As used in this Privacy Policy, the following terms have the following meanings:

“We”, “us”, and “our” refer to St. George’s University.

“Business Associates” means third party service providers which St. George’s University may contract with to provide services on our behalf including those related to the Sites or for transactions occurring on the Sites including, but not limited to, Social Networking, hosting, web analytics, Online Behavioral Advertising, lead generation, academic, business, career, or financial services.

“Educational Partners” means St. George’s University and their subsidiaries and affiliates.

“Unrelated Entities” means third parties that are not Educational Partners and who are not providing services as Business Associates

“Affiliates” means companies related by common ownership or control.

“Nonaffiliates” means companies not related by common ownership or control.

“Information” means any Information collected and includes:  “Personal Information”, “Web Analytical Information” or any other Information collected from you through our Sites.

“Personal Information” means Information that may be used, alone or in combination, to identify a specific individual and includes Financial Information.

“Online Behavioral Advertising” means the collection of data from a particular computer or device regarding web viewing behaviors over time and across web sites for the purpose of using such data to predict user preferences or interests to deliver advertising to that computer or device based on the preferences or interests inferred from such Web viewing behaviors.

“Site” or “Sites” means websites operated by or exclusively on behalf of St. George’s University, regardless of domain name or IP address.

“Social Network” means various Internet communication technologies provided on Sites  that facilitate conversation and interaction between people online and includes, but is not limited to, blogs, discussion forums, wikis, chat sessions, news groups, etc.

“Web Analytical Information” means internet-generated Information we collect when you visit our Sites.  This Information may be linked with Personal Information.  When linked with other Information identifying you personally, either alone or in combination with other Information, then such Information also will be considered Personal Information.

We collect various types of Information from you through our Sites and other websites where you can express interest in our services over the phone, via printed forms, and in person.  Some Information is collected automatically through various web and internet technologies including Social Networking tools used by us.  Other Information is collected when you provide it to us voluntarily. We may also obtain information from Educational Partners and Unrelated Entities and combine that with information we collect about you.

Each time you visit one of our Sites, Web Analytical Information is automatically gathered.  In general, this Information does not identify you personally.  Examples of Web Analytical Information include, but are not limited to:

• IP address
• Collection Date
• Publisher Name
• Connection Speed
• Day of Week or Time of Day (hour)
• Language settings
• Country, State, Designated Market Area (DMA), City (relating to IP address, if available)
• Domain (.com, .net, .mil, .org, .edu, etc.)

This Information may be linked with Personal Information to accomplish the purposes described in this Privacy Policy.

In addition to the Web Analytical Information automatically collected when you visit our Sites, St. George’s University also collects, uses, and discloses Personal Information that you provide to us voluntarily online or offline.  Some examples include, but are not limited to, when you respond to an advertisement, a survey, or a request for information; register for classes; apply for financial aid; order educational or other products and services; set up a Social Network or other Site profile; or use one of our career resources, learning assessments or other interactive tools.  The exact nature of the Personal Information may vary depending on the type of response or service requested.

We operate or may process information in multiple jurisdictions and some Educational Partners and Business Associates may be located outside of the jurisdiction in which you reside.  In such cases, your Personal Information may be collected, used, disclosed, stored and processed in these other jurisdictions for the purposes described in this Privacy Policy.  The data protection and other laws of the United States and other countries might differ from your jurisdiction.  Please be advised that, by using our Sites and services, you are consenting to the transfer and processing of your Information across international borders.  Your Information may be subject to the laws of those other jurisdictions, including lawful requirements to disclose Personal Information to government authorities.

Some laws allow you to opt-out of our sharing personal information about you in certain circumstances with nonaffiliated third party companies; that is, you may direct us to not make such disclosures.  However, we do not currently share information about you with any nonaffiliated third party that triggers this opt-out right.  Accordingly, there is no need for you to opt-out or take any other affirmative action telling us not to share such information with nonaffiliated third parties.

Some laws allow you to opt-out of our sharing certain personal information about you (e.g., information other than your transactions and experiences with us such as your credit report) among our affiliated companies; that is, you may direct us to not make such disclosures.  However, we only share your transactions and experiences information with our affiliated companies.  Therefore, there is no need for you to exercise such opt-out right.

Finally, some laws also give you the right to limit some kinds of marketing from our affiliated companies.  You may elect not to have our affiliated companies market their products or services to you where such marketing is based on information about you that we share with them.  Since our affiliated companies, from time to time, do engage in such marketing, we are providing you with the ability to opt-out so that you do not receive these types of marketing communications from us in the future.  To limit these marketing offers, please follow the instructions to unsubscribe made available on the marketing material you receive.

Our online advertisements and Sites take part in Online Behavioral Advertising.  Some of these ads are targeted to your interests and preferences based on your browsing history, which is stored in a cookie on your computer.  Your browsing history on the Sites may be tracked in these cookies even if ads are not being displayed.

Cookies, web beacons, and other relevant internet technologies are used on our Sites to allow us to accomplish the uses set out above as well as to deliver Sites messaging and to keep track of your Information.

What are cookies?

Cookies save a file to an Internet user’s computer and store a limited amount of information.  For example, some cookies help us remember your computer and streamline the login process, some are used to authenticate you as a user on our systems, and some cookies help us deliver advertising that is more customized to your needs on our Web site and the Web sites of our partners.

A cookie can either be stored in your computer’s memory temporarily and automatically deleted when you close your Web browser (a “session” cookie) or placed on your hard drive (a “persistent” cookie) by a Web server.  A persistent cookie is not deleted when the browser is closed and will stay in one of your browser’s subfolders until you delete it manually or your browser deletes it based on an expiration period setting contained within the persistent cookie’s programming.

In addition to the general browser cookies, we may use Local Shared Objects (sometimes referred to as “Flash cookies” that are built for use with the Adobe® Flash® Player), for authentication purposes, to personalize and to enhance Web site presentation and functionality.  Unlike traditional cookies, Flash cookies cannot be managed through your browser controls and are not saved in your browser’s temporary Internet files.  Flash cookies remain in your Flash Player folder until they are removed, as described below.

What are the related technologies?

St. George’s University also uses Web Beacons (also known as clear gifs or pixel tags), which are images that we incorporate onto our Web site to analyze advertising campaigns and the general usage patterns of Web site visitors.

How does St. George’s University use these technologies?

Browser Cookies:  Browser cookies are used by St. George’s University and its partners for targeted marketing activities and Web site analytics. Browser cookies are placed on sgu.edu by us as well as third-parties.  The information that we collect and share (e.g., IP Address of your computer and pages viewed) does not contain customer or consumer names, addresses, telephone numbers, or email addresses. This information helps our company refine and improve our Web site content and presentation, deliver relevant advertising regarding St. George’s University on other Web sites you visit and optimize our placement in search engine results.

Flash Cookies:  Flash cookies may be used by St. George’s University for limited purposes, such as authentication, as well as distinguishing customers from visitors to our Web site.

Web Beacons:  St. George’s University uses Web Beacons to help manage online advertising and site traffic analysis.  These image files are provided by third parties for external ad management, search marketing tracking, affiliate marketing, and sgu.edu site analytics.  In all such instances, the Web Beacon is programmed to collect your computer’s IP Address and certain other limited information when you are on our Web site.  We do not collect your name, e-mail address, or telephone numbers using this technology.  For example, with online advertising campaigns, Web Beacons enable third parties to recognize a cookie on your Web browser, which in turn enables us to learn which advertisements bring unique users to sgu.edu from other locations on the Web.

How Do I Opt Out of Cookies and Web Beacons?

Please keep in mind that refusing cookies may affect your experience on our Web site.

Browser Cookies: For these cookies, you may delete or prevent placement of cookies by following the instructions contained in the Help section of your browser.

Flash Cookies:  To delete or prevent placement of Flash cookies, you will need to visit the Adobe Flash Player Help site at www.adobe.com/go/settingsmanager, click on the hyperlink for “Website Privacy Settings panel” on the left hand side of the screen and follow the instructions for preventing third-party Flash content from storing data on your computer.

Web Beacons:  Because Web Beacons or clear gifs are included within the recipe for a web page (just the same as any other content request), you cannot opt out or refuse them.  However, where they are used in conjunction with cookies they can be rendered ineffective by either opting out of cookies or by changing the cookie settings in your browser.  In other instances, such as in the case of emails, clear gifs are not used in conjunction with cookies and if you are unhappy with the use of clear gifs in such manner, then you should not use the Web site or register to receive emails.  These small pieces of program code reside in your computer and browser and can be removed.  If you desire to remove such technologies you may do so, but this may render our Sites unusable to you.  You can opt out of cookies or the other internet technologies used by disabling these features in your browser program.  Please note that the deletion of certain opt-out cookies may require you to renew your Online Behavioral Advertising opt-outs periodically.  Consult your browser’s “Help” menu for assistance in changing cookie settings or removing cookie files.

We will take commercially reasonable measures to secure and store your Information to protect against the loss, misuse, and alteration of the Information under our control.  Unfortunately, no data transmission over the internet can be guaranteed to be completely secure.  As a result, although we will utilize such measures, we do not guarantee you against the loss, misuse, or alteration of Information under our control, and you provide Information to us at your own risk.  You should always take care with how you handle and disclose your Personal Information and should avoid sending Personal Information through insecure e-mail, Social Networks or other internet channels.

Some of our Sites may contain links to websites hosted by Educational Partners, Unrelated Entities, and Business Associates operating websites on their own behalf or on behalf of multiple entities.  Some of these websites may collect your Personal Information and may apply their own policies on how your Personal Information is used.  In addition, some of our Sites may have Additional Policies that apply to the use of Personal Information collected on that Site.  Please make sure to read the policies of any websites you visit on the internet carefully.  Please be aware that we are not responsible for the privacy practices or the content of any websites that are not operated by or exclusively for us, and the collection, use, and disclosure of Information about you will be subject to the policies applicable on those websites.

St. George’s University may update this Privacy Policy or revise it from time to time.  We make every reasonable attempt to ensure that all the information on the Site is accurate and up to date. Nevertheless, we make no representations or warranties, whether express or implied, as to the accuracy, reliability or completeness of the information, text, graphics, links or other items contained in the Site or in any site linked to or from the Site.  St. George’s University reserves the right to change the programs, policies and services described in this Site at any time without notice, and we will not be liable for any special or consequential damages that result from the use of, or inability to use, the materials in this Site.  We urge you to review this Privacy Policy frequently to obtain the current version.  Your continued provision of Personal Information or use of our services following any changes to this Privacy Policy constitutes your acceptance of such changes.