Newlane affirms that it protects student data, including student educational and administrative records and student “Personally identifiable information” (“PII”) by design. Newlane University is committed to protecting your privacy in accordance with this privacy policy, which applies to the Newlane University website, the Newlane University application or platform (i.e., the Newlane University learning management system and mastery-verification system), its related websites, and content therein (collectively: “Website”) as well as the services available through this Website (“Services”), and governs collection of personally identifiable information through the website.

PLEASE READ THIS PRIVACY POLICY CAREFULLY. By using the website, you give your consent to Newlane University’s data practices and understand that all personally identifiable information that you submit may be processed by Newlane University in the manner and for the purposes described herein.

If you do not agree to the terms and conditions set forth herein, do not use the website.

Collection of Personal Information

To apply for admission to Newlane University (“Newlane”, or the “University”), you must submit personally identifiable information to the Newlane website (“Website”). “Personally identifiable information” (“PII”) refers to data that allows Newlane University to identify you, such as your name, mailing address, telephone number, date and country of birth, your image from government-issued identification, government-issued identification number, e-mail address, and other personal information.

If you submit personally identifiable information through any of Newlane’s Communications Services (as described in the University’s Terms of Use), that information may be collected and used in accordance with this Privacy Policy.

Information and How We Use It

By submitting your PII to the Website, you understand and agree that Newlane may collect, use, transfer, and disclose your personally identifiable information as described in this Privacy Policy. The Website may collect, process and use the data which includes PII, the legal basis of which is your consent, which you give when you use the Services. Types of PII that may be used include the following, without limitation: 

  • We may process data about your use of our Website and Services (“User Data”). User Data may include your IP address, location, type of browser and version, operating system, referral source, visit length, page views and website navigation paths, as well as information about the frequency and timing of your use of the Service. The source of the User Data is an analytics tracking system. User Data may be processed for the purposes of analyzing the use of the Website and Services, operating our Website, improving and customizing the Services, ensuring the security of our Services, maintaining back-ups of our databases and communicating with you.
  • When registering or inquiring on our Website you may be asked to enter your name, email address, mailing address, telephone number, email address, date of birth, or other details (“Entered Data”). You are the source of such account data, and such data may be processed for the purposes of operating the Website, providing the Services, ensuring the security of the Website and Services, maintaining back-ups of our databases and communicating with you. Newlane will use your Entered Data for internal purposes including, but not limited to, academic and financial advising, record-keeping and tracking.
  • We may process information contained in any enquiry you submit to us regarding Services (“Enquiry Data”).
  • We may process information that you provide to us for the purpose of subscribing to our email notifications, offering you services, or promotions which may interest you (“Notification Data”). The Notification Data may be processed for the purposes of sending you relevant Notification Data.
  • We may process information contained in or relating to any communication that you send to us (“Correspondence Data”), for example, when you sign up for our newsletter or respond to a survey or marketing communication. The Correspondence Data may include communication content and/or metadata associated with such communication. The Correspondence Data may be processed for communicating with you and record keeping.
  • We may process any of the types of data described in this Privacy Policy if we are required to do so by court-order, any legal obligation to which we are subject, or when necessary, for the establishment, exercise or defense of legal claims. The legal basis for this processing is our legitimate interests, namely of the Website’s legal rights, your legal rights and the legal rights of others.
  • Please do not supply any other person’s PII to us without the specific and explicit consent of all parties, including the owner of such PII.

International transfers of your PII 

In this Section, we provide information about the circumstances in which your PII may be transferred to countries inside and outside the European Economic Area (“EEA”).

You acknowledge that PII submitted by you for publication through the Services may be available around the world via the internet. We cannot prevent the use or misuse of published PII by others once you submit it for publication, nor are we liable for such third-party use or misuse.

Such use may involve transfer of personally identifiable information to servers located outside the country from which you access the Website.

We have facilities in The United States. “Adequacy decisions” of the European Commission have been made with respect to the data protection laws of the United States. 

Adherence to the General Data Protection Regulation (GDPR) of 2018

Transfers to countries inside and outside the EEA will be protected by appropriate safeguards, namely the provisions of applicable law which relate to the protection of individuals with regards to the processing of PII to which a party may be subject including, without limitation, the General Data Protection Regulation 2018 (GDPR).

The hosting facilities for our Website are situated in The United States and Europe. The European Commission has made an “adequacy decision” with respect to the data protection laws of each of these countries. If you have opted-in and knowingly subscribe to our newsletter or other forms of correspondence, we may also use your information to inform you of new services Newlane will be providing, inform you of scholarship applications and academic programs, and send you requested information and promotional materials for marketing purposes and research.

Collection and Use of Non-Personal Information

The University automatically collects non-personal information about your computer hardware and software for the purpose of improving the administration and content of the Website, facilitating use of the University’s Website by its users, and to properly diagnose server problems and other issues.

The University may contract with third party providers to assist in better understanding visitors to the Website. Third party providers are prohibited from using any information they collect on behalf of Newlane for any purpose other than helping the University conduct and improve its services to you.

Information Sharing

The University does not sell, rent or lease your personally identifiable information to third parties without your prior written consent. Personally identifiable information collected in connection with applications for admission may, however, be collected by a third-party service provider that hosts the Website, and that information is released to application reviewers who may include University employees, contractors, volunteers and other parties. These individuals are prohibited from using your personally identifiable information except in connection with Newlane services and any other products and/or services you have requested, and they are required to maintain the confidentiality of your information.

Newlane may disclose your personally identifiable information, without notice, (i) if required to do so by law, or (ii) in the good faith belief that disclosure is necessary to protect or defend the rights, system, network, property or personal safety of the University, its personnel or its students. Newlane may disclose your personally identifiable information, with prior notice, subject to your consent, to a potential or actual partner or buyer in connection with a merger, acquisition, or any form of sale of some or all of the University’s assets.

The University requires opt-in consent (meaning, your express permission) to share any sensitive personally identifiable information, such as medical information or information concerning race or ethnicity, political or religious beliefs, and sexuality. 

Your Rights

In this Section, we have done our best to summarize the rights that you have under data protection law. These are complex, and not all of the details have been included herein. In light of this, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

Your principal rights under data protection law are:

  • the right to access;
  • the right to rectification;
  • the right to erasure;
  • the right to restrict processing;
  • the right to object to processing;
  • the right to data portability;
  • the right to complain to a supervisory authority; and  
  • the right to withdraw consent.

You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. 

You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed. Newlane will also correct, amend or delete any personal information that is inaccurate and notify any third-party recipients of the necessary changes. Newlane may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, are extremely impractical, or for which access is not otherwise required by local law or GDPR.

In some circumstances you have the right to the erasure of your personal data [by providing adequate evidence attesting to your identity] without undue delay. Those circumstances include: the personal data is no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. There are certain general exclusions of the right to erasure. Those general exclusions include where processing is necessary: [for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defense of legal claims].

In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defense of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defense of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defense of legal claims.

To the extent that the legal basis for our processing of your personal data is consent, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

If you consider that our processing of your personal information infringes data protection laws, you have a legal right to file a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.

To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

You may exercise any of your rights in relation to your personal data by written notice (including email) to us in addition to the other methods specified in this Section 5.

Opt-in

When you provide us with PII for a secondary reason, like marketing or other secondary reasons which we will convey to you from time to time if applicable, we will ask for your consent. After you opt-in, you may withdraw your consent anytime, by contacting us at contact@newlaneuniversity.com. 

Security of your Personal Information

The University maintains reasonable measures to protect your personally identifiable information from unauthorized access, use or disclosure. The University stores the personally identifiable information you provide on computer servers in a controlled environment that has implemented protections against unauthorized access, use or disclosure. Newlane has implemented procedures to safeguard the integrity of its information technology assets, including, but not limited to, authentication, monitoring, auditing, and encryption. These security procedures have been integrated into the design, implementation, and day-to-day operations of the Website as part of University’s continuing commitment to the security of electronic content as well as the electronic transmission of information.

For website security purposes and to maintain the availability of the Website for all users, the University employs software to monitor traffic and identify unauthorized attempts to upload or change information or otherwise damage the Website. When personally identifiable information (such as a credit card number) is transmitted to other websites, it is protected through the use of encryption, such as the Secure Socket Layer (SSL) protocol.

The University, however, cannot guarantee that unauthorized third parties will never be able to defeat the measures described in this section or use your personally identifiable information for improper purposes. Nothing in this Privacy Policy or in the University’s Terms of Use shall be deemed a guarantee, contract, or warranty of any kind, whether express or implied, regarding the security of your personally identifiable information.

Adherence to The Family Educational Rights and Privacy Act (FERPA) of 1974 

The Family Educational Rights and Privacy Act (FERPA) of 1974 was designed to protect the privacy of educational records, establish the rights of students to inspect and review their educational records, and provide guidelines for the correction of inaccurate or misleading information through informal and formal hearings. While FERPA does not apply to the University, since it is not a federally-funded institution, the University nonetheless strives to meet FERPA’s provisions to the extent reasonably feasible.

The University will not disclose a student’s educational record without obtaining the student’s prior written consent, except that a student’s educational record may be disclosed (i) to other school officials, including teachers with a legitimate educational interest and contractors, consultants, volunteers, or other parties to whom Newlane has outsourced educational or institutional services or functions; (ii) to parents of a dependent student, as defined in section 152 of the Internal Revenue Code of 1986; (iii) to accrediting organizations; (iv) in compliance with a judicial order or lawfully issued subpoena; or (v) for any other reason permitted under 34 CFR § 99.31.

The University depends on the accuracy of the records submitted by its students. False information on an application, or any other act to intentionally mislead or misinform instructional personnel or administrators, is grounds for disciplinary action, including dismissal from the University. Students seeking access or amendment of their educational records should contact the Office of Student Services at contact@newlaneuniversity.com

Children’s Online Privacy Protection Act

Although neither this website nor any of the University’s services are intended for children under 13 years of age, the University complies with the Children’s Online Privacy Protection Act of 1998 (“COPPA”) and does not knowingly collect any personal information online from children under the age of 13.

Use of Cookies

The Newlane Website may use “cookies”, subject to your consent if you are a resident of the European Union or are subject to GDPR, to help you personalize your online experience. A cookie is a small data file that is placed on your hard disk by a web page server. The purpose of a cookie is to tell the web server that you have returned to a specific page. For example, if you personalize Website pages, or apply for admission to Newlane, a cookie helps the University recall your specific information on subsequent visits. This simplifies the process of recording your personal information, such as your name and mailing address. When you return to the Website, the information you previously provided can be retrieved, so you can more easily benefit from the Newlane features.

Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you.

By using the Website, its related websites and other services, you hereby agree to the use of cookies as described herein. Note that most web browsers automatically accept cookies, but you can usually modify your browser settings to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of the Website.

Google Analytics

The University uses Google Analytics to collect information about use of the Website. The University uses the data it receives from Google Analytics to improve the Website, and does not combine the IP address collected by Google Analytics with your name or other identifying information that you may enter on the Website. Newlane cannot control Google’s use of the information it gathers; however, Google’s right to use and share information collected by Google Analytics about your visits to the Newlane Website is restricted by the Google Analytics Terms of Use and the Google Privacy Policy. You can prevent Google Analytics from recognizing you on return visits to this site by deleting its cookie or disabling cookies on your browser.

Your California Privacy Rights and Do Not Track Notices

California Civil Code Section 1798.83 permits customers of a company who are California residents to request certain information regarding its disclosure of personally identifiable information to third parties for their direct marketing purposes. To make such a request, please send an email to contact@newlaneuniversity.com. Please note that the University is only required to respond to one request per customer each year.

Note that the University does not respond to “Do Not Track” signals. 

The Newlane Learning Platform

All of the University’s courses, course hearings, assignments, course exams, the counseling services, and student and faculty forums are conducted through the Newlane learning and mastery-verification platform, an open source learning platform. 

No one outside the Newlane community is permitted to access the Newlane learning and mastery-verification platform. However, the Newlane site administrators have access to nearly everything in the system and certain private information is also accessible by other Newlane students, faculty and staff:

  1. Newlane profile page. Every Newlane student has a profile page which contains their first and last name, Student ID number, email address (optional), profile picture (optional) and description (optional). Student first and last name is visible to all students, faculty and staff. Newlane profile pages are NOT available to the general public.
  2. Newlane discussion forums. Anything posted in a discussion forum is visible to the instructor and to all students in that course. Your posts will include your full name and profile picture if you have chosen to upload it to the system.
  3. Private messaging system. Only the sender and receiver can view the content of messages sent through the Newlane messaging system.

If you withdraw from the University, your account will be disabled and will no longer be visible to students and instructors. Old and inactive accounts are usually deleted after four years of nonuse.

Third Party Websites, Cookies and Privacy Policies

Certain pages of the Website may contain links to websites that are not controlled by the University. Third-party cookies may be set by websites such as YouTube, Google Plus and other social media outlets or websites for which Newlane may implement plugins. Newlane may permit other companies to place cookies and use cookies according to the university policies and in accordance with this Privacy Policy. 

Third-party Providers 

In general, the third-party providers used by us will only collect, use and disclose your information to the extent necessary to allow them to perform the services they provide to us. However, certain third-party service providers, such as payment gateways and other payment transaction processors, have their own privacy policies in respect to the information we are required to provide to them for your purchase-related transactions. 

For these providers, we recommend that you read their privacy policies so you can understand the manner in which your personal information will be handled by these providers. In particular, remember that certain providers may be located in or have facilities that are located in a different jurisdiction than either you or us. So, if you elect to proceed with a transaction that involves the services of a third-party service provider, then your information may become subject to the laws of the jurisdiction(s) in which that service provider or its facilities are located. For example, if you are located in Canada and your transaction is processed by a payment gateway located in the United States, then your PII used in completing that transaction may be subject to disclosure under United States legislation, including the Patriot Act.

Once you leave our Website or are redirected to a third-party website or application, you are no longer governed by this Privacy Policy or our Website’s Terms of Service.

Third-party Links

Occasionally, at our discretion, we may include or offer third-party products or Services on our Website. These third-party sites have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites.

Age of Consent

By using this site, you represent that you are at least the age of majority in your state, province or country of residence, or that you are the age of majority in your state, province or country of residence and you have given us your consent to allow any of your minor dependents to use this site.

Retaining and Deleting PII

This Section 4 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data. 

We will retain and delete your personal data as follows:

PII will be retained for 25 years following the point of first contact with the University at the end of which period it will be deleted from our systems.

Notwithstanding the other provisions of this Privacy Policy, we may retain your PII where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

Third-party cookies are not governed by this Privacy Policy. The University does not control and is not responsible for the privacy policies or other content on websites other than the Website, including websites linked to from the Website, or for the use of personally identifiable information that you may submit to any of those websites. The University encourages you to review the privacy policies of those third-party websites directly so that you can understand how those websites collect, use and share your information.

Changes to this Policy

This Privacy Policy may be updated from time to time. Modifications will be denoted by the “updated” notice at the top of this page. Your submission of personally identifiable information to the Website following the posting of any changes to this Privacy Policy constitutes acceptance of those changes. The University encourages you to periodically review this Privacy Policy to be informed of its policies respecting your personally identifiable information. By continuing to access the Website after notice of modifications have been published, you signify your agreement to be bound by the updated terms.

Compliance with this Policy

The University regularly reviews its compliance with this Privacy Policy. If you have any questions regarding this Privacy Policy, or believe that the University has not adhered to any of its terms, please contact the University at contact@newlaneuniversity.com.