AVENU LEARNING LLC - PRIVACY NOTICE
AVENU Learning (“AVENU”, “we”, “us”, “our”) is a provider of services to higher education institutions. Our services include, for example, marketing programs, program localization and translation, student acquisition, enrollment, and retention, and faculty management.
When you contact, apply to, or enroll at a higher education institution that is an AVENU customer, we will be provided with your personal data. This Privacy Notice describes our role in the collection, use, sharing, security, and eventual disposal (collectively “processing”) of your data.
Except where specifically stated otherwise in this Privacy Notice, AVENU acts as a data “processor” or “service provider”. In this capacity, we handle your data according to the instructions of our customer, the higher education institution. In limited circumstances, clearly identified in this Notice, we may act as a data “controller”.
To gain full insight into how your data is processed, you should also consult the privacy notice of the relevant higher education institution.
(1) Personal Information Collected
Our customer universities and colleges will share with us, or authorize us to collect on their behalf, personal data that you provide when you request information or apply for admittance, as well as data generated through your later enrollment in their academic programs. This data may include your:
- Name, address, telephone number, and e-mail
- Date of birth, gender, nationality, and official ID type, number, and image
- Work situation, educational history and present learning record
- Web browsing activity obtained through standard technologies like cookies
(2) Purposes of Personal Information Collection
(i) AVENU uses your personal data to provide our contracted services to higher education institutions. In so doing, we use your personal data to:
· Market academic programs to you via channels such as e-mail, telephone, and social media (see Section 7, Your Privacy Rights for information about exercising your marketing preferences)
Support you during your application and enrollment, for example by:
- Responding to your questions and requests
- Providing you with course, admissions, and tuition information
- Assisting you with course planning decisions
- Providing access to your online account
- Accomplish standard business activities like web analytics, services improvement, and fraud prevention.
(ii) AVENU may additionally process your data (acting as data controller) to:
1. Contact you about academic programs at other universities and colleges that may be of interest to you if you did not enroll at the institution you applied to. We will use your name and contact information to provide this service.
2. Create insights and metrics that may be of value to higher education institutions, for example regarding student attributes or profiles that indicate successful academic outcomes. Your data will be just one of multiple inputs and these insights will not identify you personally.
(3) Recipients of the Personal Information
We may disclose your personal data to various individuals and organizations, including:
1. Our employees and contractors whose roles require access to your data.
2. Our “sub-processors”, for example our customer relationship management (CRM) software provider and our payments processing provider. Such vendors are contractually bound to protect your data to the same standard as AVENU.
3. The higher education institutions which you have contacted, applied to, or been enrolled in. These institutions—our customers—are the “controllers” of your personal data and may disclose your data to other organizations and individuals.
4. Your data may be transferred to a third party as a result of any merger, acquisition, or similar corporate event involving AVENU.
5. We will disclose your personal data when required to by law.
(4) Information Security
Your data may be stored on systems managed by either AVENU or by our customers, the higher education institutions. AVENU employs technical and organizational security measures appropriate to the types of personal data we process about you to protect it from unauthorized access, use, or loss. These measures include, for example, firewalls, encryption-in-transit, current security patches, virus protection measures, and access controls. We cannot, however, guarantee that unauthorized access, use, or loss will never occur.
You should additionally consult the privacy notice of the relevant higher education institution for details of its information security measures.
(5) Information Retention
For data for which the higher education institution is the data controller, the period for which your data will be retained will be set by the policies of each institution.
For data for which AVENU is the data controller (see Section 2 ii), we will retain your data for the purpose of contacting you about academic programs at other universities until you tell us that you no longer wish to receive our communications or until the data is no longer required by us for the purposes of satisfying legal or administrative obligations.
(6) International Transfer
In providing our services to our customers, AVENU receives and stores your data in the United States and potentially other countries with different privacy laws than your own. As described in this Notice, we strive to protect your data and your rights regardless of these international transfers.
(7) Your Privacy Rights
You may at any time request access to the data that we hold about you, and ask for its correction, erasure, or that we cease to process it. When necessary, AVENU will work with the appropriate higher education institution (the data controller) to fulfil your requests.
If you believe that AVENU has infringed your privacy rights, please contact us so that we can resolve the issue as quickly as possible.
Marketing: We will contact you with marketing information that we believe will interest you. We will obtain your prior consent when your local law requires it. Further, you can opt out of AVENU marketing communications at any time by using the “unsubscribe” mechanism contained in the message or simply by informing us of your wish.
(8) Contact Us
For privacy requests and queries, contact us at: firstname.lastname@example.org
AVENU Learning, LLC
111 NE 1st Street , 8th Floor, #357
Miami, FL 33132 USA