Niazee College of Osteopathic Medicine (NCOM)
Website Use & Privacy Policy
The NCOM Website located at www.ncomchicago.org is a platform for disseminating information and interacting with users like current or prospective students, faculty, staff, partners and other interested persons (“user” or ”you”) in connection with our provision of medical education and clinical training as well as related services and resources like online portals, LMS operations, tuition/fees payments, purchases, financial aid, scholarships, and HR processes. Respecting your privacy, this NCOM Website Use & Policy (the “Policy”) is designed to inform users of this NCOM Website, about i) the types of information that NCOM may gather about or collect from you in connection with your use of the Website, and ii) the conditions under which NCOM uses and discloses that information, and your rights related to that information. This Policy is subject to periodic changes; the current version on the NCOM website will apply each time you access it.
The NCOM Website is hosted in the United States of America and is subject to U.S. state and federal law. Users who access our website from other jurisdictions expressly consent to i) the transfer and use of their personal information in accordance with this Policy; ii) abide by applicable U.S. federal and state laws concerning your use of the Internet and this Website, your personal data collection, and your related agreements with us.
NOTICE: BY USING OR ACCESSING THIS WEBSITE, YOU ACCEPT THE TERMS, PROVISIONS AND PRACTICES DESCRIBED IN THIS POLICY.
A: NON-PERSONALLY-IDENTIFYING INFORMATION
Use of the Website Generally
“Non-Personally-Identifying Information” is information that without the aid of additional information cannot be directly associated with a specific person. “Personally-Identifying Information” by contrast, is information such as a name or email address that, without more, can be directly associated with a specific person. Like most website operations, NCOM gathers from users of the Website Non-Personally Identifying Information of the sort that Web browsers, depending on their setting, may make available. This includes the user’s Internet Protocol (IP) address, operating system, browser type and the locations of the websites the user views right before arriving at, navigating and immediately after leaving the Website. It may be possible to determine from an IP address a user’s internet service provider and the geographic location of the visitor’s point of connectivity as well as other statistical usage data. NCOM analyzes Non-Personally Identifying information gathered from users of the Website to help NCOM better understand how the Website is being used, and to improve the user’s experiences, both in terms of content and ease of use. NCOM may also release the Non-Personally identifying information gathered from Website users in the aggregate, such as publishing a report on trends in usage of the Website.
Web Cookies
We use ‘Web Cookies’ (small data files written to your hard drive that contain information about your visit to a web page) on the Website to track services you have used, to record registration information regarding your login name and password, to record your user preferences, to keep you logged into the Website and to facilitate payment and purchase procedures. NCOM also uses Web Cookies to track the pages that users visit during each Website session, both to help NCOM improve users’ experiences and to help NCOM understand how the Website is being used. As with other Non-Personally Identifying Information gathered from users of the Website, NCOM analyzes and discloses in aggregated form information gathered using Web Cookies, so as to help NCOM, its partners and others better understand how the Website is being used. NCOM USERS WHO DO NOT WISH TO HAVE WEB COOKIES PLACED ON THEIR COMPUTERS SHOULD SET THEIR BROWSERS TO REFUSE WEB COOKIES BEFORE ACCESSING THE WEBSITE, WITH THE UNDERSTANDING THAT CERTAIN FEATURES OF THE WEBSITE MAY NOT FUNCTION PROPERLY WITHOUT THE AID OF WEB COOKIES. WEBSITE USERS WHO REFUSE WEB COOKIES ASSUME ALL RESPONSIBILITY FOR ANY RESULTING LOSS OF FUNCTIONALITY.
Web Beacons
A “Web Beacon” is an object that is embedded in a web page or email that is usually invisible to the user and allows website operators to check whether a user has viewed a particular web page or an email. NCOM may use Web Beacons on the Website and in emails to count users who have visited particular pages, viewed emails and to deliver co-branded services. Web Beacons are not used to access users’ Personally-Identifying Information.
They are a technique NCOM may use to compile aggregated statistics about Website usage. Web Beacons collect only a limited set of information, including a Web Cookie number, time and date of a page or email view and a description of the page or email on which the Web Beacon resides. You may not decline Web Beacons. However, they can be rendered ineffective by declining all Web Cookies or modifying your browser setting to notify you each time a Web Cookie is tendered, permitting you to accept or decline Web Cookies on an individual basis.
Analytics
We may partner with selected third parties to allow tracking technology on the Website, which will enable them to collect data about how you interact with the Website and our services over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity.
Aggregated and Non-Personally-Identifying Information
We may share aggregated and Non-Personally Identifying Information we collect under any of the above circumstances. We may also share it with third parties and our affiliate companies to develop and deliver targeted advertising on the Website and on websites of third parties. We may combine Non-Personally Identifying Information we collect with additional Non-Personally Identifying Information collected from other sources. We also may share aggregated information with third parties, including advisors and promoters, for conducting general business analytics. This information does not contain any Personally-Identifying Information and may be used to develop website content and services that we hope you and other users will find of interest and to target content and promotions.
Mobile Devices, Additional Terms
- Mobile Device. If you use a mobile device to access the Website or download any of our applications, we may collect device information (such as your mobile device ID, model and manufacturer), operating system, version information and IP address.
- Geo-Location Information. Unless we have received your prior consent, we do not access or track any location-based information from your mobile device at any time while downloading or using our mobile application or our services, except that it may be possible for NCOM to determine from an IP address the geographic location of your point of connectivity, in which case we may gather and use such general location data.
- Push Notifications. We send you push notifications if you choose to receive them, letting you know when someone has sent you a message or for other services-related matters. If you wish to opt-out from receiving these types of communications, you may turn them off in your device’s settings.
- Mobile Analytics. We use mobile analytics software to allow us to better understand the functionality of our mobile software on your phone. This software may record information, such as how often you use the application, the events that occur within the application, aggregated usage, and performance data and where the application was downloaded from. We do not link the information we store within the file analytics software to any Personally-Identifying Information you submit within the mobile application.
SOCIAL MEDIA
We may use hyperlinks on the Website which will redirect you to a social network if you click on the respective link. However, when you click on a social plug-in such as Facebook’s “Like” button, Twitter’s “tweet” button or the Google+, that particular social network’s plugin will be activated, and your browser directly connects to that provider’s servers. If you do not use these buttons, none of your data will be sent to the respective social network’s plugin provider. Settings regarding privacy protection can be found on the websites of these social networks and are not within our control.
B: PERSONALLY-IDENTIFYING INFORMATION
Website Registration & Interactions
NCOM may collect a range of Personally-Identifying Information from and about website users. Much of the Personally-Identifying Information collected by NCOM about users is information provided by users themselves when (1) applying to or pursuing or supporting various activities in connection with NCOM’s provision of medical education and clinical training as well as related services and resources like online portals, LMS operations, tuition/fees payments, purchases, financial aid, scholarships and HR processes, (2) logging in with social network credentials, (3) participating in a wide range of educational and training-related actions through NCOM, as well in polls, surveys or other features of our services, (4) communicating with us, (5) creating a public profile or (6) signing up to receive NCOM information, services or newsletters. That information may include each user’s name, address, email address and telephone number, and, if you transact business with us, financial information such as your payment method (valid credit card number, type, expiration date or other financial information). We also may request information about your interests and activities, your gender, age, date of birth, username, hometown, and other demographic or relevant information as determined by NCOM from time to time. Users of the website are under no obligation to provide NCOM with Personally-Identifying Information of any kind, with the caveat that a user’s refusal to do so may prevent the user from using certain website features.
BY REGISTERING WITH OR USING THE WEBSITE, YOU CONSENT TO THE USE AND DISCLOSURE OF YOUR PERSONALLY-IDENTIFYING INFORMATION AS DESCRIBED IN THIS “COLLECTION, USE AND DISCLOSURE OF PERSONALLY-IDENTIFYING INFORMATION” SECTION
NCOM Communications
We may use your name and email address to send you notifications regarding NCOM that we think you may find valuable. Generally, you may opt out of such emails at the time of registration or through your account settings, though we reserve the right to send you notices about your account, such as service announcements and administrative messages, even if you opt out of all voluntary email notifications.
NCOM Disclosures
NCOM may disclose personally-identifying information under the following circumstances.
- By Law or to Protect Rights. When we believe disclosure is appropriate, we may disclose personally-identifying information in connections with efforts to investigate, prevent or take other actions regarding illegal activity, suspected fraud or other wrongdoing, to protect and defend the rights, property or safety of NCOM, our users, our employees or others, to comply with applicable law or cooperate with law enforcement; to enforce our Terms of Use or other agreements or policies, in response to a subpoena or similar investigative demand, a court order, or a request for cooperation from law enforcement or other government agency, to establish or exercise our legal rights; to defend against legal claims, or as otherwise required by law. In such cases, we may raise or waive any legal objection or right available to us.
- Third-Party Service Providers. We may share your personally-identifying information which may include your name and contact information (including email address) with our authorized service providers that perform certain services on our behalf. These services may include fulfilling orders, providing customer service and marketing assistance, performing business and sales analysis, supporting the website’s functionality and supporting services, resources and features offered through the website. We may also share your name, contact information and credit card information with our authorized service providers who process credit card payments. These service providers may have access to personal information needed to perform their functions but are not permitted to share or use such information for any other purpose.
- Payment Information. When making a payment on our Website, you may be taken to the website of our third-party Payment Processor who will either collect or have access to your first and last name, zip code, postal address, email address, payment amount, billing information, and payment card information. When your payment is processed, your personal data and credit card information is scrambled using SSL encryption technology. This makes it virtually impossible for information to be stolen or intercepted while being transferred across the Internet. Your payment orders are encrypted in receipt until being processed. Billing information will be used solely for billing purposes and will not otherwise be disclosed.
Changing Personally-Identifying Information: Account Termination
You may at any time review or change your Personally-Identifying Information by going to your account settings (if applicable) or contacting us using the contact information on our website. Upon your request we will deactivate or delete your account and contact information from our active databases. Such information will be deactivated or deleted as soon as practicable based on your account activity and in accordance with our deactivation policy and applicable law. To make this request, either go to your account settings (if applicable) or contact us as provided below. We will retain in our files some Personally-Identifying Information to prevent fraud, to troubleshoot problems, to assist with any investigations, to enforce our Terms of Use and to comply with legal requirements as is permitted by law. Therefore, you should not expect that all of your Personally-Identifying Information will be completely removed from our databases in response to your requests. Additionally, we keep a history of changed information to investigate suspected fraud with your account.
General Use
NCOM uses the Personally-Identifying Information in the file we maintain about you, and other information we obtain from your current and past activities on the Website to (1) support your applying to or pursuing or supporting various activities in connection with NCOM’s provision of medical education and clinical training as well as related services and resources like online portals, LMS operations, tuition/fees payments, purchases, financial aid, scholarships and HR processes; (2) to manage your account and provide you with customer support; (3) to communicate with you by email, postal mail, telephone and/or mobile devices about current or prospective services that may be of interest to you either from us or our partners or other relevant third parties; (4) to develop and display content tailored to your interests on the Website and other sites; (5) to resolve disputes and troubleshoot problems; (6) to measure interest in our services; (7) to inform you of updates; (8) to customize your experience; (9) to detect and protect us against error, fraud, and other criminal activity; (10) to enforce our Terms of Use; and (11) to do as otherwise described to you at the time of collection. At times, we may look across multiple users to identify problems. In particular, we may examine your Personally-Identifying Information to identify users using multiple user ID’s or aliases. We may compare and review your Personally-Identifying Information for accuracy and to detect errors and omissions. We may use financial information or payment method to process payment for any purchases made on the Website, enroll you in the programs in which you elect to participate, to protect against or identify possible fraudulent transactions and otherwise as needed to manage our NCOM operations.
COLLECTION AND USE OF INFORMATION BY THIRD PARTIES GENERALLY
NCOM contractually prohibits its contractors, affiliates, vendors, and suppliers from disclosing Personally-Identifying Information received from NCOM, other than in accordance with this Policy. However, third parties are under no obligation to comply with this Policy with respect to Personally-Identifying Information that users provide directly to those third parties, or that those third parties collect for themselves. These third parties include advertisers, providers of games, utilities, widgets, and a variety of other third-party applications accessible through the Website. NCOM neither owns nor controls the third-party websites and applications accessible through the Website. Thus, this Policy does not apply to information provided to or gathered by the third parties that operate them. Before visiting a third party, or using a third-party application, whether by means of a link on the Website, directly through the Website, or otherwise, and before providing any Personally-Identifying Information to any such third party, users should inform themselves of the privacy policies and practices (if any) of the third-party responsible for that website or application, and should take those steps necessary to in those users’ discretion, protect their privacy.
C: SECURITY
NCOM takes the security of your Personally-Identifying Information seriously and uses reasonable safeguards consistent with prevailing industry standards and commensurate with the sensitivity of data being stored to maintain the security of that information on our system, and we deploy appropriate electronic, personnel and physical measures to protect it from loss, theft, alteration or misuse. When sensitive personal information (such as a credit card number) is transmitted to other websites, it is protected through the use of encryption, such as the Secure Socket Layer (SSL) protocol. We also aim to comply with applicable federal, state and local laws regarding the privacy and security of information.
Caution: Please be advised that even the best security measures cannot fully eliminate all risks. We cannot guarantee that only authorized persons will view your information. We are not responsible for third-party circumvention of any privacy settings or security measures. You are particularly responsible for maintaining the confidentiality of your Personally-Identifying Information by keeping your password confidential. You should change your password immediately if you believe someone has gained unauthorized access to it or your account. If you lose control of your account, you should notify us immediately.
D: LEGAL & REGULATORY PROVISIONS
In addition to operational requirements of the college, NCOM’s disclosure of many types of student, staff and employee information may be guided or dictated by various legal and regulatory provisions including those covered by the Family Educational Rights and Privacy Act (FERPA), the Gramm-Leach-Bliley Act (GLBA), the Health Insurance Portability and Accountability Act (HIPAA), and the California’s Online Privacy Protection Act of 2003 (CalOPPA).
NCOM is committed to safeguarding and disclosing information obtained through your use of its website and other systems for official purposes in accordance with governing law, including protecting students’ education records under FERPA regulations covering the maintenance and release of information from those records.
E: CHILDREN’S DATA
The Children’s Online Privacy Protection Act (“COPPA”) protects the online privacy of children under 13 years of age. We do not knowingly collect or maintain Personally-Identifying Information from anyone under the age of 13 unless or except as required or permitted by law. Any person who provides Personally-Identifying Information through the Website represents to us that he or she is 13 years of age or older. If we learn that Personally-Identifying Information has been collected from a user under 13 years of age on or through the Website then we will take the appropriate steps to cause this information to be deleted.
F: CALIFORNIA PRIVACY RIGHTS
California Civil Code Section 1798.83 also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year, and free of charge, information about the Personally-Identifying Information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of the Personally-Identifying Information that was shared and the names and addresses of all third parties with which we shared Personally-Identifying Information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to our privacy officer as listed below.
G: DO-NOT-TRACK POLICY
Most web browsers and some mobile operating systems include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. Because there is not yet a common understanding of how to interpret the DNT signal, the Website currently does not respond to DNT browser signals or mechanisms.
H: POLICY CHANGES
NCOM may, in its sole discretion, change this Policy from time to time. Any changes to NCOM’s Policy will be reflected on this page and the date new versions are posted will be stated at the top of this Policy. Unless stated otherwise, our current Policy applies to all information that we have about you and your account. Users should regularly check this page for any changes to the Policy. NCOM will always post new versions of the Policy on the Website. However, NCOM may, as determined in its discretion, decide to notify users of changes made to this Policy via email or otherwise. Accordingly, it is important that users always maintain and update their contact information.
QUESTIONS?
If you have any questions regarding this NCOM Policy, please contact us at:
Email: info@ncomchicago.org – Attn: NCOM Website Policy question