LEARFIELD Privacy Policy

LEARFIELD Privacy Policy – Your Privacy Rights

Effective Date: May 1, 2022
Last Updated: January 1, 2023

This Privacy Policy (“Policy”) describes how LEARFIELD, (“Learfield,” “we,” or “us”) treats personal information we collect about you through our websites and platforms where the Policy is located (the “Platform”). Please note that this Policy does not apply to personal information collected directly by the organizations to which we provide our products and services, including colleges and universities. If you have questions about the privacy practices of those organizations, please contact them directly.

This Platform is operated in the United States and intended for use by individuals who are located in the United States and Canada. By using our Platform or by choosing to give us personal information, you signify your consent to this Privacy Policy. If you do not agree with any terms of this Privacy Policy, please do not use the Platform, and do not give us any personal information.

If you are a resident of California, click here to view our California Privacy Notice.

This Policy contains the following sections:

Types of Personal Information We Collect

Identifying Information. For example, we may collect your name, business or personal address, unique personal identifiers, online identifiers, telephone number, and email address. We may also collect your mobile phone number.
Account Information. If you create an account on our Platform, we may collect your account log-in and password.
Social Media Information. We may collect personal information you post on our social media pages. We may also collect your social media profile information and personal information posted on your page.
Billing Information. For example, this may include your billing address and your preferred method of payment. Through our service providers, we may also collect your credit or debit card information.
Employment Information. For example, this may include the name and address of your employer and your job title. If you apply for a job with us, we may also collect the personal information you include in your application and your employment history. We may also collect information about your education history.
School Information. If you are a student, we may collect the name of your school, class year, and whether you play a sport. If you are a booster or fan, we may collect information about your alma mater and year of graduation.
Commercial Information. We may collect personal information that could identify you and relates to the services in which you are interested or have considered. We may also collect personal information about your consuming history or tendencies.
Information You Post or Submit. We may collect personal information you post in a public space on our Platform. We may collect personal information that you submit when you contact our customer service team or your account representative. We may also collect information when you enter a promotion or complete a survey.
Demographic Information. We may collect demographic information, such as your birthdate, age, and zip/postal code. We may also collect your race and gender.
Device Information. For example, we may collect the type of device you use to access our Platform. We may also collect your browser information, device identifier, IP address, or operating system type.
Location Information. For example, we may collect information about the city or state where you are located. We may also collect geographic information based on your IP address.
Usage Information. For example, we may collect information about how you use our products or services. This includes collecting information about your interactions with the Platform.
Internet Information. If you use our website, we may collect information about the browser you are using or your browsing or search history. We might look at what site you came from, or what site you visit when you leave us. We may also collect information about how you interact with an advertisement.

How We Collect Your Personal Information

Directly From You. For example, when you:
- Register for an account.
- Request information about our services.
- Sign up to receive promotional communications or a newsletter.
- Complete a survey.
- Participate in one of our promotional sweepstakes, contests, surveys, or focus groups.
- Make a purchase through our Platform.
- Submit information to, or through, our Platform.
- Submit a request to, or engage with, our customer service team.
- Interact with our social media pages.
- Apply for a job through our platform.
- Otherwise interact with us.

Passively. For example, when you:
- Visit and navigate our platforms on any device.
- Enable location-based features on our platforms.
We may also collect personal information about users over time and across different websites and devices when you use the Platform. Third parties also collect personal information this way on our platforms.

From Third Parties. We may receive personal information about you from other sources. For example, this may include receiving personal information from:
- Our business partners, including online advertising networks, analytics vendors, and third parties that promote our products via their own platforms.
- Social media sites or job posting sites, including Facebook, Twitter, Snapchat, TikTok, LinkedIn, Pinterest, Glassdoor, YouTube, and Instagram.

Combining Information. For example, we may:
- Combine personal information that we collect offline with personal information we collect through our Platform.
- Combine personal information we collect about you from the different devices you use to access our Platform.
- Combine personal information we get from third parties with information we already have about you.

How We Use Your Personal Information

Examples of how we may use your personal information include:

To Provide Our Products and Services. This could include fulfilling your requests for products and services.
To Improve Our Products and Services. We may use your personal information to make our Platform, products, and services better. We may also use your personal information to customize your experience with us.
To Understand Your Interests. For example, we may use your personal information to better understand what interests you.
To Respond to Your Requests or Questions. This may include responding to your feedback or notifying you if you win a promotion.
To Communicate with You. We may communicate with you about your account or our relationship. We may also contact you about this Policy or our Platform terms and conditions.
To Determine Your Eligibility. We may use your personal information to verify your identity or determine your eligibility for some of our services or promotions. For example, this may include verifying your age, date of birth, and state of residence. If you apply for a job through our Platform, we may use this personal information to evaluate your application.
For Marketing Purposes. We may provide you with information about new products and special offers. We might use your personal information to serve you ads about our offers. We might tell you about new features or updates. These might be third-party offers or products we think you might find interesting. We may also use your personal information to send you electronic communications, including through email or text message. We and our partners may engage in interest-based advertising using information gathered across multiple websites, devices, or other platforms. For more information about your choices related to these communications, see the Choices Regarding Your Information section below.
For Security Purposes. This could include protecting our company and consumers who use our services. It may also include protecting our Platform or investigating a potential fraud.
To Create De-Identified Information. We may anonymize, aggregate, strip, or otherwise de-identify personal information of identifying characteristics and may use or share that data with third parties for any purpose we deem appropriate.
As Otherwise Permitted or Required By Law or As We May Notify You. This includes using your information for our legitimate business needs.
Location Information. For example, we may collect information about the city or state where you are located. We may also collect geographic information based on your IP address.
As Requested Or Directed By You.

How We Share Your Personal Information

We may share your personal information in the following ways:

Internally. We may share your personal information with our affiliates and subsidiaries for the purposes described in this Policy. This may include sharing information with other entities within the Learfield family of companies.
On Our Platform. For example, we may publicly display personal information you post on our social media sites or submit through our customer reviews feature. We may also display information you submit in connection with a promotion.
With Our Service Providers. We may share your personal information with third parties who perform services on our behalf. For example, this may include merchandise vendors. It may also include companies that send emails on our behalf or help us run our Platform.
With Our Business Partners. For example, we may also share personal information with social media sites, advertisers, media buying agencies, advertising networks, and advertising service providers for the purposes described in this Policy. We may also share personal information with companies that help us learn more about our customers.
With Third Parties for Marketing Purposes. This may include third parties in whose products or services we believe you may be interested. These third parties may also share your personal information with others. These third parties may use your personal information for their own marketing purposes or the marketing purposes of others. This may include the delivery of interest-based advertising.
With Any Successors to All or Part of Our Business or One of Our Brands. For example, this may occur if Learfield merges with, is acquired by, or sells a brand or part of its business to another business entity. This may include an asset sale, corporate reorganization or other change of control. We may sell or transfer our customer personal information as an asset or as part of a larger transaction action.
To Comply with the Law or To Protect Ourselves. For example, this could include responding to a court order or subpoena. It could also include sharing personal information if a government agency or investigatory body requests. We might share personal information when we are investigating a potential fraud. This could include fraud we think has occurred during a sweepstakes or promotion. We may also share information if you are the winner of a sweepstakes or other contest with anyone who requests a winner’s list.
For Security Purposes. This could include protecting our company and consumers who use our services. It may also include protecting our Platform or investigating a potential fraud.
As Requested Or Directed By You. This may include instances where you ask us to share your personal information with a third party, including a university or a marketing vendor.
For Other Reasons We May Describe to You at the Time of Collection.

California Privacy Notice

The California Consumer Privacy Act (“CCPA”) requires us to make specific disclosures about how we collect, use, and share the personal information of California residents who are subject to CCPA. CCPA also grants such California residents certain rights related to their personal information. This section describes our personal information practices offline and online, and contains these required disclosures and instructions for California residents who wish to exercise their rights under CCPA.

Please note that, to the extent permitted under CCPA, this section does not apply to the personal information of California residents that we collect:

From our workforce members for employment-related purposes
In the course of certain business-to-business transactions
For or on behalf of our business customers, including colleges and universities, in connection with our provision of our products and services to those customers. If you have questions about the privacy practices of our customers or wish to exercise your privacy rights with respect to the personal information that we collect on their behalf, please contact them directly.

We are required under CCPA to tell you which categories of “personal information” we collect, and which of these categories we disclose for “business purposes” or for “sale” purposes as these terms are defined under CCPA.

In the past 12 months, we have collected the following categories of personal information from California residents: identifiers; categories of personal information described in subdivision (e) of Section 1798.80, including physical characteristics or description; commercial information; internet or other electronic network activity information; audio, electronic and visual information; geolocation information; professional or employment-related information; education information; and inferences drawn from the categories in this paragraph.
In the past 12 months, we may have engaged in the “sale” (as this term is defined in CCPA) of the following categories of “personal information” from California residents to third parties: identifiers; categories of personal information described in subdivision (e) of Section 1798.80, including physical characteristics or description; commercial information; internet or other electronic network activity information; audio, electronic and visual information; geolocation information; professional or employment-related information; education information; and inferences drawn from the categories in this paragraph. If you would like to limit the cookies and other tracking tools used our on Platform, please visit our About Our Ads policy.
We may disclose any of the above categories of personal information for “business purposes” as this term is defined in CCPA.
We may collect personal information as described in the “HOW WE COLLECT YOUR PERSONAL INFORMATION” section of this Policy
• We may use personal information we collect for “business purposes” and “commercial purposes” as these terms are defined in CCPA. These purposes are as described in the “HOW WE USE YOUR PERSONAL INFORMATION” section of this Policy. .
• We may share personal information we collect with third parties as described in the “HOW WE SHARE YOUR PERSONAL INFORMATION” section of this Policy.

California resident rights under CCPA. Subject to certain exclusions included in CCPA, and as relevant to our operations, California residents have the rights listed below. We may take steps to verify your identity, as permitted or required under CCPA, before we process your request. Verification may include asking you to provide information about yourself that we can match against information already in our possession.

Notice. This means that you can request that we disclose the categories of personal information we have collected about you; the categories of sources from which such personal information is collected; the categories of personal information we have “sold” or disclosed for a business purpose; the categories of third parties to whom the personal information was “sold” or disclosed for a business purpose; and the specific pieces of personal information we have collected about you in the last 12 months.
Deletion. This means that you can request that we delete personal information about you which we have collected from you.
Opt-Out. CCPA provides a right to opt-out of the “sale” of personal information as that term is defined in CCPA. If you would like to opt out of allowing Learfield to “sell” your personal information, please follow the instructions below. In addition, if you would like to limit the cookies and other tracking tools used our on Platform, please visit our About Our Ads policy. As stated in that policy, certain choices you make may be browser and device specific.
Equal prices and services. This means that we are prohibited from discriminating against you if you exercise your rights under CCPA.

Agents that you have authorized to act on your behalf may also submit CCPA requests as instructed below. The agent must also provide evidence that they have your written permission to submit a request on your behalf. If we are unable to verify the authenticity of a request, we may ask you for more information or may deny the request.

California residents who wish to exercise their rights under this section can contact us at privacy@LearfieldIMGCollege.com. Please include your name, email address and indicate you are a California resident making a “CCPA” request. Please also identify the relevant Learfield entity or entities to which your request relates.

Additional Information about your California Rights. If you reside in California, you have the right to ask us one time each year if we have shared personal information with third parties for their direct marketing purposes. To make a request, please send us an email at privacy@LearfieldIMGCollege.com or write to us at the address listed below. Indicate in your email or letter that you are a California resident making a “California Shine the Light” inquiry. Please also identify the relevant Learfield entity or entities to which your request relates. Note that this section does not apply to personal information that we collect for or on behalf of our business customers, including colleges and universities, in connection with our provision of our products and services to those customers. If you have questions about the privacy practices of our customers or wish to exercise your privacy rights with respect to the personal information that we collect on their behalf, including colleges and universities, please contact them directly.

Children Under 18

The Platform where this Policy is located is meant for adults. We do not knowingly collect personally identifiable data from persons under the age of 18, and strive to comply with the provisions of COPPA (the Children’s Online Privacy Protection Act). If you are a parent or legal guardian and think your child under 18 has provided us with personal information, please contact us at privacy@LearfieldIMGCollege.com. You can also write to us at the address listed at the end of this Policy. Please mark your inquiries “COPPA Information Request.” Parents, you can learn more about how to protect children’s privacy on-line here.

Choices Regarding Your Information

You have certain choices about how we use your personal information. Certain choices you make are browser and device specific.

Marketing Communications:
You can opt out of receiving our marketing communications. Note that you may still receive transactional messages from us, including information about your account and responses to your inquiries. To opt out of receiving our marketing communications, you can follow the instructions contained in the communication.

Cookies & Other Tracking Technologies:
For information about our use of cookies and other tracking technologies and to read our “Do Not Track” policy, please review our About Our Ads policy.

Virginia Privacy Rights: If you are a Virginia resident, you may have the right under the Virginia Consumer Data Protection Act (“VCDPA”) to request that we:

Confirm whether or not we are processing your personal information and provide access to such personal information.
Correct inaccuracies in your personal information, taking into account the nature of the personal information and the purposes of the processing of your personal information.
Delete personal information provided to us by or obtained by us about you.
Provide you with a copy of your personal information that you previously provided to us in a portable and, to the extent technically feasible, readily usable format.
Provide a method for you to opt-out of the processing of your personal information for purposes of online behavioral advertising, the sale of your personal information, as the term “sale” is defined under the VCDPA, or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you. Please note that if you would like to limit the cookies and other tracking tools used our on Platform, please follow the instructions in our About Our Ads

Nevada Privacy Rights: If you are a Nevada resident, under Privacy and Security of Personal Information Chapter of the Nevada Revised Statutes Section 603A (“603A”), you have the right to submit a verified request to us, directing us not to make any sale of certain “personal information” as defined under this law that we have collected or will collect about you.

If you wish to exercise your Virginia or Nevada rights under this section, you can contact us at privacy@LearfieldIMGCollege.com. Please include your name, email address, state of residence and the Learfield entity or entities to which your request relates. Please indicate you are making a “Privacy Rights” request. We will make commercially reasonable efforts to authenticate any requests that you submit. If we deny your privacy request and you wish to appeal our decision, you may contact us at privacy@LearfieldIMGCollege.com. Note that this section does not apply to personal information that we collect for or on behalf of our business customers, including colleges and universities, in connection with our provision of our products and services to those customers. If you have questions about the privacy practices of our customers or wish to exercise your privacy rights with respect to the personal information that we collect on their behalf, including colleges and universities, please contact them directly.

EU Privacy Rights
If you are an EU resident, you may be able to assert a legal right regarding our collection and use of your personal information under applicable federal, state, and international law. Under these applicable laws, you may have a number of rights, including:

The right not to provide your personal information to us;
The right to object, stop, or limit the processing of your personal information;
The right to request the erasure or restriction of processing of your personal information in our possession;
The right to have your information transferred to another data controller;
The right to withdraw your consent;
The right to access to your information and request from us a description, or a copy, of the types of personal information we have stored about you; and
The right to request update or rectification of your personal information.

To exercise any of these rights, or to request more information, contact us at privacy@LearfieldIMGCollege.com or through the contact information listed at the bottom of this Policy.

Canadian Resident Rights – Accessing and Correcting Your Information
If you are a resident of Canada, you have a right to request access to your personal information and to request a correction to it if you believe it is inaccurate. If you would like to have access to the personal information we have about you, or if you would like to have it corrected, please contact us using the contact information provided below. In some cases, we may not be able to allow you to access certain personal information in certain circumstances, for example if it contains personal information of other persons, or for legal reasons. To help protect against fraudulent requests for access to your personal information, we may ask you for information to allow us to confirm that the person making the request is you or is authorized to access your information before granting access. For example, we may require you to verify your identity before you access your personal information.

Security

The Internet is not 100% secure. We cannot promise that your use of our Platform will be completely safe. We encourage you to use caution when using the Internet. We use physical, technical, and organizational means to help safeguard personal information under our control. A username and password are needed to access certain areas of the Platform. It is your responsibility to protect your username and password. Personal Information may be accessed by persons within our organization, or our third-party service providers, who require such access to carry out the purposes described in this Policy, or otherwise permitted or required by applicable law. Personal Information we collect is managed from our offices in the United States.

Storage of Personal Information

Personal Information we maintain may be stored in or outside of the United States. If you live outside of the United States, you understand and agree that we may transfer your personal information to the United States. This Platform is intended for use in the United States and is subject to the laws of the United States, which may not provide the same level of protections as those in your own country. Personal Information processed and stored in another country, including the United States, may be subject to disclosure or access requests by the governments, courts or law enforcement, or regulatory agencies in that country according to its laws.

By using our Platform or by providing us with personal information, you consent to any such transfer of information outside of your country.

Links

Our Platform may contain links to other third-party sites that are not governed by this Policy. This includes third-party sites that offer resources and content which you can access through our Platform. If you click on a link to a third-party site, you will be taken to a site we do not control. We are not responsible for the privacy practices used by third-party sites. We suggest that you read the privacy policies of those sites carefully.

How To Contact Us

If you have any questions, comments or concerns with respect to our privacy practices or this Policy, or wish to update your information, please feel free to contact us at privacy@LearfieldIMGCollege.com. You may also write to us at the following address:

Learfield
2400 Dallas Parkway, Suite 500,
Plano TX 75093

Changes In Policy

From time to time, we may change this Privacy Policy. We will notify you of any material changes to this Policy as required by law. We will also post an updated copy on our Platform. Please check our Platform periodically for updates. Your continued access to and/or use of our Platform after any such changes constitutes your acceptance of, and agreement to this Privacy Policy, as revised.