Privacy Notice

V1.0—Last modified on September 1, 2020

Introduction

AEFIS, INC (“Company,” “we,” or “us”) respects your privacy and we are committed to protecting it through our compliance with this Privacy Notice (this “notice”).

This notice describes the types of information we may collect from you or that you may provide when you visit the website http://www.aefisacademy.org (including all web pages, sub-domains and sub-parts therein contained, the “Website”) and any and all services available on or through the Website or otherwise provided by AEFIS (collectively, the “Services”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This notice applies to information we collect:

  • On this Website or through the Services.
  • In email, text, and other electronic messages between you and this Website or through the Services.

It does not apply to information collected by:

  • Us offline or through any other means, including on any other website operated by Company or any third party; or
  • Any third party, including through any application or content that may link to or be accessible from or on the Website.

Please read this notice carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this privacy notice. This notice may change from time to time (see “Changes to Our Privacy Notice“ section below). Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the notice periodically for updates.

Information We Collect About You and How We Collect It

We collect several types of information from and about users of our Website, including information:

  • By which you may be personally identified, such as name, e-mail address, your institution, position or any other identifier by which you may be contacted online or offline (“personal information”);
  • That is about you but individually does not identify you; and/or
  • About your internet connection, the equipment you use to access our Website, and usage details.

We do not collect sensitive personal information; including, but not limited to, government issued identifications, medical or health conditions, political opinions, religious or philosophical beliefs, trade union membership or other sensitive information.

We collect this information:

  • Directly from you when you provide it to us.
  • Automatically as you navigate through the Website or access the Services. Information collected automatically may include usage details, IP addresses, and information collected through cookies.
  • All data values are stored encrypted. Please note we do not support the collection or storage of any sensitive personal information relating to government issued identifications from you on our Website or through our Services.
  • Certain parts of the Website uses Google Analytics, which is provided by Google Inc. It uses cookies to collect, for example, information about the operating system and the browser that you use, your IP address, the website you previously accessed (referrer URL) and the date and time of your visit to the Website.  On subsequent repeated visits to the Website, frequently used information is automatically displayed for you.  We are able to track your usage patterns with the help of the cookies. The information generated by cookies about the use of the Website is transmitted to a Google server, which may be located within or outside of, the United States, and stored there. Google will use this information to evaluate your use of the Website.  Google may transfer these rights to third parties insofar as it is required to do so by law or in order that data may be processed on Google’s behalf. You can visit https://policies.google.com/technologies/partner-sites to learn more about Google Analytics’ use of cookies.
  • Cookies may be set by a third party other than us. These “third-party cookies” may, for example, originate from websites such as Vimeo, Zoom or other social media services such as Facebook or Twitter for which aefis.com has implemented “plug-ins.” Since the cookie policies of these sites change over time, you should determine their policies by visiting the privacy policy pages of these sites directly.

Information You Provide to Us. 

The information we collect on or through our Website or Services may include:

  • Information that you provide by filling in forms on our Website or through our Services. This includes information provided at the time of registering to use our Website, subscribing to informational communications, or requesting Services. We may also ask you for information when you report a problem with our Website or Services.
  • Records and copies of your correspondence (including email addresses), if you contact us.
  • Details of transactions you carry out through our Website and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Website.
  • Your search queries on the Website.

Information We Collect Through Automatic Data Collection Technologies.

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

  • Details of your visits to our Website, including traffic data, location data, page views, referring URL, and other communication data and the resources that you access and use on the Website.
  • Information about your computer and internet connection, including your IP address, operating system, and browser type.

The Website also may access metadata and other information associated with other files stored on your device. Any such information that we may collect through automatic technological means will be aggregated as statistical data and will not include personal information (or will have personal identifiers removed), but we may maintain or associate this data with information we collect in other ways or receive from third-parties.

The information we collect automatically may include personal information, or we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Website and  the Services and to deliver a better and more personalized service, including by enabling us to:

  • Estimate our audience size and usage patterns.
  • Store information about your preferences, allowing us to customize our Website and Services according to your individual interests.
  • Speed up your searches.
  • Recognize you when you return to our Website.

The technologies we use for this automatic data collection may include:

  • Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

  • To present our Website and its contents to you.
  • To provide you with information, products, and services that you request from us.
  • To fulfill any other purpose for which you provide it.
  • To provide you with notices about your account.
  • To notify you about changes to our Website or any products or services we offer or provide though it.
  • To allow you to participate in interactive features on our Website.
  • In any other way we may describe when you provide the information.
  • For any other purpose with your consent.
  • Carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for delivery, billing, and collection.

How We Will NOT Use Your Information

We will NOT use information that we collect about you or that you provide to us, including any personal information:

  • To contact you about goods and services that may be of interest to you.
  • To share with other organizations, without your consent.
  • To any purpose that violates AEFIS Academy Core Values

Using the Website and Services from Outside of the United States

This notice is intended to cover collection of information from residents of and within the United States.  If you are visiting the Website or accessing the Services from outside the United States, please be aware that the data protection laws governing this Website might not be as restrictive as those in your country.  Your personal information may be transferred to, stored, and processed within the United States.  Additionally, we may transfer your personal information to other countries in certain circumstances, for example because a server or third party service provider is located there.  BY USING THIS WEBSITE, ACCESSING THE SERVICES OR PROVIDING YOUR PERSONAL INFORMATION TO US, YOU ARE CONSENTING TO THE TRANSFER, SHARING, STORAGE, AND PROCESSING OF YOUR PERSONAL INFORMATION IN ACCORDANCE WITH THIS NOTICE.

There are potential risks to you associated with transferring your information to the United States due to the absence of an adequacy decision and appropriate safeguards.  These risks include the risk that you will not be able to exercise your data protection rights under applicable law to protect yourself from unlawful use or disclosure of your information.  The data protection and privacy laws of other countries, including the United States, may not afford you the same level of protection as those in your own country.

IF YOU ARE FROM THE EUROPEAN UNION OR OTHER REGIONS WITH LAWS GOVERNING DATA COLLECTION AND USE AND YOU PROVIDE US WITH YOUR PERSONAL INFORMATION, YOU ARE AGREEING TO THE TRANSFER OF YOUR PERSONAL INFORMATION TO THE UNITED STATES.

If you are a resident of the EU, United Kingdom, Lichtenstein, Norway, or Iceland, you may have additional rights under the E.U. General Data Protection Regulation (the “GDPR”) with respect to your Personal Data processed in connection with use of the Site.  For this section, we use the terms “Personal Data” and “processing” as they are defined in the GDPR, but “Personal Data” generally means information that can be used to individually identify a person, and “processing” generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure.

Where applicable, this section is intended to supplement, and not replace, the rest of this Privacy Policy. If there are any conflicts between this section and any other provision of this Privacy Policy, the policy or portion that is more protective of Personal Data shall control to the extent of such conflict.

If you have any questions about this section or whether any of this section applies to you, please contact us at academy@aefis.com.

Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this privacy notice:

  • To our subsidiaries and affiliates.
  • To contractors, service providers, and other third parties we use to support our business.
  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Website users is among the assets transferred.
  • To fulfill the purpose for which you provide it.
  • For any other purpose disclosed by us when you provide the information.
  • With your consent.

We may also disclose your personal information:

  • To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
  • To enforce or apply this Privacy Notice and our Terms of Service.
  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of  the Company or its affiliates, our customers, or others.

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

  • Tracking Technologies. You can set your browser to refuse all or some browser cookies or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this Website may then be inaccessible or not function properly.
  • Email Communication. At any time, you can choose to no longer receive select types of emails by using the “unsubscribe” method found at the bottom of each email or by changing your preferences in the Email Preferences section of your Account Settings.
  • Contact us/Personal Information. If you have any questions regarding this notice, have a specific request to access, correct, or delete any personal information that you have provided to us, or if you feel that the Website has not followed the posted notice or our Terms of Service, feel free to contact us, as provided below. Note that we may have to delete your user account on the Website, in order to delete your personal information. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

Children and Privacy

The Company does not operate websites or online services directed to children.  We do not knowingly collect personal information from visitors under 18 years of age. Please do not use our website if you are not yet 18.

Compliance and Security

The Company treats the security of your personal information with the utmost importance. We take many precautions at the infrastructure and software layers to deliver the highest level of protection for your personal information and other additional constituent data provided by you. The Company owns and operates the database and web servers that host the Company’s website and, stores your personal information. These servers are protected by securely configured firewalls that are designed to prevent data from being accessed via the Internet.

Measures have been taken to make transactions secure on our Website. Login, and administrative activity are transmitted over an industry standard Secure Socket Layer (“SSL”). All transactions encrypt your personal information in a manner designed to prevent unauthorized access as the information travels over the Internet.

Changes to Our Privacy Notice

It is our policy to post any changes we make to our privacy notice on this page. If we make material changes to how we treat our users’ personal information, we will notify you. The date the privacy notice was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this privacy notice to check for any changes.

Opt-Out

At any time, you can choose to no longer receive select types of emails by using the “unsubscribe” method found at the bottom of each email or by changing your preferences in the Email Preferences section of your Account Settings.

Even if you opt-out of receiving certain communications, you may continue to receive emails and notifications relating to event registration confirmations, membership information, and/or other community-related communications.

Additional Privacy Rights for California Residents

California residents may have additional rights under the California Consumer Privacy Act of 2018 (“CCPA”), subject to certain limitations. The obligations and rights in this section do not apply to personal information we collect about job applicants, vendors, suppliers, independent contractors, current or former full-time, part-time, and temporary employees and staff, officers, directors, or owners of the Company or residents of any state other than California. No user of the Website will be discriminated against for exercising their rights under the CCPA.

As described in this notice, we collect the following categories of personal information from users of the Website to provide our Services and related support, analyze, personalize, and improve our Services, engage in marketing and promotional activities, execute our internal operations, secure and protect our business, and comply with legal obligations:

  • Name, contact information and other identifiers, including but not limited to email, home and business addresses, phone number, login credentials, personal and online identifiers, and IP address;
  • Age or date of birth;
  • Internet or other electronic network activity information, including but not limited to browsing history, search history, and information regarding a user’s interaction with the Website;
  • Geolocation data, including but not limited to city, state, and zip code; and
  • User preferences regarding the Website and our Services.

Subject to certain exemptions, if you are a California resident, the CCPA grants you the following rights:

Request to Know. California residents have a right to request a copy of particular information we have collected about you, up to two (2) times in a 12-month period, subject to certain exemptions. We will deliver this information, free of charge, by mail or electronically in a portable and, to the extent technically feasible, readily usable format that allows the requester to transmit this information to another entity without hindrance, which may include:

  • categories of personal information collected;
  • types of sources from which the personal information is collected;
  • business and/or commercial purposes for collecting and selling a user’s personal information; and the
  • categories of third-parties with whom we have shared personal information.

Request to Delete. California residents have a right to request that we delete any personal information about them that we have collected through the Website or Services, subject to certain exceptions. If you are a California resident who makes such a request, once we receive and confirm your verifiable request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

1.  Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.

2.  Detect, prevent, or mitigate security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

3.  Use the information as necessary to identify and repair errors that impair existing intended functionality.

4.  Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

5.  Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).

6.  Enable solely internal uses that are reasonably aligned with our normal operations and consumer expectations based on your relationship with us.

7.  Comply with a legal or regulatory obligation.

8.  Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Only you, or someone legally authorized to act on your behalf, may make one of the above requests related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

In order for us to act on one of these requests, we must be able to verify your identity or authority to make the request and confirm the personal information relates to you, and your request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request and will not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Right to Opt-out of Sale of Personal Information. The CCPA gives California residents 16 years of age or older the right to opt-out of the sale of their personal information at any time. We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is at least 13 but not yet 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time.

If you are a California resident and would like to make any request as described herein, please contact us as provided in this notice. We will respond to verifiable requests received from California residents as required by law.

Contact Information

To ask questions or comment about this privacy notice and our privacy practices, contact us at:

AEFIS, INC
1429 Walnut Street, 10th Floor
Philadelphia, PA 19102
academy@aefis.com

© Copyright 2020 – AEFIS, INC.  All rights reserved. All other trademarks appearing on the Website are the property of their respective owners.

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