PRIVACY POLICY

NOTICE: On October 10, 2021, ICBC E-LEARNING adopted a Privacy Policy, providing as follows:

ICBC E-LEARNING and each Partner that provides courses through the ICBC E-LEARNING site care about the confidentiality and security of your information. This Privacy Policy applies to information that ICBC E-LEARNING collects through the ICBC E-LEARNING site when you interact with ICBC E-LEARNING, with Partners, with other users, and generally with the ICBC E-LEARNING Site.

Your information is received and controlled by ICBC E-LEARNING according to this Privacy Policy when you sign up for an ICBC E-LEARNING account or otherwise use the ICBC E-LEARNING site.

• ICBC E-LEARNING is solely and independently responsible for its own privacy practices. No Partner is responsible for ICBC E-LEARNING’s privacy practices.

If you enroll in a course offered by a Partner through the ICBC E-LEARNING site, information about you and your activity in the course is received and controlled also by that Partner as described in this Privacy Policy.

• Each Partner is solely and independently responsible for its own privacy practices. No Partner is responsible for another Partner’s privacy practices. Also, ICBC E-LEARNING is not responsible for any Partner’s privacy practices.

If you do not accept the terms of this Privacy Policy, then please do not accesses, browse, or register for the ICBC E-LEARNING Site or enroll in any courses. If you choose not to provide certain information required to provide you with various products and services offered on the ICBC E-LEARNING Site, then you may not be able to establish a user account or obtain those products or services.

Any version of this Privacy Policy in a language other than English is provided for convenience and you understand and agree that the English language version will control if there is any conflict.

This Privacy Policy is organized as follows:

• Information that ICBC E-LEARNING collects from you (including Personal Information)
• Cookies and Tracking Technologies on the ICBC E-LEARNING Site
• How your information is used
• How your information is shared
• How to manage your Personal Information
• Storage & Security
• Privacy Policy updates
• Contact information
• Glossary

INFORMATION THAT ICBC E-LEARNING COLLECTS FROM YOU (INCLUDING PERSONAL INFORMATION)

ICBC E-LEARNING directly collects information when you:

• sign up for an ICBC E-LEARNING user account and create an ICBC E-LEARNING user profile;
• enroll and participate in online courses;
• purchase a product or service (for example, Verified Certificates);
• send email messages to ICBC E-LEARNING (including messages to learner support);
• participate in user surveys; and
• participate in public forums, webinars, and other interactive experiences on the ICBC E-LEARNING Site.

ICBC E-LEARNING also indirectly collects usage information about your visit to the ICBC E-LEARNING Site, as explained in the section below titled Cookies and Tracking Technologies.

ICBC E-LEARNING does not itself collect or store financial account numbers or identification issued by a governmental entity, employer, or other authority. Instead, if you choose to make a purchase on the ICBC E-LEARNING Site, for example a Verified Certificate, you will be directed to ICBC E-LEARNING’s third-party payment processor and ICBC E-LEARNING’s third-party ID verification service provider. If you do not wish to submit the required authentication or payment information, then you will not be able to obtain a certificate via the ICBC E-LEARNING Site.

ICBC E-LEARNING requires your Personal Information limited circumstances when you:

• sign up for an ICBC E-LEARNING user account (name, username, email address);
• purchase a Verified Certificate (so that ICBC E-LEARNING’s third-party vendor can authenticate your identity) or other product or service (so that ICBC E-LEARNING’s third-party vendor can process payment);
• participate in remote proctoring or other course facilitation processes (so that ICBC E-LEARNING’s third-party vendor can monitor and assess the integrity of your course activity); or
• earn a Verified Certificate (the certificate will have your name on it).

To the extent that ICBC E-LEARNING associates the information that ICBC E-LEARNING collects directly or indirectly with an individual (for example, you), the association is based on Personal Information in your account profile.

You may voluntarily choose to share additional Personal Information on the ICBC E-LEARNING Site, for example:

• in your ICBC E-LEARNING account profile (and you may display a limited or full profile to other ICBC E-LEARNING site users);
• in applying for financial assistance; or
• when participating in a course, forum, webinar, or other interactive experience on the ICBC E-LEARNING site (noting that in some cases, this information is shared with a third party that provides tools or other assistance for the ICBC E-LEARNING Site or a course).

ICBC E-LEARNING encourages you to use discretion before voluntarily sharing additional Personal Information on the ICBC E-LEARNING site. (If you later choose to delete your ICBC E-LEARNING account, deletion of your Personal Information will be subject to the process and limits outlined below.)

Partners do not receive your Personal Information unless and until you enroll in a course. If you enroll in a course, the Partner that offers the course will receive Personal Information from your ICBC E-LEARNING account profile plus the information that ICBC E-LEARNING collects about your activity and performance in the course in which you enrolled.

Cookies And Tracking Technologies on the ICBC E-LEARNING Site

Like many companies, ICBC E-LEARNING uses Cookies and other common Tracking Technologies on the ICBC E-LEARNING Site and in email communications to help ICBC E-LEARNING better understand your use and needs of the ICBC E-LEARNING Site, current and future ICBC E-LEARNING-related products and services, and how ICBC E-LEARNING and Partners can improve. For example:

• based on your cookie settings, ICBC E-LEARNING tracks information indicating, among other things, which pages of the ICBC E-LEARNING Site were visited, the order in which they were visited, when they were visited, and which hyperlinks and other user interface controls were used;
• ICBC E-LEARNING may log the IP address, operating system, and browser software (including mobile use and device type when you use ICBC E-LEARNING native mobile apps) you used when accessing the ICBC E-LEARNING Site, and ICBC E-LEARNING may be able to determine from an IP address your Internet Service Provider and the geographic location of your point of connectivity; and
• ICBC E-LEARNING may track and collect information from emails that ICBC E-LEARNING sends to you, for example whether you opened the email or clicked on any links from the email.

ICBC E-LEARNING also partners with third parties to help us track and understand your activity on the ICBC E-LEARNING Site, how you interact with ICBC E-LEARNING’s social media, and how you find or may be referred to the ICBC E-LEARNING Site. Individual Partners may separately use Tracking Technologies within their courses and email communications to understand your activity within a course and how you find or may be referred to a course on the ICBC E-LEARNING Site.

ICBC E-LEARNING and Partners use Cookies and other Tracking Technologies for the following purposes:

• when necessary for system administration, security, and integrity to ensure the ICBC E-LEARNING Site works properly for you. Without these technologies, the ICBC E-LEARNING Site may not function correctly;
• to enable analytics, performance and functionality, to help ICBC E-LEARNING and Partners gather information about how visitors use the ICBC E-LEARNING Site and monitor ICBC E-LEARNING Site performance, and to enhance your experience by recognizing whether you have visited the ICBC E-LEARNING Site before and may have any personal preferences; and
• to support marketing by enabling ICBC E-LEARNING and Partners to deliver content relevant to your interests on the ICBC E-LEARNING Site and third-party sites based on how you interact with ICBC E-LEARNING or Partner advertisements or content. ICBC E-LEARNING and Partners use “first-party” cookies, which means cookies served by ICBC E-LEARNING or an individual Partner, and also “third-party” cookies, which means cookies served by third parties that help ICBC E-LEARNING and Partners track this information.

You have some options for managing Cookies and other Tracking Technologies. These include:

• Modifying your browser settings: You should be able to control how and whether your web browser accepts Cookies by adjusting its privacy and security settings. The “help” feature of the menu bar on most browsers will tell you how to stop accepting new Cookies, how to receive notification of new Cookies, and how to disable existing Cookies. If you reject ICBC E-LEARNING’s Cookies, many functions and conveniences of the ICBC E-LEARNING Site may not work properly.
• Opting-out of certain third-party tracking and advertising: Some of the third parties used by ICBC E-LEARNING or a Partner for Cookies and Tracking Technologies offer the ability to opt-out from their tracking by following processes described on their websites. A list of some such third parties is maintained and available at the ICBC E-LEARNING learner Help Center and includes, for some, links to applicable opt-out processes. Neither ICBC E-LEARNING nor any Partner is responsible for the effectiveness of any third-party opt-out options.

HOW YOUR INFORMATION IS USED

ICBC E-LEARNING and Partners use information, including Personal Information, to carry out the following purposes:

• Operate and improve the ICBC E-LEARNING Site – This includes creating and improving features that support the ICBC E-LEARNING community and enable ICBC E-LEARNING Site usage at scale. This also includes personalizing the ICBC E-LEARNING Site, so your learning experience is tailored to your interests and needs.
• Create, administer, provide, and teach courses – This includes creating and improving the delivery of massive open online courses and programs on ICBC E-LEARNING. This also includes personalizing courses, so your learning experience is tailored to your interests and needs, and assessing your performance and awarding certificates.
• Offer and improve products and services – This includes enabling you to navigate the ICBC E-LEARNING Site, to enroll and participate in courses and programs on the ICBC E-LEARNING Site, to learn effectively in such courses and programs, and to purchase or obtain products and services on the ICBC E-LEARNING Site such as Verified Certificates.
• Develop and maintain the security and performance of the ICBC E-LEARNING Site – This includes tracking ICBC E-LEARNING Site outages and creating software solutions, detecting violations of the Terms of Service, and monitoring uses, misuses, and potential misuses of the ICBC E-LEARNING Site.
• Communicate with you – This includes answering your course and platform questions, notifying you of course and ICBC E-LEARNING Site maintenance and updates, marketing to you about course offerings, programs, news, and related products and services of ICBC E-LEARNING or ICBC E-LEARNING affiliates, and as permitted under applicable law, sending you communications about products or services of selected business partners that may be of interest to you.
• Support scientific research including, for example, in the areas of cognitive science and education – This includes collaborating to enable and conduct research about how learner’s access and master course materials online, with the goal of improving course outcomes.
• Track ICBC E-LEARNING Site usage against goals and mission – This includes performing analytics to evaluate access to and performance in courses and course-related products and services and to report aggregate usage information (not Personal Information) to business partners and external audiences.
• Exercise, enforce, and comply with legal rights and obligations – This includes responding to subpoenas, court orders, or other legal process; and investigating, preventing, or taking action regarding illegal activities, suspected fraud, security or technical issues, or to protect the rights, property, or safety of ICBC E-LEARNING, Partners, or others, and as otherwise required by applicable law.

ICBC E-LEARNING or a Partner may also seek your consent for additional uses of information, including Personal Information, and will use it only for the purpose described to you. All use of Personal Information is subject to applicable law.

HOW YOUR INFORMATION IS SHARED

ICBC E-LEARNING and Partners share information, including Personal Information, with third parties for the following purposes:

• With service providers, contractors, and other third parties that help carry out the uses described above – ICBC E-LEARNING requires third parties to: (1) abide by this Privacy Policy and applicable law; (2) handle Personal Information in a confidential manner and maintain adequate security; and (3) use Personal Information only as needed to fulfill the relevant purpose(s). In some cases, the ICBC E-LEARNING Site and individual courses are integrated with third-party services or contain links to websites published by third parties, including other content providers as well as service providers. These third parties are responsible for their own privacy practices, so you should pay attention anytime you are redirected to a third-party website and be sure to review its privacy policy.
• With other learners in courses that you take and with other visitors to the ICBC E-LEARNING Site, to create an interactive learning environment, support class participation, and share course information – This includes sharing comments, coursework, or other information or content that you submit to a portion of the ICBC E-LEARNING Site designed for viewing by other class Partners or for public communication. This also includes providing opportunities for you to communicate with other users who may have similar interests or educational goals, for instance, recommending specific study partners or connecting potential student mentees and mentors. In such cases, ICBC E-LEARNING and each Partner that offers a course in which you enrolled may use all information collected about you to determine who might be interested in communicating with you, but will only provide others your username (for clarity, no disclosure of your real name or email address).
• With employers, government programs, institutions, or other enterprises that sponsor your enrollment in a course for training or other educational purposes – If an entity pays for or otherwise sponsors your Verified Certificate or course participation, ICBC E-LEARNING will share information with the entity as needed to confirm your enrollment, participation, progress, and completion status in that course.
• With affiliates of ICBC E-LEARNING or a Partner, or with successors in the event of a merger, acquisition, or reorganization, for their use consistent with this Privacy Policy.

ICBC E-LEARNING or a Partner may also seek your consent for additional disclosures of information, including Personal Information, and will share it only as described to you. In addition, ICBC E-LEARNING or a Partner may share with the public and with third parties, including but not limited to researchers and business partners, information and Personal Information that is de-identified or aggregated in a manner that does not personally identify you.

HOW TO MANAGE YOUR PERSONAL INFORMATION

You can manage your Personal Information through learner features on the ICBC E-LEARNING Site and requests to the ICBC E-LEARNING learner support team. If your request involves information controlled by a Partner, ICBC E-LEARNING learner support will notify and coordinate with the appropriate Partner to address your request. ICBC E-LEARNING will provide support to the extent required by applicable law (for example, learners in the European Union) and more broadly when possible, as a courtesy in our sole discretion. ICBC E-LEARNING will notify you in the event that ICBC E-LEARNING is unable to meet a request that is not legally required. Similarly, Partners will only be obligated to comply with requests to the extent legally required, but may choose to comply with other requests in their sole discretion.

Access and correct your Personal Information

Much of your Personal Information is available in your ICBC E-LEARNING account. Your name, email address, and other identifiable profile information is editable through the profile settings in your ICBC E-LEARNING account except as noted below. Your account dashboard lists all current and archived courses in which you have enrolled and includes links to any Verified Certificates you may have earned. The dashboard also contains copies of your answers and other participation and performance in courses. Please contact ICBC E-LEARNING learner support to access and update this or other information. If your request involves information controlled by a Partner, ICBC E-LEARNING learner support will notify the appropriate Partner of your request.

Exceptions:

• Usernames cannot ever be changed. This is an ICBC E-LEARNING system restriction. Because usernames identify you in courses and elsewhere on the ICBC E-LEARNING Site, ICBC E-LEARNING encourages you to use discretion in choosing your username. If you want to protect your identity, do not use your real name or a name identifiable to you as your username.
• ICBC E-LEARNING does not track or index every time or every place on the ICBC E-LEARNING Site when or where a learner may volunteer Personal Information, so neither ICBC E-LEARNING nor Partners will be able to help you locate or manage all such instances. ICBC E-LEARNING encourages you to use discretion before volunteering Personal Information on the ICBC E-LEARNING Site.

Restrict or object to the processing of Personal Information

If you want to manage emails and other communications to you, you may update your preferences in your ICBC E-LEARNING account dashboard, follow the steps described in links at the bottom of email messages, or contact ICBC E-LEARNING learner support. You may object to, or request that ICBC E-LEARNING or a Partner stop, its use of your Personal Information for other purposes by contacting the ICBC E-LEARNING learner support team. If your request involves information controlled by a Partner, ICBC E-LEARNING learner support will notify the appropriate Partner of your request. Please note that if you choose to restrict ICBC E-LEARNING’s or a Partner’s ability to process Personal Information, and the processing is otherwise required to provide you with various services and products offered on the ICBC E-LEARNING Site, you may not be able to establish an ICBC E-LEARNING user account or enroll for a course, and ICBC E-LEARNING or a Partner may not be able to provide you with those services or products.

Delete account and Personal Information

To request deletion of your ICBC E-LEARNING account and Personal Information, you should click the button labeled “Delete my account” in your ICBC E-LEARNING account settings. Because deletion on the ICBC E-LEARNING system is a permanent action and cannot be reversed, ICBC E-LEARNING may ask you to complete a process that aims to confirm your authority to manage the ICBC E-LEARNING account affected by your request.

With respect to your ICBC E-LEARNING account, ICBC E-LEARNING will permanently:

• deactivate your ICBC E-LEARNING account,
• remove the active profile,
• retire your username, and
• remove you from ICBC E-LEARNING email lists.

With respect to your Personal Information, ICBC E-LEARNING will permanently delete your ICBC E-LEARNING account profile Personal Information from the ICBC E-LEARNING Site.

As noted above, to the extent that ICBC E-LEARNING associates the information that ICBC E-LEARNING collects directly or indirectly with an individual (for example, you), the association is based on Personal Information in your ICBC E-LEARNING account profile. By erasing the Personal Information in your ICBC E-LEARNING account profile, the remaining information about your activity on the ICBC E-LEARNING Site will no longer be associated with you, except as noted below.

These changes will be applied to data stores that are used for operation of the ICBC E-LEARNING Site including course administration by Partners. If you enrolled in any courses on the ICBC E-LEARNING Site, the ICBC E-LEARNING learner support team will share your request with the Partners that offered those courses.

Exceptions:

• Deletion will not apply to historical activity logs or archives unless and until these logs and data naturally “age-off” the ICBC E-LEARNING system.
• ICBC E-LEARNING does not track or index every time or every place on the ICBC E-LEARNING Site when or where a learner may volunteer Personal Information, so neither ICBC E-LEARNING nor Partners will be able to help you locate or manage all such instances. ICBC E-LEARNING encourages you to use discretion before voluntarily sharing your Personal Information on the ICBC E-LEARNING Site.
• ICBC E-LEARNING will archive course data (in a manner and to the extent permitted under applicable law) to serve its mission to enable scientific research on cognitive science and education. These archives are used to produce encrypted research data packages for Partners, and Personal Information may not be deleted from research data packages retained by Partners.
• ICBC E-LEARNING and each applicable Partner cannot always delete records of past interactions and transactions. For example, records relating to previous purchases on the ICBC E-LEARNING Site must be retained for financial reporting, audit, and compliance reasons.
• ICBC E-LEARNING and each Partner will retain and use Personal Information as necessary to comply with its legal obligations, resolve disputes, enforce its agreements, and as otherwise permitted by applicable law.

Data retention

ICBC E-LEARNING will retain your Personal Information for as long as your account is active or as needed to provide you with services; to maintain a record of your transactions for financial reporting, audit, and compliance purposes; and to comply with ICBC E-LEARNING’s legal obligations, resolve disputes, enforce its agreements, and as otherwise permitted by applicable law. If you enroll in a Partner’s course, such Partner will also retain your Personal Information for as long as needed to provide you with services; to maintain a record of your transactions for financial reporting, audit, and compliance purposes; and to comply with its legal obligations, resolve disputes, enforce its agreements, and as otherwise permitted by applicable law. Upon your request that ICBC E-LEARNING deactivate your account and delete your information, ICBC E-LEARNING will follow the process described above, including without limitation archiving your course data (in a manner and to the extent permitted under applicable law) to serve its mission to enable scientific research on cognitive science and education. These archives will be used to produce encrypted research data packages for Partners, and each such Partner may also keep and use course data for scientific research.

STORAGE & SECURITY

ICBC E-LEARNING stores information, including Personal Information, on its own servers and also on servers of companies that ICBC E-LEARNING hires to provide services. Each Partner also stores information, including Personal Information, on its own servers and/or on servers of companies that the Partner hires to provide services. In each case, information may be stored in the United States, South Africa and in other countries where ICBC E-LEARNING or a Partner operates, and in countries where ICBC E-LEARNING and each Partner’s respective service providers operate. If you are in the European Union, Switzerland, or other regions with laws governing data collection and use, you acknowledge that ICBC E-LEARNING and each Partner may transfer, process and store your personal information in the United States and other countries, the privacy laws of which may be considered less strict than those of your region.

ICBC E-LEARNING controls its own copy of information collected through the ICBC E-LEARNING Site and has an information security program designed to protect information in its possession or control. This is done through a variety of privacy and security policies, processes, and procedures. ICBC E-LEARNING uses administrative, physical, and technical safeguards that reasonably and appropriately protect the confidentiality, integrity, and availability of the information that it collects, receives, stores, or transmits. Nonetheless, no method of transmission over the Internet, or method of electronic storage, is 100% secure; and therefore, ICBC E-LEARNING cannot guarantee its absolute security. While ICBC E-LEARNING works hard to ensure the integrity and security of its network and systems, ICBC E-LEARNING cannot guarantee that its security measures will prevent “hackers” or other unauthorized persons from illegally accessing or obtaining information.

If ICBC E-LEARNING learns of a security breach involving its copy of your Personal Information, ICBC E-LEARNING may attempt to notify you electronically so that you may take appropriate protective steps. By using the ICBC E-LEARNING Site or providing Personal Information to ICBC E-LEARNING, you agree that ICBC E-LEARNING can communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the ICBC E-LEARNING Site. If a security systems breach occurs, ICBC E-LEARNING may post a notice on the ICBC E-LEARNING homepage (www.icbc-elearning.com) or elsewhere on the ICBC E-LEARNING Site and may send an email to you at the email address associated with your ICBC E-LEARNING account. Depending on where you are located, you may have a legal right to receive notice of a security breach, involving your Personal Information, in writing.

If a Partner learns of a security breach involving that Partner’s copy of your Personal Information, the Partner may attempt to notify you electronically so that you may take appropriate protective steps. By enrolling in a Partner’s course on the ICBC E-LEARNING Site or providing Personal Information to the Partner, you agree that the Partner can communicate with you electronically regarding security, privacy, and administrative issues relating to your course enrollment and participation. If a security systems breach occurs, the affected Partner may post a notice on the ICBC E-LEARNING site and/or send an email to you at the email address associated with your enrollment in the Partner’s course on the ICBC E-LEARNING Site. Depending on where you are located, you may have a legal right to receive notice of a security breach, involving your Personal Information, in writing.

Privacy Policy Updates

This Privacy Policy will be reviewed and updated from time to time. When changes are made, the Privacy Policy will be labeled as “Revised (date),” indicating that you should review the new terms, which will be effective immediately upon posting on this page, with an updated effective date. By accessing the ICBC E-LEARNING Site after any changes have been made, you accept the modified Privacy Policy and any changes contained therein. In case you miss the notification referenced above, be sure to return to this page periodically to ensure familiarity with the most current version of this Privacy Policy.

Contact Information

If you have privacy concerns, have disclosed data you would prefer to keep private, or would like to access the Personal Information that ICBC E-LEARNING maintains about you, please contact on our website using the contact form. If your request involves a Partner, ICBC E-LEARNING will notify the appropriate Partner of your request.

Glossary

Cookies are unique identifiers usually in the form of small data files placed on your device that send certain information about your activity on the ICBC E-LEARNING Site or in an email communication back to ICBC E-LEARNING or the authorized third party that served the cookie. ICBC E-LEARNING or third parties may also use Flash cookies.

ICBC E-LEARNING Site consists of all content and pages located within the ICBC-ELEARNING.COM web domain and all ICBC E-LEARNING mobile applications.

Partner is each educational institution or other leading global institution or entity that provides courses through the ICBC E-LEARNING Site.

Personal Information is information that specifically identifies you or that, when combined with other information, could be used to identify you.

Tracking Technologies are web beacons, clear gifs, pixels, and similar technologies that are also unique identifiers used to track your online activity but are not stored on your device.

Verified Certificate is a virtual certificate that shows that you have successfully completed your ICBC E-LEARNING course or program and verified your identity using your webcam and your acceptable form of photo ID.

Effective Date: October 10, 2021