- ECoursemate, Ltd. is the data controller of the personal information we collect about you (i.e., the entity that determines the means and purposes of collecting, using, and disclosing the personal information), unless you are part of a degree, certain MasterTrack programs, or certain other circumstances as communicated to you, in which case ECoursemate is the data processor.
- We collect the personal information set out in the “What Information We Collect” section of this Privacy Notice below, including account registration details such as name and email, details of Content Offerings you undertake, survey information (where you provide it), identity verification data, and information about your use of our site and Services.
- We use your personal information for the purposes set out in the “How We Use the Information” section of this Privacy Notice below, including providing our site and Services to you, ensuring the security and performance of our site, conducting research relating to Content Offerings, sharing information with our Content Providers and our suppliers, direct marketing, and performing statistical analysis of the use of our site and Services.
- You have a number of rights that you can exercise in relation to our use of your personal information, as set out in the “Updating or Deleting Your Personally Identifiable Information” section of this Privacy Notice below.
You can find information about us and how we collect, use, and store your personal data in each section of this Privacy Notice:
- Purpose and who we are
- What Information this Privacy Notice Covers
- What You Agree to by Using Our Site
- What Information We Collect
- How We Use the Information
- External Links
- Retention of Personally Identifiable Information
- Confidentiality & Security of Personally Identifiable Information
- Updating or Deleting Your Personally Identifiable Information
- Questions, Suggestions and Complaints
- International Privacy Practices
- Changing Our Privacy Notice
- No Information from Children Under 13
Purpose and who we are
What Information this Privacy Notice Covers
This Privacy Notice covers information we collect from you through our Site. Some of our Site’s functionality can be used without revealing any Personal Data, but for features or Services related to the Content Offerings, Personal Data is required. In order to access certain features and benefits on our Site, you may need to submit, or we may collect, “Personal Data” (i.e., information that can be used to identify you and which may also be referred to as “personally identifiable information” or “personal information”). Personal Data can include information such as your name, email address, IP address, and device identifier, among other things. You are responsible for ensuring the accuracy of the Personal Data you submit to ECoursemate. Inaccurate information may affect your ability to use the Site, the information you receive when using the Site, and our ability to contact you. For example, your email address should be kept current because that is one of the primary manners in which we communicate with you.
What You Agree to by Using Our Site
We consider that the legal bases for using your personal information as set out in this Privacy Notice are as follows:
- our use of your personal information is necessary for complying with our legal obligations; or
- use of your personal information is necessary for our legitimate interests or the legitimate interests of others. Our legitimate interests are to:
- run, grow and develop our business;
- operate our Site and provide our Services;
- select appropriately skilled and qualified suppliers;
- build relationships with partners and academic institutions;
- carry out research and statistical analysis;
- carry out marketing and business development; and
- for internal administrative and auditing purposes.
- consent, to send you certain communications or where you submit certain information to us, or where required to rely upon consent by local law.
Which legal basis applies to a specific activity will depend on the type of personal information used and the context in which it is being used.
If we rely on our (or another party’s) legitimate interests for using your personal information, we will undertake a balancing test to ensure that our (or the other party’s) legitimate interests are not outweighed by your interests or fundamental rights and freedoms which require protection of the personal information.
We may process your personal information in some cases for marketing purposes on the basis of your consent (which you may withdraw at any time as described below).
If we rely on your consent for us to use your personal information in a particular way, but you later change your mind, you may withdraw your consent by visiting your profile page and clicking the box to remove consent and we will stop doing so. If you withdraw your consent, this may impact the ability for us to provide some of our Services to you.
What Information We Collect
We gather the following types of information about users through the Site:
- Personal Data provided directly by you or via third parties. We collect Personal Data that you provide to us when you register for an account, update or change information for your account, purchase products or Services, complete a survey, sign-up for email updates, participate in our public forums, send us email messages, and/or participate in Content Offerings or other Services on our Site. We may use the Personal Data that you provide to respond to your questions, provide you the specific Content Offering and/or Services you select, send you updates about Content Offerings or other ECoursemate events, and send you email messages about Site maintenance or updates.
- Account Registration. If you register for an account on our Site, you may be required to provide us with certain Personal Data such as your name and email address. You may also voluntarily provide us with additional Personal Data.
- Updates. ECoursemate may offer you the ability to receive updates either via email or by posting on portions of the Site only accessible to registered users. In order to subscribe to these Services, you may be required to provide us with Personal Data such as your name and email address.
- Participation in Content Offerings. ECoursemate offers users the opportunity to participate in Content Offerings on or through the Site. If you desire to participate in a Content Offering, you will be asked to provide us with certain information necessary to conduct such a Content Offering. This information may include, among other things, your name and email address.
If you participate in a Content Offering, we may collect certain user-generated content, such as assignments you submit, peer-graded assignments, and peer grading feedback. We also collect course data, such as responses to in-video quizzes, standalone quizzes, exams, and surveys. You should not include any Personal Data or other information of a personal or sensitive nature, whether relating to you or another person, on assignments, exams, or surveys, except for information required to participate in or submit such assignments, exams, or surveys.
- Identity Verification. ECoursemate may offer you the ability to verify your identity for select Services. In order to enroll for these Services, you may be required to provide us or our third-party identity verification vendor with Personal Data such as your name, address, date of birth, a headshot taken using a webcam, and a photo identification document. Additionally, if you apply for financial aid in connection with these Services, you may be required to provide information regarding your income.
- Communications with ECoursemate. We may receive Personal Data when you send us an email message or otherwise contact us.
- Third Party Sites. We may receive Personal Data when you access or log-in to a third-party site, e.g., Facebook, from our Sites. This may include the text and/or images of your Personal Data available from the third-party site.
- Surveys. We may receive Personal Data when you provide information in response to a survey operated by us or a Content Provider.
- Partner sites. Partner sites providing Content Offering-related tools and services to ECoursemate users may collect nonfinancial individual-level user data regarding the individual’s use of that partner site while the partner sites provide those services to ECoursemate. The partner sites may share that data with ECoursemate for the purpose of improving our Services, the partner site’s services, and the individual’s education experience. This data includes information such as the amount of time spent on the partner site and pages viewed.
- Third Party Payment Processing. ECoursemate provides you with the ability to pay for Content Offerings and other Services using a credit card or other methods through a third-party payment processing service provider. Please note that our service provider – not ECoursemate – collects and processes your financial information.
How We Use the Information
- Information relating to your use of our Site. We use information relating to your use of the Site to build higher quality, more useful Services by performing statistical analyses of the collective characteristics and behavior of our users, and by measuring demographics and interests regarding specific areas of our Site. We may also use this information to ensure the security of our Services and the Site.
- Personally Identifiable Information provided directly by you or via third parties. Except as set forth in this Privacy Notice or as specifically agreed to by you, ECoursemate will not disclose any of your Personal Data. In addition to the other uses set forth in this Privacy Notice, we may disclose and otherwise use Personal Data as described below.
- Providing the Site and our Services. We use Personal Data which you provide to us in order to allow you to access and use the Site and in order to provide any information, products, or Services that you request from us.
- Technical support and security. We may use Personal Data to provide technical support to you, where required, and to ensure the security of our Services and the Site.
- Updates. We use Personal Data collected when you sign-up for our various email or update services to send you the messages in connection with the Site or Content Offerings. We may also archive this information and/or use it for future communications with you, where we are legally entitled to do so.
- Forums. You should not post any personally identifiable information or other information of a personal or sensitive nature, whether relating to you or another person, within a Forum post. If you choose to post personally identifiable information, such personally identifiable information may be collected during your use of the Forums. We may publish this information via extensions of our platform that use third-party services, like mobile applications. We reserve the right to reuse Forum posts that contain personally identifiable information in future versions of the Content Offerings, and to enhance future Content Offerings. We may archive this information and/or use it for future communications with you and/or your designee(s), and/or provide it to the Content Provider, business partners, or the instructor(s) associated with the courses you have taken. We may also use or publish posts submitted on the Forums without using personally identifiable information.
- Participation in Content Offerings. We use the Personal Data that we collect from you when you participate in a Content Offering through the Site for processing purposes, including but not limited to tracking attendance, progress, and completion of the Content Offerings. We may also share your Personal Data and your performance in a given Content Offering with the instructor or instructors who taught it, with teaching assistants or other individuals designated by the instructor or instructors to assist with the creation, modification, or operation of the Content Offering, and with the Content Provider(s) with which they are affiliated. We may also use the information generated when taking a Content Offering or using the Services for predictive analysis of your performance in the Content Offerings. Also, we may archive this information and/or use it for future communications with you, where we are legally entitled to do so.
- Identity Verification. For Services that require identity verification, we may use the Personal Data that we collect for verifying your identity, and for authenticating those submissions made on the Site were made by you. This service may be provided through a third-party identity verification vendor. Your photo identification document will be deleted after successful verification of your profile information.
- Communications with or from ECoursemate. When you send us an email message or otherwise contact us, we may use the information provided by you to respond to your communication and/or as described in this Privacy Notice. We may also archive this information and/or use it for future communications with you where we are legally entitled to do so. Where we send you emails, we may track the way that you interact with these emails (such as when you open an email or click on a link inside an email). We use this information for the purposes of optimizing and better tailoring our communications to you.
- Communications with ECoursemate Business Partners. We may share your Personal Data with Content Providers and other business partners of ECoursemate so that Content Providers and other business partners may share information about their products and services that may be of interest to you where they are legally entitled to do so.
- Research. We may share general course data (including quiz or assignment submissions, grades, and forum discussions), information about your activity on our Site, and demographic data from surveys operated by us with our Content Providers and other business partners so that our Content Providers and other business partners may use the data for research related to online education.
- Disclosure to ECoursemate Operations and Maintenance Contractors. We use various service providers, vendors, and contractors (collectively, “Contractors”) to assist us in providing our Services to you. Our Contractors may have limited access to your Personal Data in the course of providing their products or services to us, so that we in turn can provide our Services to you. These Contractors may include vendors and suppliers that provide us with technology, services, and/or content related to the operation and maintenance of the Site or the Content Offerings. Access to your Personal Data by these Contractors is limited to the information reasonably necessary for the Contractor to perform its limited function for us.
- Disclosure to Acquirers. ECoursemate may disclose and/or transfer your Personal Data to an acquirer, assignee, or other successor entity in connection with a sale, merger, or reorganization of all or substantially all the equity, business, or assets of ECoursemate to which your Personal Data relates.
- e-Readers. If we receive any Personal Data related to the extent to which you use designated e-Readers or other devices to access ECoursemate materials, we may archive it, and use it for research, business, or other purposes.
Retention of Personally Identifiable Information
We keep your Personal Data for no longer than necessary for the purposes for which the Personal Data is collected and processed. The length of time we retain Personal Data for depends on the purposes for which we collect and use it and/or as required to comply with applicable laws and to establish, exercise, or defend our legal rights.
Confidentiality & Security of Personally Identifiable Information
We will use industry standard physical, technical, and administrative security measures to keep your Personal Data confidential and secure, and will not share it with third parties, except as otherwise provided in this Privacy Notice, or unless such disclosure is necessary in exceptional cases, such as a physical threat to you or others, as permitted by applicable law. Because the Internet is not a 100% secure environment, we cannot guarantee the security of Personal Data, and there is some risk that an unauthorized third party may find a way to circumvent our security systems or that transmission of your information over the Internet will be intercepted. It is your responsibility to protect the security of your login information. Please note that e-mail communications are typically not encrypted and should not be considered secure.
Updating or Deleting Your Personal Data
You have certain rights in relation to your Personal Data. You can access your Personal Data and confirm that it remains correct and up-to-date, choose whether or not you wish to receive material from us or some of our partners, and request that we delete or provide you with a copy of your personal data by logging into the Site, selecting ‘Settings’ from the dropdown in the top right, and scrolling down to find the appropriate option. The ability to delete an account may be disabled for some users, particularly those who are enrolled in for-credit offerings such as degrees, MasterTrack certificate programs, and other similar offerings.
If you would like further information in relation to your rights or would like to exercise any of them, you may also contact us via firstname.lastname@example.org. If you reside or are located in the ECOWAS sub-region, or other regions in Africa that offers similar protections, you have the right to request that we:
- provide access to any Personal Data we hold about you;
- prevent the processing of your Personal Data for direct marketing purposes;
- update any Personal Data which is out of date or incorrect;
- delete any Personal Data which we are holding about you;
- restrict the way that we process your Personal Data;
- provide your Personal Data to a third-party provider of services; or
- provide you with a copy of any Personal Data which we hold about you.
We try to answer every request promptly where possible and provide our response within the time period stated by applicable law. Keep in mind, however, that when deleting your Personal Data there may be residual information that will remain within our databases, access logs, and other records, which may or may not contain your Personal Data. Please also note that certain Personal Data may be exempt from such requests in certain circumstances, which may include if we need to retain your Personal Data to comply with a legal obligation. When you email us with a request, we may ask that you provide us with information necessary to confirm your identity.
No Information from Children Under 13
ECoursemate strongly believes in protecting the privacy of children. Any use or access by anyone under the age of 13 is prohibited, and certain regions and Content Offerings may have additional requirements and/or restrictions. In line with this belief, we do not knowingly collect or maintain Personal Data on our Site from persons under 13 years of age, and no part of our Site is directed to persons under 13 years of age. If you are under 13 years of age, then please do not use or access this Site at any time or in any manner. We will take appropriate steps to delete any Personal Data of persons less than 13 years of age that has been collected on our Site without verified parental consent upon learning of the existence of such Personal Data.
Questions, Suggestions, and Complaints
If you have any privacy-related questions, suggestions, unresolved problems, or complaints, you may contact us via privacy@eCoursemate.org. If you reside or are located in the ECOWAS sub-region, or other regions in Africa that offer similar protections, our Data Protection Officer and Privacy Team may assist with all queries regarding our handling of Personal Data at security@eCoursemate.org. If you reside or are located in the ECOWAS sub-region, or other regions in Africa that offer similar protections, you may also make a complaint to our supervisory body for data protection matters (namely the Ghana Data Protection Commissioner’s Office) or seek a remedy through local courts if you believe that your rights have been breached.
Below is a list of all the revisions made to our Privacy Notice, with links to view the difference between each revision.
- 30-05-2022: Initial release