Privacy Policy

Minerva and Minerva University jointly collect information on our respective websites and during the Minerva University application process.

Please see the Minerva Privacy Policy and the Minerva University Privacy Policy for more detailed information.

Effective date: June 14, 2018

Introduction

Minerva University (MU) takes your privacy very seriously. This privacy and cookie policy ("Policy") describes how MU ("Company," "we," and "our") collects, uses and shares personal data when using the Minerva University website (the "Site") and during the Minerva University application process (the "Application process"). Please read the following information carefully to understand our views and practices regarding your personal data and how we will treat it.

Particularly Important Information

Who we are: For the purpose of applicable data protection legislation, the data controller of your personal data is Minerva University of

Minerva University 14 Mint Plaza, Suite 300 San Francisco, CA 94103

MU is currently partnering with the Minerva Project, which provides it with services. During this partnership, Minerva Project and MU jointly collect and share personal information about inquirer applicants to the Minerva University for admissions, administrative, reporting, and operational purposes.

Must Read Sections: We draw your attention in particular to the sections entitled "International Data Transfer" and "Your Rights."

Changes to this Policy: We will post any modifications or changes to the Policy on our site. We reserve the right to modify the Policy at any time, so we encourage you to review it frequently. The "Last Updated" legend above indicates when this Policy was last changed. If we make any material change(s) to the Policy, we will notify you via email prior to such changes(s) taking effect.

1. Purposes of Processing

What is personal data?

We collect information about you in a range of forms, including personal data. As used in this Policy, "personal data" is as defined in the General Data Protection Regulation 2018 and any successor legislation. This includes any information which, either alone or in combination with other information we hold about you, identifies you as an individual, including, for example, your name, postal address, email address and telephone number.

Why do we need your personal data?

We will only process your personal data in accordance with applicable data protection and privacy laws. We need certain personal data in order to provide you with access to the site and to process your application for admission to Minerva University. If you created a profile/registered with us, you will have been asked to tick a box to agree to provide this information in order to access our Application process. This consent provides us with the legal basis we require under applicable law to process your data. You maintain the right to withdraw such consent at any time. If you do not agree to our use of your personal data in line with this Policy, please do not use our site.

If you are accepted as a student and elect to register and enroll with us, personal information collected as part of the Application process will become part of your ongoing student record. That student record will be subject to a different privacy policy that you will receive prior to registration and enrollment.

2. Collecting Your Personal Data

We collect information about you in the following ways:

Information You Give Us.

The Minerva University application is multi-step process where you'll be asked to provide information about yourself to help us evaluate your application for admission. Different applicants will likely provide different kinds of information, so what is collected from each applicant will vary. No two applications or applicants will be the same. The following are the general types of information we will collect during the application process:

Basic personal identifiers and contact information such as your name, address, phone number, date of birth, country of citizenship and email address that you provide to us. In addition, we may ask for other personal information to better understand our applicant pool and to allow us to accommodate our students' needs in their educational and living environments.
Applicant account information like a username and password to allow you to enter, modify, and submit your application to us online. Information about your past educational background and performance along with information about which programs or schools you've attended. This will include information such as your academic institution or program name and address, transcripts from those schools or educational programs, metrics of academic achievement such as grade point average, class rank, and test scores, and recommendations and assessments from teachers, counselors, school administrators, and other trusted adults, mentors, or peers. In addition to the information you provide to us, we may independently verify information you provide or seek additional information about your past educational achievement to support your application materials.
Information to better understand your educational potential, readiness, interests, creativity, cognitive ability, and personality. This, too, will vary by applicant. This may include written, verbal, or online assessments, interviews, personal statements, video, audio or other media you provide, and other assessments.
Information about your interests and activities in order to understand your accomplishments outside of the classroom.
Identification including passport or other official identification and current photographs, which are used to guard against and detect cheating on admission challenges.
Parent information, which is required if you are under the age of 18.
Payment information for application fees. MU may request credit card or other payment information in connection with application fees associated with the application process. MU does not store credit card numbers or other financial information, instead we use a payment processing partner to facilitate this on our behalf.
The personal data you provide when you report a problem with your application or when we provide you with customer support.
The personal data you provide when you correspond with us by phone, email or otherwise.

Information We Get from Others

We may also get information about you from other sources, for example, if you have agreed to share information with one of our partners, such as organizations that refer or sponsor prospective students, we may add this to information we get from the application. In addition, we may also receive information about you from partners, educational institutions, or other third party sources that we may combine with other personal information we may hold about you.

Information Automatically Collected

We automatically log information about you and your computer or mobile device when you access our site and application. For example, when visiting https://www.minerva.edu/, we log your computer or mobile device operating system name and version, manufacturer and model, browser type, browser language, screen resolution, the website you visited before browsing to our site, pages you viewed, how long you spent on a page, access times and information about your use of and actions on our site. We collect this information about you using cookies. Please refer to the sections on cookies and Pixel Tags below. In addition, we receive information that your computer or device automatically sends to us like your IP address, a date and timestamp of your visit, a referring URL of the website you were visiting prior to coming to our website, and information about the type of browser, operating system, and device you are using to access our site.

Automated Decision Making and Profiling

We do not use your personal data for the purposes of automated decision-making. However, we may do so in order to fulfil obligations imposed by law, in which case we will inform you of any such processing and provide you with an opportunity to object.

3. Cookies

What are cookies?

We may collect information using "cookies." Cookies are small data files stored on the hard drive of your computer or mobile device by a website. We 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 are used only by us to recognize your computer or mobile device when it revisits our Site and Application process; and (2) third-party cookies, which are served by service providers on our Site and Application process, and can be used by such service providers 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	Purpose
Necessary Cookies	Necessary cookies help us make our Site and Application process usable by enabling basic functions like page navigation, access to secure areas of the website, and helping the content of the pages you request load quickly. The Site and Application process cannot function properly without these cookies.
Preference Cookies	Preference cookies enable a website to remember information that changes the way our Site and Application process behave or look, like your preferred language or the region that you are in. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you visit our Site and Application process.
Statistic Cookies	Statistic cookies help us understand how visitors interact with our Site and Application process by collecting and reporting information anonymously. These cookies are used to collect information about traffic to our Site and Application process and how users use our Site and Application process. The information gathered does not identify any individual visitor. It includes the number of visitors to our Site and Application process, the websites that referred them to our Site and Application process, the pages they visited on our Site and Application process, what time of day they visited our Site and Application process, whether they have visited our Site and Application process before, and other similar information. We use this information to help operate our Site and Application process more efficiently, to gather broad demographic information and to monitor the level of activity on our Site and Application process. You may find an up-to-date listing of all cookies, their providers, and purpose on our Cookie Declaration page.
Marketing cookies	Marketing cookies are used to track visitors across websites, including our Site and Application process. These help us measure and understand the effectiveness of our advertising campaigns across other third-party services.

Opt-In consent for cookies

We automatically issue Necessary cookies. For Preference, Statistic, and Marketing cookies, we provide you with the option to opt in to receive these cookies. We only issue these cookies after you have explicitly opted in. You may review the cookies at any time at our Cookie Declaration page.

Disabling cookies

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" facility). Many browsers are set to accept cookies until you change your settings.

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 and www.youronlinechoices.com.uk.

If you do not accept our cookies, you may experience some inconvenience in your use of our Site and Application process. 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 or Application process.

4. Pixel Tags

We may also use pixel tags (which are also known as web beacons and clear GIFs) on our Site and Application process to track the actions of users on our Site and Application process. 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. Pixel tags measure the success of our marketing campaigns and compile statistics about usage of our Site and Application process, so that we can manage our content more effectively. The information we collect using pixel tags is not linked to our users' personal data.

5. 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 respond to do not track signals. To find out more about "Do Not Track," please visit http://www.allaboutdnt.com.

6. Using Your Personal Data

We may use your personal data as follows:

to operate and improve the design and usability of our sites and services
to manage your account, including to communicate with you regarding your application
to respond to inquiries, and to provide information to you that is requested from us including technical notices, updates, security alerts, and support and administrative messages
to evaluate you as a candidate for admission to Minerva University. In addition, personal information provided in your application may be used to determine your eligibility for scholarships and other awards.
to look at application information in the aggregate, without personal identifiers, to better understand characteristics of our applicant pool in any given year or over time. We do this to improve the application process.
to process payments you make via our Site
with your consent, to send you emails about upcoming activities and other news, including information about our services. You may opt-out of receiving such information at any time: such marketing emails tell you how to "opt-out." Please note, even if you opt out of receiving marketing emails, we may still send you non-marketing emails. Other communications include emails about your account with us and our dealings with you as we believe necessary or appropriate (a) to comply with applicable laws; (b) to comply with lawful requests and legal process, including to respond to requests from public and government authorities; (c) to enforce our Policy; and (d) to protect our rights, privacy, safety or property, and/or that of you or others, as described in the "Sharing of your Personal Data" section below.

7. Sharing Your Personal Data

We may share your personal data as follows:

Third Parties Designated by You. We may share your personal data with third parties where you have provided your consent to do so.
Our Third Party Service Providers. We may share your personal data with our third-party service providers who provide services to Minerva University such as educational services, data analysis, payment processing, information technology and related infrastructure provision, fulfillment, customer service, email delivery, auditing and other similar services. These third parties are only permitted to use your personal data to the extent necessary to enable them to provide their services to us. They are required to follow our express instructions and to comply with appropriate security measures to protect your personal data.
Partners. We may share some or all of your personal data with our partners, in which case we will require our affiliates to comply with this Policy. In particular, you may let us share personal data with our partners where you wish to receive communications from them.
Organization Restructuring. We may share personal data if there were a sale or transfer of all or a part of our business or assets. These transactions can include a merger, financing, acquisition, or bankruptcy transaction or proceeding.
MU may share aggregated or non-personally identifiable information from MU applications publicly and with other organizations
Other Disclosures. We may share personal data as we believe necessary or appropriate: (a) to comply with applicable laws; (b) to comply with lawful requests and legal process, including to respond to requests from public and government authorities to meet national security or law enforcement requirements; (c) to enforce our Policy; and (d) to protect our rights, privacy, safety or property, and/or that of you or others.

8. Anonymous Data

When we use the term "anonymous data," we are referring to data and information that does not permit you to be identified or identifiable, either alone or when combined with any other information available to a third party.

We may create anonymous data from the personal data we receive about you and other individuals whose personal data we collect. Anonymous data might include analytics information and information collected by us using cookies. We make personal data into anonymous data by excluding information (such as your name) that makes the data personally identifiable to you. We use this anonymous data to analyze usage patterns in order to make improvements to our site and application.

9. Third Party Sites

Our site may contain links to third-party websites and features. This Policy does not cover the privacy practices of such third parties. These third parties have their own privacy policies and we do not accept any responsibility or liability for their websites, features or policies. Please read their privacy policies before you submit any data to them. For example, Medium, Twitter, Instagram, Facebook, Youtube, LinkedIn.

10. User Generated Content

You may share personal data with us when you submit user-generated content to social media sites, such as forums, message boards and blogs. Please note that any information you post or disclose on such applications or sites will become public information, and will be available to other users and to the general public. We urge you to be very careful when deciding to disclose your personal data, or any other information, on social media sites . Such personal data and other information will not be private or confidential once it is published on such sites.

11. International Data Transfer

Your information, including personal data that we collect from you, may be transferred to, stored at and processed by us and our affiliates and other third parties outside the country in which you reside, including, but not limited to the United States, where data protection and privacy regulations may not offer the same level of protection as in other parts of the world. By using our Site and Application process, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy.

12. Security

MU takes reasonable measures to protect your personal information in an effort to prevent loss, misuse and unauthorized access, disclosure, alteration, and destruction. We take the following steps to help keep your data secure:

We encrypt data transmissions using SSL technology.
We have reasonable measures in place to protect the physical security of records we store on our premises.
We restrict access to personal information to MU employees, contractors, and agents who need to know that information in order to process it for us or as part of their job requirements, and who are subject to confidentiality or employment agreements.

MU will never ask you for financial information or for your account password in an email or phone call. Please be aware, however, that despite our efforts, no security measures are perfect or impenetrable and no method of data transmission can be guaranteed against any interception or other type of misuse. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us using the details in Section 18 below.

13. Retention

We will only retain your personal data as long reasonably required under our Records Retention Policy unless a longer retention period is required or permitted by law (for example for regulatory purposes).

14. Our Policy on Children

Our Site and application process 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 using the details in Section 18 below. We will delete such information from our files as soon as reasonably practicable.

15. Sensitive Personal Data

Subject to the following paragraph, we ask that you not send us, and you not disclose, any sensitive personal data (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 or through the Site, Application process, or otherwise to us.

If you send or disclose any sensitive personal data to us when you submit user generated content to our Site or Application process, you consent to our processing and use of such sensitive personal data in accordance with this Policy. If you do not consent to our processing and use of such sensitive personal data, you must not submit such user-generated content to our Site or Application process.

16. Your Rights

Opt-out. You may contact us anytime to opt-out of: (i) direct communications; (ii) automated decision-making and/or profiling; (iii) our collection of sensitive personal data; (iv) any new processing of your personal data that we may carry out beyond the original purpose; or (v) the transfer of your personal data outside the European Economic Area (EEA). Please note that your use of some of the site/application may be ineffective upon opt-out.
Access. You may access the information we hold about you via your profile/account or by contacting us directly and access will be provided within a reasonable period of time.
Amend. You can also contact us to update or correct any inaccuracies in your personal data.
Move. Your personal data are portable - i.e. you to have the flexibility to move your data to other service providers as you wish.
Erase and forget. In certain situations, for example when the information we hold about you is no longer relevant or is incorrect, you can request that we erase your data.

If you wish to exercise any of these rights, please contact us using the details in Section 18 below. In your request, please make clear: (i) what personal data are concerned; and (ii) which of the above rights you would like to enforce. For your protection, we may only implement requests with respect to the personal data associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable and in any event, within one month of your request. Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting such change or deletion.

17. Complaints

We are committed to resolve any complaints about our collection or use of your personal data. If you would like to make a complaint regarding this Policy or our practices in relation to your personal data, please contact us at privacy@minerva.edu. We will reply to your complaint as soon as we can and in any event, within 45 days. We hope to resolve any complaint brought to our attention; however if you feel that your complaint has not been adequately resolved, you reserve the right to contact the appropriate governmental authority. In California, this is the Bureau of Private Postsecondary Education (www.bppe.cal.gov), in the EU, it is the local data protection supervisory authority, and in the UK, the Information Commissioner's Office.

18. Contact Information

We welcome your comments or questions about this Policy. You may contact us in writing at privacy@minerva.edu or