What You Consent to by Using Our Site
What Information We Collect
We gather two types of information about users through the Site:
Non-Personal Information. When users come to our Site, we may track, collect and aggregate Non-Personal Information indicating, among other things, which pages of our Site were visited, the order in which they were visited, when they were visited, and which hyperlinks were “clicked.” We also collect information from the URLs from which you linked to our Site. Collecting such information may involve logging the IP address, operating system and browser software used by each user of the Site. Although such information is not Personally Identifiable Information, we may be able to determine from an IP address a user’s Internet Service Provider and the geographic location of his or her point of connectivity.
You should be able to control how and whether cookies will be accepted by your web browser. Most browsers offer instructions on how to reset the browser to reject cookies in the “Help” section of the toolbar. If you reject our cookies, many functions and conveniences of this Site may not work properly.
Personally Identifiable Information. We collect Personally Identifiable Information that you provide to us when you register for an account, update or change information for your account, purchase products or services, complete a survey, sign-up for email updates or Online Courses, participate in our public forums, send us email messages, and/or participate in Online Courses or other services on our Site. We may use the Personally Identifiable Information that you provide to respond to your questions, provide you the specific course and/or services you select, send you updates about Online Courses offered by ICBM or other ICBM events, and send you email messages about Site maintenance or updates.
Account Registration. If you register for an account on our Site, you may be required to provide us with Personally Identifiable Information such as your name and email address
Updates. ICBM may offer you the ability to receive updates either via email or by posting on portions of the Site only accessible to registered users. In order to subscribe to these services, you may be required to provide us with Personally Identifiable Information such as your name and email address.
Participation in Online Courses. ICBM offers users the opportunity to participate in an Online Course on or through the Site. If you desire to participate in a course, you will be asked to provide us with certain information necessary to conduct such a course. This information may include, among other things, your name and email address.
If you participate in an online course, we may collect from you certain student-generated content, such as assignments you submit to Course Facilitators, peer-graded assignments and peer grading student feedback. We also collect course data, such as student responses to in-video quizzes, standalone quizzes, exams and surveys.
Identity Verification. ICBM may offer you the ability to verify your identity for selected classes. In order to enroll for these services, you are required to provide us with Personally Identifiable Information such as your name, address, date of birth, a headshot taken using a webcam, a photo identification document, and a sample of your typing patterns. Additionally, if you apply for financial aid in connection with these services, you are required to provide information regarding your income.
Communications with ICBM. We may receive Personally Identifiable Information when you send us an email message or otherwise contact us.
Third Party Sites. We may receive Personally Identifiable Information when you access or log-in to a third party site, e.g., Facebook, from our Sites. This may include the text and/or images of your Personally Identifiable Information available from the third party site.
Surveys. We may receive Personally Identifiable Information when you provide information in response to a survey operated by us.
Partner sites providing Online Course related tools and services to ICBM users may collect nonfinancial individual level user data regarding the individual’s use of that partner site while engaged with such Online Course related activities, and the partner sites may share that data with ICBM for the purpose of improving ICBM’s services, the partner site’s services, and the individual’s education experience. This data includes information such as the amount of time spent on the partner site and pages viewed.
Third Party Credit Card Processing. ICBM provides you with the ability to pay for Online Courses and other services using a credit card through a third party payment processing service provider. Please note that our service provider – not ICBM – collects and processes your credit card information.
How We Use the Information
Non-Personal Information. We use Non-Personal Information to build higher quality, more useful services by performing statistical analyses of the collective characteristics and behavior of our users, and by measuring demographics and interests regarding specific areas of our Site. We may also use it for other business purposes.
Updates. We use Personally Identifiable Information collected when you sign-up for our various email or update services to send you the messages in connection with the Site or an Online Course. We may also archive this information and/or use it for future communications with you.
Forums. To facilitate your use of the Forums, we use Personally Identifiable Information collected during your use of the Forums. In addition, we may publish this information via extensions of our Platform that use third-party services, like mobile applications. We also reserve the right to reuse Forum posts containing Personally Identifiable Information in future versions of the courses we offer, and to enhance future course offerings. We may archive this information and/or use it for future communications with you and/or your designee(s), and/or provide it to ICBM or the instructor(s) associated with the courses you have taken. We may also use or publish posts submitted on the Forums without using Personally Identification Information.
Participation in Online Courses. We use the Personally Identifiable Information that we collect from you when you participate in an Online Course through the Site for processing purposes, including but not limited to tracking attendance, progress and completion of an Online Course. We may also share your Personally Identifiable Information and your performance in a given Online Course with the Course Facilitator or Course Facilitators who taught the course, with teaching assistants or other individuals designated by the Course Facilitator or Course Facilitators to assist with the creation, modification or operation of the course, and with the institution or institutions with which they are affiliated. Also, we may archive this information and/or use it for future communications with you.
Identity Verification. For services that require identity verification, we use the Personally Identifiable Information that we collect for verifying your identity, and for authenticating that submissions made on the Site were made by you. Your photo identification document will be deleted after successful verification of your profile information.
Disclosure to ICBM Operations and Maintenance Contractors. We use various service providers, vendors and contractors (collectively, “Contractors”) to assist us in providing our products and services to you. Our Contractors may have limited access to your Personally Identifiable Information in the course of providing their products or services to us, so that we in turn can provide our products and services to you. These Contractors may include vendors and suppliers that provide us with technology, services, and/or content related to the operation and maintenance of the Site or the Online Course. Access to your Personally Identifiable Information by these contractors is limited to the information reasonably necessary for the contractor to perform its limited function for us.
Disclosure to Acquirers. ICBM may disclose and/or transfer your Personally Identifiable Information to an acquirer, assignee or other successor entity in connection with a sale, merger, or reorganization of all or substantially all of the equity, business or assets of ICBM to which your Personally Identifiable Information relates.
e-Readers. If we receive any Personally Identifiable Information related to the extent to which you use designated e-Readers to access ICBM materials, we may archive it, and use it for research, business, or other purposes.
Confidentiality & Security of Personally Identifiable Information
Updating or Deleting Your Personally Identifiable Information
You can access your Personally Identifiable Information and confirm that it remains correct and up-to-date or choose whether or not you wish to receive material from us or some of our partners by logging into the Site and visiting your user account page. You may also contact us via firstname.lastname@example.org. We try to answer every email promptly, but may not always be able to do so. Keep in mind, however, that there will be residual information that will remain within our databases, access logs and other records, which may or may not contain your Personally Identifiable Information.
If you have any privacy-related questions, unresolved problems, or complaints you may contact us via email@example.com.
California Privacy Rights
Under California’s “Shine the Light” law, California residents who provide personal information in obtaining products or services for personal, family or household use are entitled to request and obtain from us once a calendar year information about the customer information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year (e.g. requests made in 2012 will receive information regarding 2011 sharing activities).
To obtain this information, please send an email message to firstname.lastname@example.org with “Request for California Privacy Information” on the subject line and in the body of your message. We will provide the requested information to you at your e-mail address in response. Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing will be included in our response.
International Privacy Practices
ICBM’s Sites are primarily operated and managed on servers located and operated within the United States. In order to provide our products and services to you, we may send and store your personal information (also commonly referred to as personal data) outside of the country where you reside or are located, including to the United States. Accordingly, if you reside or are located outside of the United States, your personal information may be transferred outside of the country where you reside or are located, including to countries that may not or do not provide the same level of protection for your personal information. We are committed to protecting the privacy and confidentiality of personal information when it is transferred. If you reside or are located within the European Economic Area and such transfers occur, we take appropriate steps to provide the same level of protection for the processing carried out in any such countries as you would have within the European Economic Area to the extent feasible under applicable law. By using and accessing our products and services, users who reside or are located in countries outside of the United States agree and consent to the transfer to and processing of personal information on servers located outside of the country where they reside, and that the protection of such information may be different than required under the laws of their residence or location.
No Information from Children Under 13
ICBM strongly believes in protecting the privacy of children. In line with this belief, we do not knowingly collect or maintain Personally Identifiable Information on our Site from persons under 13 years of age, and no part of our Site is directed to persons under 13 years of age. If you are under 13 years of age, then please do not use or access this Site at any time or in any manner. We will take appropriate steps to delete any Personally Identifiable Information of persons less than 13 years of age that has been collected on our Site without verified parental consent upon learning of the existence of such Personally Identifiable Information.
Effective as of 15 October, 2015.
Institute for Contemporary Buddhist Ministry (“ICBM”) is committed to the privacy and security of our students. ICBM Student Records Policy complies with the Family Educational Rights and Privacy Act of 1974 (FERPA) – sometimes called the Buckley Amendment – which establishes students’ rights and institutions’ responsibilities regarding the privacy of education records. It provides guidelines for maintaining the confidentiality of education records and monitoring the release of information from those records.
Your Rights Under FERPA
As a current or former student, The Family Educational Rights and Privacy Act (FERPA) affords you certain rights regarding your education records. They are:
The right to inspect and review your records. You may request to review your records by submitting a written request to ICBM Registrar or other school official having custody of such records;
The right to seek amendment of your records which you believe are inaccurate, misleading, or otherwise in violation of your privacy rights. Requests for amendment of records must be in writing and must describe the specific portions of specific records that you wish to have amended, text or instructions as to the change desired, and the reasons why the change is justified;
The right to restrict the disclosure of Directory Information; and
The right to file a complaint with the Department of Education’s Family Policy Compliance Office concerning alleged failures by ICBM to comply with the requirements of FERPA.
Definition of Education Records
Education records are those records directly related to a student maintained by ICBM or by a party acting for ICBM.
Release of Education Records
Except as provided in FERPA (see below) or other applicable law, ICBM will not disclose personally identifiable information from your education records unless you provide a written release containing:
What information is to be released
To whom the information is to be released
The purpose for which it is to be released
Your signature and the date signed
Faculty and staff are responsible for protecting the identity of students and keeping student grades confidential. Grades or evaluations linked to personal identifiers (names, ID numbers, or social security numbers) may not be publicly disclosed. Grades or evaluations may be posted only by using randomly generated codes or numbers. The return of graded papers or other assignments must also be accomplished in a manner that protects your identity.
Some records created and maintained by ICBM, although not covered by FERPA, may be subject to other federal and state laws or regulations regarding disclosure.
Directory Information Restriction
You may choose to grant or restrict release of your Personally Identifiable Information. ICBM by default restricts release of your personally identifiable information, and will only release personally identifiable information with your consent.
ICBM, in compliance with the Family Educational Rights and Privacy Act (FERPA), is responsible for monitoring access to and release of information from student education records. Staff and faculty with access to student education records are legally responsible for protecting the privacy of the student by using information only for legitimate educational reasons to instruct, advise, or otherwise assist students. FERPA also assures certain rights to students at ICBM regarding their education records. These rights do not transfer to parents, guardians, spouses or other family members without the specific written permission of the student.
Code of Responsibility for Security and Confidentiality of Records and Files
Security and confidentiality are matters of concern to all Institute employees and to all other persons who have access to education records. The purpose of this code is to clarify responsibilities in these areas. Each individual who has access to confidential information is expected to adhere to the regulations stated below. A person who has access to education records may not:
Reveal the content of any record or report to anyone, except in the conduct of his or her work assignments and in accordance with Institute policies and procedures.
Make or allow any unauthorized use of information.
Knowingly include false, inaccurate or misleading entry in any report or record.
Knowingly expunge a data record or a data entry form and record, report or file.
Share individual passwords with any other person (for password protected data).
Seek personal benefit or allow others to benefit personally from the knowledge of any confidential information they have acquired through work assignments.
Remove any official record or report, or copy of any official report, from the office where it is maintained, except in the performance of official duties.
Any knowledge of a violation of this code must be reported immediately to the violator’s supervisor. Violations may lead to disciplinary action, including dismissal.
Definition of Education Records
Education records are those records directly related to a student maintained by ICBM or by a party acting for ICBM.
Policy Revised and Updated July 9, 2016