Privacy Policy

Effective Date: January 13th, 2016

Last Updated: December 30, 2019

Guild Education, Inc. (“Guild,” “we” or “us”) has prepared this privacy policy (“Privacy Policy”) to describe to you, or if you represent an entity or other organization, that entity or organization (in either case, “you,” or “your”) how Guild collects, uses, discloses and protects the Personal Information that we may collect from you and other end users (“Users”) when using or accessing our Services, or that we may obtain from third parties or through the means described below.

This Privacy Policy is incorporated by reference into the Guild TERMS OF USE (the “Terms”). Please read this Privacy Policy and our Terms carefully. Capitalized terms not defined in this Privacy Policy, shall have the meanings defined in the Terms.

  1. How We Collect Personal Information

We obtain the categories of Personal Information listed below through our Services from the following categories of sources:

  • Personal Information You Provide. Guild collects Personal Information when you voluntarily submit it to us. For example, we may collect or receive Personal Information from Users when a User: creates an Account; edits Registration Information; signs up to receive our newsletters or other marketing materials or contacts; applies to one of our Programs or our partnering educational institutions’ Programs; uses or accesses the Services; posts a review; submits a request to our customer service team; interacts with our social media pages; or otherwise interacts with us or other Users through the Services, at an event, over the phone, through email, or through other communication channels. 
  • Automatically Collected Personal Information. In addition to Personal Information that we may receive directly from you, Guild indirectly collects other information from you automatically through the Services. For example, we receive Personal Information from Users when a User visits and navigates a Website on any device. We may also collect Personal Information about Users over time and across different websites, apps, and devices when a User accesses a Website. Third parties also collect Personal Information this way on a Website. Guild collects some Personal Information automatically using cookies or other online tracking technologies as described in our Cookies Policy, available at https://www.guildeducation.com/cookie-policy/.
  • Personal Information Obtained from Third Parties. In addition to the Personal Information that we collect from you directly and automatically, Guild may receive Personal Information about you from other third party sources. For example, we receive Personal Information from your employer, our partnering educational institutions, social media sites, and other companies that provide Personal Information to supplement what we already know about Users. We may merge or combine such Personal Information with the Personal Information we collect from you directly or automatically. 

2. The Personal Information We Collect

Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked to, directly or indirectly, a particular consumer or household. The following are categories (with non-exhaustive examples) of Personal Information we may collect about you:

CategoriesExamples Processing Purpose
A. Individual Identifiers and Demographic InformationName, alias, postal address, telephone number, unique personal identifier, online identifier, Internet Protocol address, email address, age or date of birth, gender, username and password.– Benefits Eligibility
– Marketing Campaigns
– Application and Enrollment Assistance
– Coaching / Student Success Support
– Payment Processes: tuition assistance / reimbursement, reimbursement for educational materials, invoicing
– Services Improvements
B. Sensitive Personal InformationFinancial aid and reimbursement information, information about dependents, Social Security number, nationality, race/ethnicity.– Benefits Eligibility
– Application and Enrollment Assistance
– Coaching / Student Success Support
– Payment Processes: tuition assistance / reimbursement, reimbursement for educational materials, invoicing 
C. Sensory DataAudio, electronic, visual, or similar information.– Coaching / Student Success Support
– Coaching Quality Control 
D. Commercial InformationServices obtained or considered, interests, program application information, enrollment status and related information, course performance data, or other purchasing or consuming histories or tendencies.– Benefits Eligibility
– Marketing Campaigns
– Application and Enrollment Assistance
– Coaching / Student Success Support
– Payment Processes: tuition assistance / reimbursement, reimbursement for educational materials, invoicing
E. Internet or Network ActivityBrowsing history, search history, information on an individual’s interaction with a website, application, or advertisement.– Marketing Automation: website use (user segmentation)
– Services Improvements
F. Professional or Employment-Related Information Received from Your EmployerEmployer Name, job title, full- or part-time status, employer-based training attainment, employee name, email, identifier, location, and date of birth.– Benefits Eligibility
– Marketing Campaigns
– Application Assistance and Enrollment Assistance- Providing Credit for Employer-based Training
– Coaching / Student Success Support
– Payment Processes: tuition assistance / reimbursement, reimbursement for educational materials, invoicing 
G. Education Information Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as academic history such as courses taken and/or completed, degrees earned, areas of study, and family college history, grades, transcripts, class lists, student schedules, student identification codes, student financial information, student disciplinary records.– Benefits Eligibility
– Application and Enrollment Assistance
– Payment Processes: Tuition assistance / reimbursement, reimbursement for educational materials, invoicing
H. Inferences Drawn from Personal InformationProfile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, or aptitudes.– Services Improvements (persona creation)
– Satisfaction and Motivation Evaluation and Analysis

Personal information does not include:

  • Publicly Available Information – Publicly available information from government records. 
  • Deidentified Information or Aggregate Information – “Deidentified Information” means information that cannot reasonably identify, relate to, describe, be capable of being associated with, or be linked, directly or indirectly, to a particular individual, and for which Guild has implemented technical safeguards and business processes that prohibit reidentification of the individual. “Aggregate Information” means information that relates to a group or category of individuals, from which individual identities have been removed, that is not linked or reasonably linkable to any individual or household, including via a device. 
  • Excluded Information – Certain laws require separate privacy notices or are exempt from general personal information privacy policy disclosure requirements. Such laws include the Fair Credit Reporting Act (FCRA).

We reserve the right to use the above described categories of information covered by this Privacy Policy for any purpose, including, but not limited to, improving our Services, analyzing the use of our Services, tracking outcomes, Program application and enrollment trends, and tracking macro student success and performance. We may also disclose such categories of information covered by this Privacy Policy to our partnering educational institutions, employers, or third-party service providers.

3. How We Use the Information We Collect

We may use the Personal Information we collect from you or about you in the following ways:

  • Provide the Services. We use Personal Information to provide our Services or Content to you, enhance our Users’ experience, and notify you about changes to our Services or Content.
  • Benefits Eligibility. We use Personal Information to verify your identity and/or determine your eligibility for Account creation and registration. We may also track your participation in Programs in order to fulfill our responsibilities to your employer.
  • Application and Enrollment Assistance. We use Personal Information to facilitate your application to and enrollment process with our partnering educational institutions and to assist you in applying for financial assistance related to the Programs.
  • Providing Credit for Employer-based Training. We use Personal Information to facilitate your receipt of academic credit through our partnering educational institutions for employer-based training that you have previously completed.
  • Coaching / Student Success Support. We use Personal Information to provide you with academic- and employment-related coaching services and/or to communicate with you about any Programs in which you are enrolled or were previously enrolled. We track your participation Programs in connection with these coaching services.
  • Coaching Quality Control. We use Personal Information to improve and maintain the quality of our coaching services.
  • Satisfaction and Motivation Evaluation and Analysis. We use Personal Information to evaluate and analyze User satisfaction and motivation.
  • Services Improvements. We use Personal Information to understand and analyze the usage trends and preferences of our Users to make our Services better, diagnose technical issues, prevent fraud, and develop new features and functionality for our Services. We use Personal Information that we receive from third parties in order to enhance our ability to serve you and to tailor our Services to you. 
  • Payment Processes. We use Personal Information to facilitate tuition payment or reimbursement for Programs or educational materials.
  • Secure our Services. We use Personal Information to monitor our Services for security purposes.
  • Marketing Campaigns. We use Personal Information to respond to your communications and to send you information online, at in-person events, or by distributing materials on your job site, including marketing communications, updates relating to existing Programs, company news, or other related information that may be of interest to you.
  • Marketing Automation. We use Personal Information to send you advertisements or other marketing materials via postal mail, email, telephone, text message, or other social media outlets about Programs or Services that we think may be of interest to you if you have requested or agreed to receive such information, or where we are otherwise permitted by law to contact you for these purposes.
  • Consent. We use Personal Information for any other purpose described when you provide your Personal Information with your consent.

4. How We Secure Your Information

We maintain reasonable and appropriate administrative, technical, and physical safeguards designed to secure your Personal Information against unauthorized access or acquisition. For additional information on the security of your payment card information, please review the website privacy policy for the website through which you are submitting your payment. Please keep in mind that no electronic data transmission or storage of information can be guaranteed to be completely secure or error free, and we cannot warrant or ensure the security of any information that you transmit to us.

5. How We Share Your Information

In addition to the specific situations discussed elsewhere in this Privacy Policy, Guild may share your Personal Information in the following circumstances: 

  • Service Providers. We may from time to time engage service providers to perform functions on our behalf such as supporting our Services, conducting our business, processing payment transactions, managing our marketing communications, recruitment and/or admissions process, tracking student enrollment and student performance, or otherwise providing the Services to you. We may share your Personal Information with such service providers, so long as those parties agree to keep your Personal Information confidential.
  • Behavioral-Based Advertising. We participate in behavioral-based advertising. This means that a third party may use technology (e.g., a cookie) to collect information about your use of our Website so that we can provide advertising about goods and services tailored to your interest. For example, we use third party providers to serve ads or collect data on our behalf across the Internet and sometimes on this Website. Some of these third-party providers may collect Personal Information about your visits to our Website, and your interaction with devices and Services to tailor marketing messages on this Website and other sites or to trigger real-time interaction, customize this Website or enhance your profile. Some of these third-party providers may be able to collect Personal Information that you share with this Website via a web form automatically and prior to your pressing a submit button; and they may be able to use Personal Information from your visits to this Website to send marketing messages to you in a way that may personally identify you. This information is collected using a cookie, a javascript tag, or pixel, or cross-device identification methods. The Personal Information collected by these third-party providers may include your device’s IP address, user agent, email addresses (where hashed or otherwise rendered pseudonymous) and other user and device-level pseudonymous information. Please keep in mind that your browser settings may not permit you to control the technologies utilized by these third-party companies.
  • Partnering Educational Institutions and Your Employer. When you apply to a Program offered by one of our partnering educational institutions, we may transfer your Personal Information to such partnering institution in connection with providing Programs and Services to you, including to facilitate the application, admissions and enrollment process, apply for academic credit for you, track your participation in Programs, or fulfill our contracted responsibilities to your employer and partnering educational institutions. We may also transfer Personal Information to your employer in connection with providing Programs and Services to you, including to assess benefits eligibility, facilitate the enrollment process, to provide information on your academic achievements and progress, and enable you to receive tuition assistance and reimbursement.
  • Related Companies and M&A Transactions. We may share your Personal Information with companies that are affiliated with us (that is, that control, are controlled by, or are under common control with us). We reserve the right to disclose and transfer your Personal Information in connection with the sale of all or a part of our business, a corporate merger or other restructuring. 
  • Legal Compliance. We may also disclose your Personal Information, usage information and device identifier (such as IP address) to third parties to comply with a legal obligation, to respond to a valid government or law enforcement request such as a warrant or subpoena, to enforce our Services-related agreements or other applicable policies, to respond to an emergency, or to protect the rights, property, safety or security of third parties, Users of our Services or the public.
  • Social Networking. The Services may offer you the ability to share your Personal Information through a social networking site (e.g., Facebook, Twitter), using such site’s integrated tools (e.g., Facebook “Like” button, or Twitter “Tweet” button). The use of such integrated tools enables you to share Personal Information about yourself with other individuals or the public, depending on the settings that you have established with such social networking site. For more information about the purpose and scope of data collection and use in connection with such social networking site or a site’s integrated tools, please visit the privacy policies of the entities that provide these social networking sites.
  • Public Forum and Messaging. The Services may provide you with the opportunity to post comments, messages, or reviews in a public forum. If you decide to submit Personal Information at these locations, that information will be available to other Users of the Services.
  • Referrals. Users may recommend other Users by providing their contact information or selecting friends from a social networking site.
  • Consent. We may ask if you would like us to share your Personal Information with other unaffiliated third parties who are not described elsewhere in this Privacy Policy, and we may do so with your consent.

6. Rights Under The Family Education Rights and Privacy Act (“FERPA”)

Under certain circumstances, if you enroll in a Program offered by one of our partnering educational institutions, the disclosure of certain Personal Information that you provide to us, and/or information that we may create or receive from our partnering educational institutions that pertains to you, may be protected under FERPA, if applicable. You may also have specific rights related to accessing and/or updating your Personal Information when FERPA applies. For more information related to the applicability of FERPA and your rights under it, please contact us at [email protected]

7. Children Under the Age of 13

Our Services are not intended for or targeted toward children under 13 years of age. We do not knowingly collect Personal Information from children under 13. If you believe we may have inadvertently collected any Personal Information from or about a child under 13, please contact us at [email protected]

8. Your Choices

You can make the following choices regarding your Personal Information:

  1. Changes to Your Personal Information. We rely on you to update and correct the Personal Information contained in your Account. Note that we may keep historical information in our backup files as permitted by law. If the Services do not permit you to update or correct certain Personal Information, please contact us as described below.
  2. Access to Your Personal Information. You may request access to your Personal Information by contacting us as described below. We will grant you reasonable access to the Personal Information that we have about you as required by law. 
  3. Deletion of Your Personal Information. Typically, we retain your Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. You may, however, request that we delete your Personal Information by contacting us as described below. We will grant a request to delete Personal Information as required by law, but you should note that in many situations we must keep Personal Information to comply with our legal obligations, resolve disputes, enforce our agreements, or for another one of our business purposes. Except as provided above, we will delete, aggregate, or de-identify all of your Personal Information as described in this subsection within the timeframes required by law.
  4. How to Opt-Out of Future Marketing Communications. If at any time you would like to unsubscribe from receiving future emails or text messages, you may opt-out of future marketing emails and text messages by following the unsubscribe instructions provided to you. If you would like to stop receiving phone calls, you may ask the representative calling you to stop at any time. If you would like to stop seeing our content on a social media site, you may follow the relevant instructions and policies provided for that site to opt-out of receiving our content. Please note that if you are enrolled in one of our Programs or have an Account, we reserve the right to send you certain communications relating to your enrollment, your Account or your use of the Services, and these transactional messages may be unaffected if you choose to opt-out of marketing communications.
  5. Behavioral-Based Advertising. We participate in behavioral-based advertising. If you wish to limit third parties’ collection of information about your use of our Website, you can opt-out of such at the Digital Advertising Alliance or Network Advertising Initiative. PLEASE NOTE THAT OPTING-OUT OF BEHAVIORAL ADVERTISING DOES NOT MEAN THAT YOU WILL NOT RECEIVE ADVERTISING WHILE USING WEBSITE. IT WILL, HOWEVER, EXCLUDE YOU FROM INTEREST-BASED ADVERTISING CONDUCTED THROUGH PARTICIPATING NETWORKS, AS PROVIDED BY THEIR POLICIES AND CHOICE MECHANISMS.
  6. Do-Not-Track. Some web browsers and devices permit you to broadcast a preference that you not be “tracked” online. At this time, we do not modify your experience based upon whether such a signal is broadcast.

9. Exercising Your Privacy Rights

When exercising the rights or options described in this Privacy Policy, the following guidelines apply:

  1. No Fee Usually Required. You will not have to pay a fee to access your Personal Information (or to exercise any of the other rights). However, we may charge a reasonable fee or decline to comply with your request if your request is clearly unfounded, repetitive, or excessive.
  2. What We May Need from You. When exercising your rights or otherwise assisting you, we may need to request specific information from you to help us confirm your identity. This is a security measure to ensure we do not disclose Personal Information to any person who is not entitled to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
  3. Time to Respond. We try to respond to all legitimate requests within 45 days of your request. Occasionally it may take us longer than 45 days to respond, for instance if your request is particularly complex or you have made a number of requests. In this case, we will notify you of the delay, and may continue to update you regarding the progress of our response.
  4. No Discrimination. You will not be subject to discrimination as a result of exercising the rights described herein. In some cases, when you exercise one of your rights, we will be unable to comply with the request due to legal obligations or otherwise, or we will be unable to provide you with certain products or services. These responses are not discrimination and our reasons for declining your request or ceasing services will be provided at that time.
  5. Authorized Agent. You may designate an authorized agent to make a request on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide a valid power of attorney, the requester’s valid government issued identification, and the authorized agent’s valid government issued identification.

10. Notice to California Residents

Guild must disclose whether the following categories of Personal Information are disclosed for a “business purpose” or “valuable consideration” as those terms are defined under California law. Note that while a category below may be marked, that does not necessarily mean that we have Personal Information in that category about you. In the preceding twelve months, we have disclosed the following categories of Personal Information in the manner described. 

CategoryInformation is Disclosed for a Business PurposeInformation is Disclosed for Valuable Consideration
A. Individual Identifiers and Demographic InformationYesNo
B. Sensitive Personal Information
YesNo
C. Sensory Data
YesNo
D. Commercial Information
YesNo
E. Internet of Network Activity
YesYes
F. Professional or Employment-Related Information Received from Your EmployerYesNo
G. Education Information
YesNo
H. Inferences Drawn from Personal InformationNoNo

If you are a consumer as defined in the California Consumer Privacy Act (CCPA), i.e., a resident of California as defined in Section 17014 of Title 18 of the California Code of Regulations, you have certain rights in relation to your Personal Information under the CCPA. Under the CCPA, you have the following additional rights:

  • Right to Opt Out of Disclosure of Personal Information for Valuable Consideration. If you are 16 years of age or older, you have the right to direct us to not sell your 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 from either the consumer who is between 13 and 16 years of age. Consumers who opt-in to Personal Information sales may opt-out of future sales at any time. To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by visiting the following link: [https://privacyportal-cdn.onetrust.com/dsarwebform/7e36dde6-901f-4b96-8230-aea679ca6987/d94da412-ccc1-4a1f-a7e4-2091549a19b8.html]. Once you make an opt-out request, we will wait at least twelve months before asking you to reauthorize Personal Information sales. However, you may change your mind and opt back into Personal Information sales at any time by visiting the following Internet webpage link: [hyperlink]. You do not need to create an Account with us to exercise your opt-out rights. We will only use Personal Information provided in an opt-out request to review and comply with the request.
  • Notice of Disclosure for Direct Marketing. Under California Civil Code sections 1798.83-1798.84, California residents who have an established business relationship with Guild are entitled to ask us for a notice describing what categories of Personal Information we share with third parties for their direct marketing purposes. This notice will identify the categories of information shared with and will include a list of the third parties with which it is shared, along with their names and addresses. If you are a California resident and would like a copy of this notice, please submit a written request to us at [email protected]

11. Changes to Our Privacy Policy

We reserve the right to update this Privacy Policy at any time, without prior notice to you, and any changes will become effective immediately upon posting. The date this Privacy Policy was last revised is identified at the top of the page. If we make material changes to this Privacy Policy, we will notify you by e-mail to the primary e-mail address specified in your Account or through a notice on the Website home page. You are responsible for ensuring we have an up-to-date, active and deliverable e-mail address for you or for periodically visiting our Website and this Privacy Policy to check for any changes. Your continued use of our Services following posting of changes constitutes your acceptance of such changes.

12. Links to Other Websites

While using our Website you may be directed to other websites or services that are operated by third parties. We have no control over these third parties and we are not responsible for the privacy practices of such third parties. This Privacy Policy does not apply to information collected by any other website or third party, or to any information collected by third parties through any application or content (including advertising) that may link to or be accessible from our Website. You should carefully review the privacy policy for any third party sites that you visit.

13. International Users

Guild’s Websites are operated in the United States. If you are located in a jurisdiction outside of the United States, please be aware that the Personal Information we collect about you will be transferred to the United States. By using our Website, or providing us with any Personal Information, you consent to the transfer, processing and storage of your Personal Information in the United States, a jurisdiction in which the privacy laws may not be as comprehensive as those in the country where you reside.

14. Contact Us

If there are any questions regarding this Privacy Policy or you would like to access or update your Personal Information, you may contact us at [email protected].

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