personal Information rights and choices. Please see YOUR CALIFORNIA PRIVACY RIGHTS below for more information.
YOUR CALIFORNIA PRIVACY RIGHTS
If you are a California resident, California law may provide you with additional rights regarding Company’s use of your Personal Information under the California Consumer Privacy Act (“CCPA”). Depending on the circumstances and which Website you use, Company may have disclosed the following categories of your Personal Information for a “business purpose” (as defined in the CCPA) in the preceding twelve (12) months: identifiers; protected characteristics; commercial information; geolocation data; internet or other electronic network activity information; financial, medical, or health insurance information; audio, electronic, visual, thermal, olfactory, or similar information; professional information; education information; and inferences drawn from any of the aforementioned information categories. For more details about the Personal Information Company has collected over the last 12 months, please see the WHAT INFORMATION IS COLLECTED? section above. Company collects this information for, among other things, the business and commercial purposes described in the HOW DOES COMPANY USE THE INFORMATION IT COLLECTS? section below. Company shares this information with, among others, the categories of third parties described in the HOW COMPANY SHARES AND DISCLOSES YOUR INFORMATION section below.
Company does not “Sell” (as such term is defined in the CCPA) the Personal Information it collects but may in the future. The CCPA considers some transfers of Personal Information to third parties in exchange for value as a “Sale,” even if no money changes hands, such as when online identifiers, Device IDs, and other information is shared with third-party businesses to further their own commercial purposes such as generating profiles about individuals. In the event Company decides to Sell your Personal Information, California residents have the right to opt-out of the Sale. Please note that Company can still share Personal Information with third parties if those transfers aren’t “sales,” such as with Company’s Service Providers (as defined in the CCPA). Additionally, Company may use third-party cookies for advertising purposes as further described above.
Subject to certain limitations, the CCPA permits Users of the Website that are California residents to (i) request more information regarding Company’s collection of specific categories or pieces of information (including how Company uses and discloses the information), (ii) request that Company delete your Personal Information (iii) request to opt out of any “sales” that may be occurring, and (iv) not be discriminated against for exercising any of these rights.
California residents may make such a request pursuant to their rights under the CCPA by sending an email to [email protected]. Company will verify your request using the information associated with your account, including email address. Government identification may be required. California residents may also designate an authorized agent to exercise these rights on their behalf. To learn more about your California privacy rights email [email protected] or visit https://www.caprivacy.org.
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of the Website that are California residents to request certain information regarding Company’s disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an email to [email protected] or write to Company at the address below.
HOW COMPANY SHARES AND DISCLOSES YOUR INFORMATION
This section describes how Company may share and disclose your information. Company does not control how you or any other third party choose to share or disclose your information.
User Instructions
Company will share and disclose your information in accordance with your instructions and in accordance with applicable law and legal process.
Disclosure for Legal Purposes
Company reserves the right to disclose any personally identifiable information or other information it collects through the Website or otherwise if it is required to do so by law or if it reasonably believes that the disclosure is necessary in order to (a) fulfill a government request; (b) conform with the requirements of law or to comply with legal process served on it; (c) protect or defend its legal rights or property or third party licensors of any material on the Website; or (d) in an emergency to protect the health or safety of the Users of the Website or the general public.
Your use of the Website, including any disputes arising from it, is subject to this Privacy Policy as well as the Terms and all dispute resolution, limitation on damages, and choice of law provisions therein. Company encourages you to refer to this Privacy Policy on an ongoing basis so that you understand the current Privacy Policy. Unless stated otherwise, the current Privacy Policy applies to all information that Company has about you and your account.
Does Company Disclose Information to Outside Parties?
Company may share your information to individuals outside of Company, including, without limitation, its affiliates, Service Providers, or to any third parties. Currently, Company does not Sell, trade, or otherwise transfer to outside parties your personally identifiable information for a referral fee, but it may do so in the future. Company, in its sole discretion, may also release your information when it believes release is appropriate to comply with the law, enforce Website policies, or protect Company’s or others’ rights, property, or safety. Additional non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.
Business Transfers
As Company continues to grow and develop its business, it is possible that its corporate structure might change or that it might merge or otherwise combine with, or that substantially all of its assets might be acquired by, another company. In any such transactions, customer information generally is, will most probably be, and should be expected to be one of the transferred business assets.
HOW DOES COMPANY USE THE INFORMATION IT COLLECTS?
In addition to the uses mentioned or described above, Company uses the information that it collects from or about you to improve the materials, products, and other services that it makes available on the Website, to notify you of changes made to the Website or new products or services made available on or through the Website, to evaluate your needs and customize content delivered through the Website to you according to those needs, to facilitate the processing of any purchases or uses you make through the Website, to send you promotional material from Company and its affiliates, and for other legitimate and lawful business purposes of Company. Other than to the extent necessary or convenient for Company to perform the Terms, Company may share information collected about you with third parties, such as for certain special programs that it offers in connection with some of its business affiliates, which may involve special promotions and/or pricing, and in which you may or may not be participating. Should you register as a participant in one of those programs, Company will acknowledge your registration and notify its applicable business affiliates of your registration, thereby enabling you to receive the corresponding program benefits. At this time, which may be subject to change in Company’s sole discretion, it is Company’s policy not to sell lists containing Personal Information about Users, purchasers, registrants, or subscribers; however, Company may in the future sell lists containing Personal Information, contact information, including the name, email, and mailing address, or a combination thereof, about Users, purchasers, registrants, or subscribers. By providing your information, you are consenting to such use. You have the right to withdraw consent to marketing at any time by contacting Company at [email protected].
HOW DOES COMPANY PROTECT INFORMATION COLLECTED ABOUT YOU?
Company places a high value on protecting information transmitted via the Website. For this reason, Company uses state-of-the-art security solutions to process payments and to provide secure communication methods. Company’s payment services providers use industry-standard Secure Socket Layer (SSL) encryption technology to safeguard User information. Other security safeguards include, but are not limited to, third-party payment processors, data encryption, firewalls, and physical access controls to building and files. Company does not store payment information. Company takes commercially reasonable measures to secure and protect customer-specific information transmitted via the Website. However, no security system is impenetrable. COMPANY CANNOT AND DOES NOT GUARANTEE AND HEREBY EXPRESSLY DISCLAIMS THAT INFORMATION USERS SUPPLY TO COMPANY OR ON THE WEBSITE WILL BE TOTALLY SECURE.
HOW LONG DOES COMPANY KEEP YOUR PERSONAL DATA?
Company will only retain your personal data for as long as reasonably necessary to fulfill the purposes it collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements. Company may retain your personal data for a longer period in the event of a complaint or if it reasonably believes there is a prospect of litigation in respect to its relationship with you. To determine the appropriate retention period for personal data, Company considers the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which it processes your personal data, and whether it can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting, or other requirements.
LINKED SITES
For your convenience, some hyperlinks may be posted on the Website that link to other websites not under the control of Company. Other company logos may also be posted on the Website as service providers to Company or Users. Please note that this Privacy Policy applies only to the Website and not to other websites of other organizations to which it may link. Company is not responsible for the privacy policies or practices of any other third-party sites. You should make your own inquiries regarding them. In addition, when you initiate a transaction on a website that the Website links to, even if you reached that site through the Website, the information that you submit to complete that transaction becomes subject to the privacy practices of the owner of that linked site. You should read their privacy policies to understand how they use and protect Personal Information that they collect. Company is not responsible for the privacy or information practices of its suppliers or any third-party websites.
WHAT CHOICES DO YOU HAVE?
You may update at any time the information about you derived from information you have provided to Company. You may also ask Company at any time to remove your name from the list of Users who wish to receive electronic communications and e-mail advertisements from Company or its affiliates by simply sending such a request to Company at the addresses given below. Once you opt out, Company will honor your choice until you inform it otherwise. Please remember, however, that if Company has already shared information about you pursuant to your registration and participation in any special programs of its business affiliates (as described above), Company has no control over how such business affiliates may further use that information, and you will need to contact them directly in that regard.
Subject to applicable law, you also have the right to (i) restrict Company’s use of information that constitutes your personal data and (ii) lodge a complaint with your local data protection authority. If you are a resident of the European Economic Area and believe Company maintains your personal data within the scope of the General Data Protection Regulation (“GDPR”), you may direct your questions or complaints to Company or your local supervisory authority.
YOUR LEGAL RIGHTS
You have the right to any of the following at any time:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data Company holds about you and to check that it is lawfully processing it.
Request correction of the personal data that Company holds about you. This enables you to have any incomplete or inaccurate data Company holds about you corrected, though it may need to verify the accuracy of the new data you provide to it.
Request erasure of your personal data. This enables you to ask Company to delete or remove personal data where there is no good reason for it continuing to process it. You also have the right to ask Company to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where Company may have processed your information unlawfully, or where Company is required to erase your personal data to comply with local law. Note, however, that Company may not always be able to comply with your request of erasure for specific legal reasons, which will be notified to you, if applicable, within a reasonable amount of time after your request.
Object to processing of your personal data where Company is relying on a legitimate interest (or those of a third party) and there is something about your particular situation that makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where Company is processing your personal data for direct marketing purposes. In some cases, Company may demonstrate that it has compelling legitimate grounds to process your information, which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask Company to suspend the processing of your personal data in the following scenarios:
- If you want Company to establish the data’s accuracy.
- Where Company’s use of the data is unlawful, but you do not want Company to erase it.
- Where you need Company to hold the data even if Company no longer requires it as you need it to establish, exercise, or defend legal claims.
- You have objected to Company’s use of your data, but Company needs to verify whether it has overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. Company will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information that you initially provided consent for Company to use or where Company used the information to perform a contract with you.
Withdraw consent at any time where Company is relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, Company may not be able to provide certain products or services to you. Company will advise you if this is the case at the time you withdraw your consent.
Any request made by you will be processed within thirty (30) days of you providing notice to Company.
WHO CAN YOU CONTACT FOR MORE INFORMATION?
Should you feel that your privacy or security is being compromised, or have any other questions regarding the privacy practices or this Privacy Policy, please notify Company using the following contact information:
Attn: Legal
SUM Bible College and Theological Seminary
1101 Investment Blvd., Suite 200
El Dorado Hills, CA 95762
Email: [email protected]
YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTAND, AND CONSENT TO THE PRIVACY PRACTICES DESCRIBED IN THIS PRIVACY POLICY.
