Last Updated: May 10, 2019
DATA PRIVACY BEST PRACTICES IN THE UNITED STATES
DATA PRIVACY BEST PRACTICES IN THE EUROPEAN UNION (EU)
As of October 6, 2015, the European Court of Justice invalidated the Safe Harbor Framework in the decision Maximillian Schrems v. Data Protection Commissioner (Case C-362/14).
On February 2, 2016, the EU and US announced a new data transfer deal, the EU-US Privacy Shield. As ARI receives further information on compliance with this program, ARI will ensure it meets its standards. ARI retains and reiterates its commitment to Internet user privacy for users across the globe.
On May 25, 2018, the EU began enforcing GDPR. ARI takes this privacy law seriously and makes every effort to ensure it is compliance with all aspects of the law.
The following are ARI’s promises to each User:
(1) Notice. When ARI collects your personal information, we give you timely and appropriate notice describing what personal information we are collecting, how we will use it and the types of third parties with whom we may share it. This notice is located in this policy.
(2) Choice. ARI will give you choices about the ways we use and share your personal information, and we will respect the choices you make. Please recognize that ARI is a system that provides many links to third party sites and, as such, we advise and encourage them to take appropriate action with respect to their own privacy standards.
(3) Relevance. ARI will collect only as much personal information as is required to meet the specific, identified purposes as listed in this Policy, and we will not use it for other purposes without obtaining your consent.
(4) Retention. ARI will keep your personal information only as long as we need it for the purposes for which we collect it, or as permitted by law. Any individual who wishes to have their personal data removed from ARI’s databases may contact the data protector officer.
(5) Accuracy. ARI will take appropriate steps to make sure your personal information in our records is accurate, as much as is within the power of ARI.
(6) Access. ARI will provide ways for you to access your personal information as quickly as possible upon request, as required by law, so you can correct inaccuracies. Please use the address below to request access to your information.
(7) Security. ARI will take appropriate physical, technical and organizational measures to protect your personal information from loss, misuse, unauthorized access or disclosure, alteration, and destruction.
(8) Sharing. Except as described herein, ARI will not share your personal information with third parties without your consent.
(9) International Transfer. If ARI is used to transfer your personal information to another country, ARI will take appropriate measures to protect your privacy and the personal information transferred.
(10) Enforcement. ARI will regularly review how we are meeting these privacy promises, and we provide an independent way to resolve complaints about our privacy practices (see below).
(11) Data Breaches. In the event of any data breach all potentially effected individuals will be notified within 72 hours of when ARI first learns of the breach.
To access your information, ask questions about our privacy practices or issue a complaint, contact us at:
The Ayn Rand Institute
ATTN: Data Protection Officer
6 Hutton Centre Drive, Suite 600
Santa Ana, CA 92707
INFORMATION WE COLLECT
Information You Voluntarily Submit
ARI collects any personally identifiable information that you provide to us voluntarily when you respond to a request for information, register for or order educational or other products and services, set up a social network or otherwise register for a Site profile or account, or choose to use one of our learning assessments, courses or other interactive tools.
The exact nature of the information you submit may vary depending on the type of response or service requested. We will only collect information necessary to provide a requested service or respond to an inquiry. The type of information you submit may constitute personally identifiable information (PII), including, without limit, the following types of information:
- First and Last Name;
- Street Address, City, State, Country, Postal Code;
- Date of Birth;
- Native Language;
- Email Address;
- Valid Day or Evening Telephone Number;
- Cell Phone Number;
- Confirmation of the age of majority;
- Prior Education History;
- Social Networking Content; and
- Other Information after you become an ARI user, such as course records relating to your use of ARI education tools that may be required to be collected in the normal course of your studies.
No Required Information
Information We Automatically Collect
Besides information you provide us voluntarily, ARI may also collect the following information automatically every time you visit the Site:
i. Log Files
Similar to many websites, ARI gathers certain anonymous browsing information automatically and stores it in web server log files. This information includes but is not limited to the following:
- IP Addresses;
- Collection date;
- Connection speed;
- Language settings;
- Country, State, DMA and City; and
- Domain (.com, .net, .mil, .org, .edu, etc.)
ARI uses this information to improve our Site, analyze trends, administer the Site, track users’ movements around the Site and gather aggregate information about our user base as a whole.
A cookie is a small text file that is stored on a user’s computer for recordkeeping purposes. It can also help us understand how ARI Site visitors click through to our Site, and what pages they view during their visit. Similar to many websites, ARI stores an encrypted cookie on your computer so ARI can remember you when you come back to the ARI Site without requiring you to log in every time. Cookies also allow ARI to track and understand the interests of our users to enhance the overall experience on our Site.
You can set your web browser software to disable cookies, but this may render the ARI Site unusable to you. To do so, please refer to the help section of your specific browser for more information on how to manage or disable cookies.
Browsers with “Do Not Track” Instructions
The ARI Site does not respond to instructions from browsers where a Do Not Track feature has been activated. The ARI Site automatically collects log file and cookie information from all users.
ARI does not knowingly collect or solicit any information from any individual under the age of thirteen absent parental or guardian consent, nor do we direct any of our business practices or system outputs towards children under the age of thirteen.
ARI is committed to respecting the privacy of children online and ensuring that the Site is fully compliant with the Children’s Online Privacy Protection Act (COPPA). In the event that we learn we have collected personal information from a child under the age of thirteen without verification of parental or guardian consent, ARI will promptly delete any personal information associated with that child as quickly as possible. If you believe ARI has information from or about anyone under thirteen years of age, please notify ARI by email at email@example.com or write to ARI at the address provided below.
HOW INFORMATION IS USED
Standard Requested Services
We may use information collected on the ARI Site (aynrand.org), as well as any other ARI property or activity, to perform the standard services associated with the Site, including to determine your admissibility and to register you for your selected courses, to provide you with services you request, to respond to your inquiries, to provide you with courses and course support, for fostering communication and collaboration among members of the ARI community through social networks and to maintain business records for reasonable periods, to engage in marketing activities; and/or as may be required or permitted by legal, regulatory, industry self-regulatory, insurance, audit or security requirements applicable to ARI.
In addition to the ARI Site (aynrand.org), any user activity on ARI’s mobile app (Ayn Rand University) is also covered under this agreement.
In order to improve the experience for our users, ARI may offer you the ability to sign up for optional email communications, such as updates from ARI, periodic newsletters or invitations to events. These communications are enhancements to the ARI service and are entirely optional. ARI will ask for your consent before sending you promotional communications and will make it easy for you to unsubscribe from these communications.
Our Commitment to Our Contributors
We will not sell, share or trade our contributors’ names or personal information with any outside entity, nor send mailings to our donors on behalf of other organizations. In limited circumstances we may, with your permission, share your information with two organizations closely affiliated with ARI: ARI-Canada and the Anthem Foundation for Objectivist Scholarship.
This policy applies to all information received by ARI, both online and offline, on any Platform (“Platform,” includes the ARI website and mobile applications), as well as any electronic, written or oral communications.
To the extent any contributions are processed through a third-party service provider, our donors’ information will only be used for purposes necessary to process the contribution.
Identification of Authors
The ARI Site may offer opportunities for you to comment on content found on the ARI Site, engage in dialogue, share information and may allow you to submit original content. When you make a contribution to the Site you may be identified by your ARI Site account username or the name under which you choose to post.
We use marketing information to help us better plan our Site and services to meet your needs; to measure and improve our Site’s services and features; to communicate with you by email to provide you with customer support, to prevent potentially illegal activities (including illegal downloading of copyrighted materials in accordance with our Terms of Conditions and Services) and to enforce our Terms of Conditions and Services. We also use a variety of technological systems to detect and address anomalous activity and to screen content to prevent certain abuses such as spam.
Site Statistics, Internal Reporting and Analysis
ARI may use information collected from web log and cookie files to analyze and publish anonymous, non-personal, aggregate statistics that may help us to analyze how the Site and its services are being accessed and used, to improve Site performance and delivery, to analyze learning outcomes and preferences and to analyze and mitigate Site and data security risks. ARI may also track and publish anonymized aggregate information, such as the total number of users who have viewed a particular web page. ARI will publish this data in aggregate form only and will not tie it to any personally identifiable information.
HOW INFORMATION IS SHARED AND DISCLOSED
In order to better understand the impact and reach of our programs, ARI shares information about our program participants with our affiliates and select organizations or entities with which we have an established relationship. Such information is never sold. By sharing your information with ARI, you agree that we may use your information to contact you about other activities, with educational materials or opportunities, as disclosed to you at the point of collection, or in any other manner that advances our educational and charitable purposes. We may share or transfer your information with our affiliates and any other organizations or entities for similar purposes.
On Public Forums, Discussion Boards or Message Boards
Some of our features may allow you to communicate with other users by posting public messages. Please be aware that what you write in these public messages can be viewed, collected or used by anyone who visits our website. ARI is not responsible for any personally identifiable information that you submit or permit others to submit through public messages.
To Third-Party Vendors
From time to time, ARI may contract with third-party vendors to support ARI’s standard business practices and to provide you with a better experience on the Site. ARI will only disclose your personally identifiable information to those vendors who also adhere to industry-standard data privacy best practices. ARI will never sell your personally identifiable information for marketing or other purposes. ARI may also include features whereby you may log in to various third-party social media platforms (for example, Facebook, Twitter or Instagram) while on the ARI Site. Please note that anytime you are logged in to any third-party social media platform, that third-party social media platform may collect information about your browsing habits, including log files or cookie information, or may collect any information you submitted voluntarily. Information collected by third-party social media platforms while you are logged in to those platforms is subject to the privacy policies of those platforms.
Where Required by Law
ARI may disclose your personally identifiable information as required by law and where ARI believes disclosure is necessary to protect our legal rights and/or to comply with a judicial proceeding, court order or legal process served on our Site.
Acquisition or Other Transfer
If ARI is acquired, all of our assets, including user information, may be transferred to the acquiring company. At that time, your user information, including any personally identifiable information you have selected to provide, may become subject to the acquiring company’s privacy policies. In addition, in the event that ARI must liquidate our assets due to bankruptcy or other event, ARI will consider our user information, including personally identifiable information, as a unique asset subject to sale or other transfer. Before ARI transfers your information under any of these scenarios, ARI will notify you by posting a notice on our Site, and ARI will remind you of your ability to add, edit or delete your personally identifiable information from the website in advance of any such transfer.
Other than as described above, ARI does not share or disclose the information that our Site collects to any other third parties.
HOW TO ACCESS YOUR PERSONAL INFORMATION
You may contact ARI at the address listed below or email ARI at firstname.lastname@example.org at any time to receive a copy of the personally identifiable information that ARI may have collected about you for your ARI account or participation in ARI educational programs.
The Ayn Rand Institute
ATTN: Data Privacy Supervisor
6 Hutton Centre Drive, Suite 600
Santa Ana, CA 92707
For California Residents
California Civil Code Section § 1798.83 permits users of our website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact ARI using the information listed above.
HOW LONG INFORMATION IS RETAINED
HOW INFORMATION IS KEPT SECURE
ARI has implemented a variety of commercially standard encryption and security technologies and procedures to protect information, including your personal information, stored in our computer systems from unauthorized access. Please be aware that no method of transmission over the Internet, or method of electronic storage, is 100% secure, thus ARI strives to use commercially acceptable means to protect your personal information, but ARI cannot guarantee its absolute security.
ARI also maintains standard physical and electronic procedural safeguards that limit access to your personally identifiable information to our employees (or people working on our behalf and under confidentiality agreements) who, through the course of standard business activities, need to access your personally identifiable information.
YOUR CHOICES REGARDING YOUR PERSONAL INFORMATION
Sharing Information With Other Members
You are able to control what personal information about you is shared with other users and what information you choose to keep private in your use of the Site.
If you subscribe to any optional promotional communications, you will be able to unsubscribe from them through the emails we send you.
DATA ERASURE REQUEST
Anyone may request to have their user data permanently deleted, whether for a GDPR request or otherwise. We treat all requests the same way and with urgency.
You can request this by filling the RIGHT TO ERASURE REQUEST FORM and submit to email@example.com.
THIRD PARTY LINKS
This policy does not cover the privacy practices of any third parties that we do not own or control. We may provide links to other services and on occasion to other sites that may interest you. All of these sites operate independently of ARI, and they have their own privacy or security practices. ARI encourages you to review their policies before submitting any personal information to them.
A NOTE TO INTERNATIONAL USERS
While the https://aynrand .org, https://ari.aynrand.org and https://campus.aynrand.org ARI Sites are currently intended for and directed towards users in the United States, from time to time ARI may collect information from international users. ARI has implemented data privacy practices consistent with the data privacy principles outlined in the OECD Privacy Guidelines, the APEC Privacy Framework and the Federal Trade Commission’s Data Privacy Principles, and GDPR. Privacy regulations change rapidly, and ARI strives to maintain the highest data privacy practices consistent with domestic and international regulations. Users in the European Union should refer to the above Data Privacy Best Practices in the European Union section regarding ARI’s promises to each EU User.
If you want access to or wish to update any of your Personal Information or have any questions or complaints about our privacy practices, please contact us at:
The Ayn Rand Institute
ATTN: Data Privacy Supervisor
6 Hutton Centre Drive, Suite 600
Santa Ana, CA 92707