Effective Date: March 25, 2019
We refer to the above website(s) and all related websites as “sites” and to each of them as a “site.” When we refer to “we,” “us,” or “our,” we mean NuStep, or the specific division, subsidiary, or affiliate that operates a site, provides its content, or processes information received through it, each as appropriate and applicable. When we refer to “you” or “your,” we mean the person accessing the site. If the person accessing the site does so on behalf of, or for the purposes of, another person, including a business or other organization, “you” or “your” also means that other person, including a business organization.
We take your privacy and the protection of your personal data seriously. We will only store, process and disclose your personal information in accordance with applicable law. We will make it clear when we collect personal information and will explain what we intend to do with it. We do our best to protect your privacy through the appropriate use of information security measures.
NuStep may collect different information from or about you depending on the manner in which you use our site(s) or Services. The following examples are provided to help you better understand the information we may collect through your use of the site(s) or in the course of us providing our Services.
We may collect, use, store and transfer different kinds of personal data about you, which we have grouped together as follows:
As an example of how we collect any information you provide to us directly, in order to use certain features of the site(s), such as creating an account, you are required to provide a username or email address and password, and in that case, we will collect and store any personal information you provided to us, such as email address, username, and/or password.
You may access our site(s) through third-party platforms, such as Facebook. If you use our site(s) on or through a third-party platform, including via any mobile and/or other Internet connected devices (“Wireless Devices”), or click on third-party links, the collection, use, and disclosure of your information and your use of the site(s) will also be subject to the privacy policies and other terms of such third parties or third-party platforms. You should review such privacy policies, terms and other agreements.
When you access NuStep’s site(s), we may automatically collect certain information. This information may include without limitation: (a) technical information about your computer or Wireless Device, such as your IP address, geolocation information, device type, operating system type and version, unique device ID, browser, browser language, domain and other systems information or platform types (collectively “Technical Information”); and (b) usage statistics about your interaction with the NuStep’s site(s), including pages accessed, referring website address(es) time spent on pages, pages visited, search queries, click data, date and time and other information regarding your use of the NuStep’s site(s) (collectively “Usage Data”).
We may use information about you for a number of purposes, including:
You can ask us or third parties to stop sending you marketing messages at any time by contacting us in writing and letting us know your specific opt-out request. To learn about your choices regarding interest-based advertising and cross-device tracking, please see below.
This section defines NuStep’s policies and practices with respect to Biometric Data, as defined below, and is implemented under applicable laws, including, but not limited to, the Illinois Biometric Information Privacy Act, 740 ILCS § 14/1, et seq. and as may be amended (“BIPA”).
NuStep will collect your Biometric Data for the following purpose(s):
NuStep will not disclose, disseminate, or otherwise share your Biometric Data to or with anyone other than its vendors, who provide NuStep with products and services using Biometric Data, without/unless:
NuStep shall use a reasonable standard of care to store, transmit, and protect from disclosure any Biometric Data collected. Such storage, transmission, and protection from disclosure shall be performed in a manner that is the same as or more protective than the manner in which NuStep stores, transmits, and protects from disclosure other confidential and sensitive information.
NuStep shall retain Biometric Data only until, and shall request that its vendors destroy such data when, the first of the following occurs:
We require all third parties to respect the security of your personal data. We do not allow our third-party service providers to use your personal information for their own purposes and they are only permitted to process your personal data in accordance with our instructions.
NuStep may disclose personal information when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be violating any agreement with NuStep, or may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other users of our site(s), or anyone else that could be harmed by such activities. We may disclose information in response to a subpoena, search warrant, in connection with judicial proceedings, or pursuant to court orders, legal process or other law enforcement measures. NuStep may disclose or access personal information when we believe in good faith that the law requires it, to establish our legal rights or to defend against legal claims, and for administrative and other purposes that we deem necessary to maintain, service and improve our Services.
We use third-party analytics such as Google Analytics to help understand your usage of our site(s) and to improve our Services.
We may disclose or use aggregated or de-identified information for any purpose. Aggregated Data may be derived from your personal information but does not directly or indirectly reveal your identity.
Like many online platforms, NuStep and its analytics vendors use server logs and automated data collection tools, such as browser cookies, pixel tags, scripts and web beacons. These tools are used for analytics purposes to enable NuStep to understand how users interact with the site(s) and Services. NuStep and its analytics vendors may tie the information gathered by these means to the identity of users.
Cookies are small text files placed on a computer or device while browsing the Internet. Cookies are used to collect, store and share bits of information about user activities. NuStep uses both session cookies and persistent cookies.
Session cookies are used to identify a particular visit to the NuStep’s site(s) and collect information about your interaction with the site(s). These cookies expire after a short time or when the user closes their web browser after using the site(s). NuStep uses these cookies to identify a user during a single browsing session, such as when you log into the site(s). This helps NuStep improve the site(s) and Services as well as improve the users’ browsing experience.
A persistent cookie will remain on a user’s device for a set period of time specified in the cookie. NuStep uses these cookies to identify and recognize a specific user over a longer period of time. They allow NuStep to:
Examples of persistent cookies include: (i) preferences cookies to remember information about a user’s browser and settings preferences, such as preferred language – preference cookies make a user’s experience more functional and customized, (ii) authentication and security cookies to enable a user to log in or stay logged in to access the site(s) and Services, to protect user accounts against fraudulent log-ins by others and to help detect and protect against abuse or unauthorized usage of user accounts and (iii) functional cookies to make the experience of using the site(s) and Services better, like remembering the sound volume level selected by the user.
NuStep uses tracking technology to: (i) determine if a certain page was visited or whether an email sent by NuStep was opened or clicked on by a user; and (ii) to customize the learning experience of individual users by recommending specific courses and other content.
We also use clear gifs in HTML-based emails sent to our users to track which emails are opened and clicked on by recipients. We may use the information we obtain from the cookie in the administration of the site(s), to improve the usability of the site(s) and for marketing purposes. We may also use that information to recognize your computer when you visit our site(s), and to personalize our site(s) for you.
Cookies and information captured through our site(s) are stored for a certain retention period, however you can eliminate these cookies any time before the expiration date.
You can adjust the settings in your browser in order to restrict or block cookies that are set by the site(s) (or any other website on the Internet). Your browser may include information on how to adjust your settings. Alternatively, you may visit www.allaboutcookies.org to obtain comprehensive general information about cookies and how to adjust the cookie settings on various browsers. This site also explains how to delete cookies from your computer.
You can control and delete these cookies through your browser settings through the following:
Or you can also use the following cookie management and disposal tool from Google Analytics by downloading and installing the browser plug-in from the following link: http://tools.google.com/dlpage/gaoptout.
Please be aware that restricting cookies may impact the functionality of the Services. Most browsers allow you to refuse to accept cookies. Additional general information about cookies, including how to be notified about the placement of new cookies and how to disable cookies, can be found at www.allaboutcookies.org.
For instance, information collected through Google Analytics is shared with Google and its partners who may combine it with other information you provided to them or they collected from your use of their services. This information is stored in Google’s servers according to their privacy practices.
We may collect information from other sources, such as social media platforms that may share information about how you interact with our social media content. We do not control how your personal information is collected, stored or used by such third-party websites or to whom it is disclosed. You should review the privacy policies and settings on any social media website that you subscribe to so that you understand the information they collect and may be sharing. If you do not want your social media websites to share information about you, you must contact that website and determine whether it gives you the opportunity to opt-out of sharing such information. NuStep is not responsible for how these third-party websites may use information collected from or about you.
We generally retain your information as long as reasonably necessary to provide you the Services or to comply with applicable law. To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal information and whether we can achieve those purposes through other means and the applicable legal requirements. We may retain copies of information about you and any transactions or Services you have used for a period of time that is consistent with applicable law, applicable statute of limitations or as we believe is reasonably necessary to comply with applicable law, regulation, legal process or governmental request, to detect or prevent fraud, to collect fees owed, to resolve disputes, to address problems with our Services, to assist with investigations, to enforce other applicable agreements or policies or to take any other actions consistent with applicable law.
In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you. This allows the specific information collected (name, email, address, phone number, etc.) to become anonymous, but allows NuStep to keep the transaction or engagement data. For example, NuStep will not be able to tell if John Smith registered for an event, but we will be able to tell that a person registered for an event and maintain headcount and transactional history. This will allow NuStep to maintain a level of information that helps us develop and improve our site(s) and Services.
You may opt-out of receiving marketing and promotional messages from NuStep, if those messages are powered by NuStep, by contacting us in writing and letting us know your specific opt-out request. If you decide to opt-out, you will still receive non-promotional communications relevant to your use of our Services.
The Children’s Online Privacy and Protection Act (COPPA) regulates online collection of information from persons under the age of 13. It is our policy to refrain from knowingly collecting or maintaining personal information relating to any person under the age of 18. If you are under the age of 18, please do not supply any personal information through the site(s). If you are under the age of 18 and have already provided personal information through the site(s), please have your parent or guardian contact us immediately using the information provided under CONTACT US so that we can remove such information from our files.
We take reasonable measures, including administrative, technical, and physical safeguards, to protect your information from loss, theft, misuse, and unauthorized access, disclosure, alteration, and destruction. Nevertheless, no online or computer environment is 100% secure, and we cannot guarantee absolute security of the transmission or storage of your information. We hold information about you both at our own premises and with the assistance of third-party service providers. Further public disclosure here of our security measures could aid those who might attempt to circumvent those security measures. If you have additional questions regarding security, please feel free to contact us directly using the information provided under CONTACT US.
California law permits residents of California to request certain details about our disclosure of your personal information by us to third-parties for direct marketing purposes during the immediate preceding calendar year. If you are a California resident and would like to request this information, please contact us using the information provided under CONTACT US.
Please contact NuStep with any questions or concerns regarding this Privacy Notice.
5111 Venture Drive
Ann Arbor, Michigan, USA 48108