Emeritus and its partners, including its University partners (collectively “Emeritus”, “we” or “us”) collect personal data and other data from the Site.

Personal Data we collect

The Personal Data we collect may include:

1. your name
2. your e-mail address
3. your identification number
4. your contact particulars
5. your image
6. your country of residence
7. your residential address
8. your educational details
9. your date of birth

Any other data you provide to us

Any other data our University partners or referral partners provide to us

Information we collect apart from your Personal Data may include the following:

1. Cookies and Usage Data

How we use your Personal Data

We collect, use and disclose your Personal Data for the following purposes in connection with the products or services for which you have applied, to the extent applicable:

1. General administration of your application and/or registration and/or enquiry for any programme offered by us or our University partners;
2. To perform or carry out EMERITUS’ obligations arising from any contracts entered into between you and us;
3. To enable EMERITUS’ subcontractors, third-party agents and service providers to fulfill obligations/services as stipulated in your contract with EMERITUS;
4. To administer and update your records in our databases, and monitoring and maintaining a record of previous transactions;
5. Improvement of our offerings, both individually (e.g., by course staff when working with a student) and in aggregate, and to individualize the experience and to evaluate the access and use of the Site;
6. The purpose for which you specifically provided the information, for example, to respond to a specific inquiry or provide you with access to the specific course content and/or services you select;
7. Tracking of both individual and aggregate attendance, progress and completion of a course, and analysis of statistics on student performance and the manner in which students learn;
8. Monitoring and detection of violations as well as other misuses and potential misuses of the Site;
9. Sending you updates about courses offered by EMERITUS or other events, sending you communications about products or services of EMERITUS, EMERITUS affiliates, or selected business partners that may be of interest to you, or sending you email messages about Site maintenance or updates;
10. Authentication of your identity when needed;
11. Process of refunds, as applicable;
12. Conducting checks with the DO NOT CALL Registry;
13. Compliance with internal policies and procedures and any applicable laws, rules, regulations, codes of practice or guidelines, orders or requests issued by any court, legal or regulatory bodies (including but not limited to disclosures to regulatory bodies, conducting audit checks, surveillance and investigation and US embargo laws or any regulations or laws promulgated by the United Nations);
14. Conduct of direct marketing; we may process your Personal Data to contact you via email, telephone, direct mail, SMS or other methods of communication to provide you with information regarding the products or services that may be of interest to you. We may send information to you regarding the products or services, upcoming promotions and other information that may be of interest to you, using the contact details that you have provided to us and always in compliance with applicable law.
15. To facilitate data analysis and business planning purposes, marketing, advertising, and sales efforts;
16. To improve the Site, our products and services;
17. For training purposes;
18. For government, audit and other regulatory purposes, including but not limited to, EMERITUS re-certification and accreditation purposes;
19. For internal reporting and/or accounting purposes;
20. The Purposes described elsewhere in this Policy (for example in the section entitled “Use and Disclosure to Third Parties”); and
21. Any other purpose as disclosed to you at the point of collection or pursuant to your consent.

We may also contact you by any means of communication for which EMERITUS has been given contact details, including but not limited to via email, telephone numbers, and post, for the purpose of getting your feedback or for providing you with information which we believe could be of interest to you or your organisation.

By your submission of your personal data to us, our University partners, or referral partners, you consent to the onward disclosure of your Personal Data to these service providers (as set out in “How we use your personal data”) and the processing of your Personal Data by these service providers.

By providing us, our University partners, or referral partners your Personal Data regardless of the manner in which you have provided such Personal Data, you represent and warrant to us that consent, including that of the third party, has been obtained for collection, use and disclosure of the Personal Data for the above mentioned purposes. Because we are collecting the third party’s data from you, you undertake to make the third party aware of all matters listed in this Policy.

EMERITUS ensures that the Personal Data held by us shall be kept confidential. When transferring Personal Data to our third-party service providers, and/or our affiliates or related corporations whether in Singapore or elsewhere in order to carry out one or more of the purposes listed above, we will require them to ensure that Personal Data disclosed to them is kept confidential and secure.

You consent to the collection, use and disclosure of your Personal Data for the above mentioned purposes and agree to be bound by the obligations it imposes on you, when you accept this Policy. You accept this Policy when you continue to browse on EMERITUS’ website or continue to engage with EMERITUS.

In this regard, please note that it is your responsibility and obligation to ensure that all Personal Data submitted to us, our University partners, and/or referral partners is complete, accurate, true and correct at the time of submission. Failure on your part to do so may result in our inability to provide you with products and services you have requested.

Please note that if you do not consent to any of the above business purposes, EMERITUS may also be unable to meet the purposes for which the information was collected.

We employ other companies and individuals to perform functions on our behalf. They will require access to the Personal Data needed to perform their functions for EMERITUS, but may not use it for other purposes. We will share Personal Data we collect with the following third parties or purposes:

1. With service providers or contractors that perform certain functions on our Site, including managing our learning management system, hosting our videos and course ware, processing information that is provided to us, processing purchases via third party providers, and other transactions through the Site, operating the Site or portions of it, providing or administering courses, or in connection with other aspects of EMERITUS services;
2. With other visitors to the Site, course platform or our mobile learning app, to the extent that you submit comments, course work, or other information or content (collectively, “Postings”) to a portion of the Site, course platform or mobile learning app designed for public communications; and with other members of an EMERITUS class of which you are a member, to the extent you submit Postings to a portion of the Site, course platform or mobile learning app designed for viewing by those class members. We may provide your Postings to students who later enroll in the same classes as you, within the context of the forums, the courseware, or otherwise. If we do re-post your Postings originally made to non-public portions of the Site, course platform or mobile learning application or learning management system we will post them without your real name and e-mail (except with your express permission), but we may use your username without your consent.
3. To provide opportunities for you to communicate with other users of the Site who may have similar interests or educational goals. For instance, we may recommend specific study groups or connect potential student and coaches. In such cases, we may use all information collected about you to determine who might be interested in communicating with you.
4. To third parties whose practices are not covered by this Policy (e.g., third party providers of goods and services, marketing and advertising companies and agencies, content publishers and retailers);
5. We may also share Personal Data about you with the University collaborating on a course for which you are enrolled, and this University may use your Personal Data in accordance with their own privacy policies.
6. To respond to subpoenas, court orders, or other legal process; to investigate, or prevent, or take action regarding illegal activities, suspected fraud, or security or technical issues, or to enforce our terms and conditions, or this Policy; as otherwise may be required by applicable law; or to protect our rights, property, or safety or those of others;
7. For government, audit and other regulatory purposes, including but not limited to, EMERITUS re-certification and accreditation purposes;
8. With affiliates of EMERITUS or with successors in the event of a merger, acquisition or reorganization, for their use consistent with this Policy;
9. As otherwise described to you at the point of collection of Personal Data or pursuant to your consent; and
10. For integration with third party services.

In addition, we may share aggregated information that does not personally identify you with the public and with third parties, including but not limited to researchers and business partners.

Please keep in mind that whenever you voluntarily disclose Personal Data online – for example on message boards, through e-mails, or in chat areas – that information can be collected and used by others. By posting Personal Data online that is publicly accessible, you may receive unsolicited messages from other parties in return.

The Site contains links to websites published by third parties, including other content providers as well as certain service providers, such as those who process payments on behalf of EMERITUS. Some of these third-party websites may have our logo or trademark acknowledged on their website. These other websites are not under our control, and you acknowledge and agree that we are not responsible for the collection and use of your information by such websites, unless we have otherwise indicated in this Policy. We encourage you to be aware when you are be redirected to a third-party website and review the privacy policies of each website you visit and use.

The Personal Data that we hold about you may be stored on servers hosted in Singapore, Japan, US, China, India and on several cloud servers used by our service providers and vendors. EMERITUS implements a variety of security measures to maintain the safety of your submitted information. All electronic storage and transmission of Personal Data is secured and stored on managed servers with controlled access and appropriate security technologies.

We have implemented appropriate technical and organizational security measures designed to protect your Personal Data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, unauthorized access, and other unlawful or unauthorized forms of processing, in accordance with applicable law. In certain instances we may use Secure Sockets Layer encryption and/or transfer certain Personal Data in a non-human readable format to provide protection.

Although every reasonable effort has been made to ensure that all Personal Data will be so protected, EMERITUS cannot be responsible for any unauthorised use or misuse of such information and from risks which are inherent in all internet communications. We cannot guarantee there will not be a breach, and we are not responsible for any breach of security or for the actions of any third parties.

Your Personal Data will only be disclosed for the express purpose of delivering the product or service requested and shall not be sold or disclosed to any other company for any other reason whatsoever without your consent.

We take every reasonable step to ensure that Personal Data that we process is accurate and, where necessary, kept up to date, and any of your user information that we process that you inform us is inaccurate (having regard to the purposes for which they are processed) is erased or rectified.

Please contact us via privacy@emeritus.org should you wish to have access to or seek to update, correct or withdraw the consent to collect and use your Personal Data. Your email should identify yourself and state which Personal Data and information about its use and/or disclosure is requested.

We will retain Personal Data only for as long as is necessary for the purposes set out in this Policy. In addition, we will retain and use Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain certain data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies. You have full rights to stop processing and/or remove of your data by emailing us at privacy@emeritus.org (by stating “Retention of Data” as the subject matter of the enquiry in the subject matter line.)

You are also entitled to learn about the legal basis of data transfers to a country outside Singapore or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by us and our third-party applications to safeguard Personal Data.

If any such transfer takes place, you can find out more by checking the relevant sections of this document or enquire by writing to us at privacy@emeritus.org (by stating “Data Transfer” as the subject matter of the enquiry in the subject line).

EMERITUS will not transfer Personal Data within or outside Singapore unless it is ensured that the Personal Data will be accorded a level of protection which is comparable to the protection under the PDPA.

Your Newsletter and Email Subscriptions.
You can opt out or unsubscribe to a newsletter or other email list at any time by following the instructions at the end of the newsletters or emails you receive. Please allow five to ten business days for changes to take effect. For some services, member service-related communications are an integral part of such services to which you subscribe and you may continue to receive emails as part of that particular portion of the services unless you cancel your account, even if you opt out of the newsletters or email list. If you have provided more than one email address to us, you may continue to be contacted unless you request to unsubscribe each email address you have provided.

Telephone Communications.
Our telephone communications with you may be recorded in accordance with this Policy. By choosing to continue any telephone conversation, you acknowledge and agree to the terms of this Policy. If you do not agree, terminate the telephone conversation immediately and avoid any further telephone communications with EMERITUS.

Cookies and Pixel Tags.
You may stop or restrict cookies and pixel tags on your computer or purge cookies from your browser by adjusting your web browser preferences. However, if you “turn off,” purge, or disable cookies or pixel tags, although you may still use the services, you may not be able to use all of the features, functions, or services available on the Site. We have also provided another measure of disabling the cookies, you will see a pop up on our website that can enable you to control the cookies tracking.

EU Residents.
GDPR provides certain rights for EU residents. You may decline to share certain information with us, in which case we may not be able to provide some of the features and functionality of the Site or the Services. These rights include, in accordance with applicable law, the right to object to or request the restriction of processing of your information, and to request access to, rectification, erasure and portability of your own information. Where we process your information on the basis of your consent, you have the right to withdraw that consent (noting that such withdrawal does not affect the lawfulness of any processing performed prior to the date on which we receive notice of such withdrawal, and does not prevent the processing of Personal Data in reliance upon any other available legal bases). Requests should be submitted by contacting us by writing to privacy@emeritus.org (and you must state “Privacy Policy” as the subject matter of the enquiry in the subject line). If you are an EU resident and have any unresolved privacy concern that we have not addressed satisfactorily after contacting us, you have the right to contact the appropriate EU Supervisory Authority and lodge a complaint.

General Data Protection Regulation (GDPR).
Pursuant to Article 27 of Europe’s General Data Protection Regulation (GDPR), Emeritus Institute of Management Pte Ltd, has appointed European Data Protection Office (EDPO) as its GDPR representative in the EU. EU residents can contact EDPO regarding matters pertaining to the GDPR by sending an email to privacy@edpo.brussels, using EDPO’s online request form, or writing to EDPO at Avenue Huart Hamoir 71, 1030 Brussels, Belgium.

This Privacy Policy Addendum supplements the Privacy Policy at emeritus.org and describes additional rights of residents of the State of California under the California Consumer Privacy Act of 2018, as amended (the “CCPA”).

California residents are entitled once a year, free of charge, to request and obtain certain information regarding our disclosure, if any, of certain categories of Personal Information (as defined under CCPA) to third parties for their direct marketing purposes in the preceding calendar year.

Notice to California Residents

This section describes how we handle the Personal Information of California residents (as defined in Section 17014 of Title 18 of the California Code of Regulations), and the rights they have under the CCPA”) to the extent that (1) we collect and process such information in the context of providing services and selling goods (hereinafter, Customer Related Personal Information); and (2) the obligations imposed by the California Consumer Privacy Act of 2018 (“CCPA”) apply to such data. This section also notifies California residents of our collection practices regarding such Personal Information and describes your rights under the CCPA.

Capitalized terms not defined in this section shall be as defined in CCPA or in the Privacy Policy, as applicable.

Notice at Collection

We collect the following categories of Customer Related Personal Information from you:

1. Identifiers: We collect identifiers such as real name, alias, postal address, unique personal identifiers, online identifier, Internet Protocol address (see “internet activity” below), email address, and account name.
2. Internet /electronic network activity: When you browse our sites or otherwise interact with us online, we may collect browsing history, search history, and other information regarding your interaction with our sites, application or advertisements.
3. Customer Records: We collect Personal Information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) such as name, signature, description, address, telephone number, bank account number, or other financial information. Some Personal Information included in this category may overlap with other categories.
4. Characteristics of protected classifications under California or federal law: In some circumstances, we may collect information that is considered protected under California or federal law such as age but only when that information is relevant for our business purposes. We abide by the legal requirements imposed under applicable law regarding such information.
5. Sensory data: In some circumstances, we collect audio information (e.g., records of calls made through our systems when call recording is activated), electronic and visual information (e.g. recordings from security cameras), or similar information.
6. Geolocation data: If you interact with us online, we may gain access to the approximate location of the device or equipment you are using. If you visit our facilities, we may keep record of the fact that you visited, the location visited, and the day/time.
7. Biometrical data: We do not independently collect biometric data such as DNA data, fingerprints, voice prints, retina scans, or face scans; however, we may collect data from which biometric data could be derived (such as voice recordings and pictures.)
8. Commercial Information: We collect commercial information, such as records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
9. Professional or employment related data: Because we collect and handle information related to our services, we may collect from you professional or employment information such as company name, designation, work experience, etc.
10. Inferences: We may draw inferences from other information we collect about you. For example, if you use our services, we may create a client profile reflecting our understanding of your personal preferences.

We use the Customer Related Personal Information collected for operational purposes or other business purposes as described in this Privacy Policy. Examples of how we may use Customer Related Personal Information include:

• For our internal efforts to operate and improve our business.
• For advertising and marketing purposes relating to our services and programs, including marketing on social media sites.
• For our general administrative purposes.
• For social-media engagement.
• For security purposes, as necessary to help us protect against, identify, or investigate fraud or other criminal activity.
• For other legal purposes, if we have a legal obligation, or need to pursue or defend against legal claims, for which we need to process your information.
• For communication purposes, to get in touch with you in connection with any of the reasons listed above.

We share Personal Information in the context of marketing and advertising in ways that may be considered selling under CCPA. You can opt-out out of the sharing as described in the California Rights section below. However, we do not authorize third parties to use your Personal Information for their own purposes unless you direct us to do so.

Collection and sharing practices in the last twelve (12) months

In the last twelve (12) months we have collected Customer Related Personal Information for all categories outlined in the Notice at Collection section above.

We collected such information from the sources described in our Privacy Notice. For example, we have collected Customer Related Personal Information:

• Directly from our customers (for example, information provided through the Site or other communications with us).
• From our business partners with whom you have consented to the sharing of your information.
• From consumers’ activity on the Site (for example, Site visit information collected directly or through third-party analytics providers).
• From a device’s GPS, Wi-Fi, Bluetooth, or IP address.
• From consumers’ activities on social media.
• From our interaction through social media.

We have shared Customer Related Personal Information for our operational purposes or other business purposes as described in our Privacy Notice. We also share Personal Information in the context of marketing and advertising in ways that may be considered selling or sharing under CCPA. The types of entities with which we have shared Customer Related Personal information include:

• Service providers
• Other members of our corporate group
• Governmental entities (where we are under a duty to disclose or as required to protect our rights or the rights of others).
• Business Partners and other third parties as necessary to provide services to our customers

Your rights under California law

If you are a California resident, you have the following rights under CCPA:

• Right to know/access information: You have the right to request that we disclose to you: (1) the specific pieces of Personal Information we have collected about you over the past 12 months; (2) the categories of Personal Information collected or shared over the past 12 months; (3) the purposes for which we collected or shared such Personal Information; (4) the categories of third parties to whom we have disclosed such Personal Information.
• Right to delete: You have the right to request in certain circumstances deletion of the Personal Information that we have received about you. As a general rule, we must delete the Personal Information at your request and require our vendors to do so as well. However, the law provides certain exceptions that allow us to retain the information even if you have requested that it be deleted. If we do not erase the information pursuant to one of those exceptions, we must inform you of that fact and of any rights you may have to appeal our decision.
• Right to Opt Out of Sale of Personal Information to Third Parties. You have the right to opt out of any sale of your Personal Information by Emeritus to Third Parties. We do not sell information to third parties.
• Right to Information Regarding Participation in Data Sharing for Financial Incentives. You have the right to be free from discrimination based on your exercise of your CCPA rights. We do not discriminate against anyone who chooses to exercise their CCPA rights.

California law also provides that California residents are entitled to know how we respond to “Do Not Track” settings. Like many other websites and online services, we do not currently alter our practices when we receive a “Do Not Track” signal.

How to exercise your Rights

You can make requests related to your California privacy rights by completing our Enquiry Form.

You may also make those requests by writing to us at privacy@emeritus.org

Please be aware that we do not accept or process requests through other means (e.g., via fax, chats, social media etc.).

When you make a request, we may ask you to provide verifying information, such as your name, email, or phone number. We will review the information provided and may request additional information via email or other means to ensure we are interacting with the correct individual. Please also be aware that making any such request does not ensure complete or comprehensive removal or deletion of personal information or content you may have posted, and there may be circumstances in which the law does not require or allow us to fulfill your request.

If we suspect fraudulent or malicious activity on or from the password-protected account, we may decline a request or request that you provide further verifying information.

You may only make a verifiable consumer request twice within a 12-month period. Making a verifiable consumer request does not require you to create an account with us.  We will only use Personal Information provided in a verifiable consumer request to verify your identity or authority to make the request.

Please note that we review and may make changes to this Policy from time to time. When changes are made, the Policy link will include a notation “Revised (date).” indicating that you should review the new terms, which will be effective immediately upon posting on this page, with an updated effective date. The notation will be included in this Policy link for at least seven (7) days after the update has been made. By accessing the Site after any changes have been made, you signify your agreement on a prospective basis to the modified Policy and any changes contained therein. In case you miss the notification referenced above, be sure to return to this page periodically to ensure familiarity with the most current version of this Policy.