Franklin University Privacy Policy

1.1 Personal Information
It is always up to you whether to disclose personally identifiable information to us, although if you elect not to do so, we reserve the right not to register you as a user or provide you with any products or services. 

We may collect personal information such as your name, email address, contact number, and other relevant details when you voluntarily provide it to us through forms, registrations, or other means.

1.2 Where We Collect It
This Online Privacy Policy explains how the University collects, uses, and discloses information, including cookies, in compliance with applicable laws, including the California Consumer Privacy Act (CCPA), the General Data Protection Regulation (GDPR), and other relevant privacy regulations worldwide.

Under applicable privacy laws, you may have certain rights regarding your personal information, including the right to access, correct, delete, or restrict the processing of your information. You may also have the right to object to the processing of your information or withdraw your consent. To exercise these rights, please contact us at privacy@franklin.edu 

If you are accessing our website from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States or other countries. By using our website, you consent to the transfer of your information to these countries, which may have different data protection laws than your country of residence.

1.3 Student or Visitor Options 
Students and/or visitors who visit the Franklin University website may be required to consent to cookie requirements depending on their geographic location. Cookie consent requirements vary across different jurisdictions, as each country or region has its own data protection laws and regulations. Here is an overview of key geographies and their cookie consent requirements, to include the European Union, the United States, the State of California, Canada, the United Kingdom, and other areas not mentioned:

1.3.1 European Union (EU) - General Data Protection Regulation (GDPR)
The GDPR requires website operators to obtain informed and freely given consent from users before placing non-essential cookies on their devices. Websites must provide clear and specific information about the types of cookies used, their purpose, and how users can manage their preferences. Consent must be obtained through affirmative actions, such as clicking an "Accept" button or actively adjusting cookie settings. Users have the right to withdraw their consent at any time and must be provided with an easy and accessible way to do so. Under the GDPR in the EU, the collection and use of cookies are subject to specific requirements and guidelines. The GDPR defines cookies as a form of personal data if they can be used to identify an individual directly or indirectly. Here are some key considerations regarding the types of cookies that can or cannot be collected under the GDPR:

1.3.1.1 Necessary Cookies: The GDPR allows for the collection of cookies that are strictly necessary for the functioning of a website or service. These cookies are essential for providing the requested service or enabling basic website functionality, such as remembering user preferences, maintaining session information, and facilitating e-commerce transactions. Consent is not required for the collection of necessary cookies.

1.3.1.2 Performance and Functionality Cookies: The GDPR permits the collection of performance and functionality cookies that enhance the user experience but are not strictly necessary for the website's basic functionality. These cookies may include analytics cookies that collect information about website usage, such as the number of visitors, pages visited, and user behavior. Consent is generally required for the collection of performance and functionality cookies.

1.3.1.3 Advertising and Tracking Cookies: The GDPR imposes stricter requirements for the collection of advertising and tracking cookies. These cookies are used to track user behavior across websites and deliver targeted advertisements. Consent is generally required for the collection of advertising and tracking cookies. Users must be provided with clear and specific information about the purposes of these cookies and have the ability to give or withhold consent.

1.3.1.4 Third-Party Cookies: The GDPR also addresses the collection of cookies by third-party entities. If a website allows third-party cookies for advertising or tracking purposes, businesses must obtain user consent and provide clear information about the third parties involved and the purposes of the cookies.

Consent under the GDPR must be freely given, specific, informed, and unambiguous. Users must have the ability to give or withhold consent, and they must be provided with clear information about the types of cookies used, their purposes, and any third parties involved. Consent should be obtained through affirmative actions, such as clicking an "Accept" button or actively adjusting cookie settings.

It's important to note that the GDPR grants individuals certain rights regarding their personal data, including the right to be informed about the collection and use of their data, the right to access and rectify their data, the right to restrict or object to the processing of their data, and the right to have their data erased. Businesses subject to the GDPR must comply with these rights and provide the necessary mechanisms for individuals to exercise them.

1.3.2 United States
The United States does not have a comprehensive federal data protection law like the GDPR. Instead, cookie consent requirements may vary at the state level. Some states, such as California, have implemented their own privacy laws, like the CCPA and the California Privacy Rights Act (CPRA). These laws require website operators to provide clear and conspicuous notices about the types of cookies used and their purpose. Users must be given the option to opt-out of the sale of their personal information, which may include certain cookies.

1.3.2.1 CCPA
Under the CCPA in the United States, there are specific requirements and guidelines regarding the collection and use of cookies. The CCPA defines personal information broadly and includes online identifiers such as cookies. Here are some key considerations regarding the types of cookies that can or cannot be collected under the CCPA:

A.    Essential Cookies: The CCPA allows for the collection of cookies that are necessary for the functioning of a website or service. These are typically referred to as "essential" or "strictly necessary" cookies. They enable basic website functionality, such as remembering user preferences, allowing access to secure areas, and facilitating e-commerce transactions. These cookies can be collected without the need for explicit user consent.

B.    Non-Essential Cookies: The CCPA requires businesses to obtain user consent before collecting non-essential cookies or cookies that are used for purposes beyond the basic functioning of a website. Non-essential cookies include:

i.     Analytics Cookies: These cookies are used to collect information about website usage, such as the number of visitors, pages visited, and user behavior. Consent is generally required for the collection of analytics cookies.
ii.    Advertising Cookies: These cookies are used to track user behavior across websites and deliver targeted advertisements. The collection of advertising cookies generally requires user consent.
iii.   Social Media Cookies: These cookies allow users to share content from a website on social media platforms. Consent is typically required for the collection of social media cookies.

C.    Third-Party Cookies: The CCPA also addresses the collection of cookies by third-party entities. If a website allows third-party cookies for advertising or tracking purposes, businesses must provide a clear and conspicuous opt-out mechanism for users to exercise their right to opt-out of the sale of their personal information. This opt-out must be accessible through a "Do Not Sell My Personal Information" link on the website.

It's important to note that the CCPA grants California residents certain rights regarding their personal information, including the right to know what personal information is being collected, the right to opt-out of the sale of personal information, and the right to request deletion of their personal information. Businesses subject to the CCPA must comply with these rights and provide the necessary mechanisms for users to exercise them.

1.3.3 Canada
In Canada, the Personal Information Protection and Electronic Documents Act (PIPEDA) governs cookie consent requirements. Consent must be obtained before collecting, using, or disclosing personal information, including through the use of cookies. Websites must provide clear and understandable information about the purposes of the cookies and how users can manage their preferences.

1.3.4 United Kingdom (UK)
The UK has adopted the GDPR into its domestic law with the Data Protection Act 2018. Similar to the EU, cookie consent in the UK requires informed and freely given consent. Website operators must provide clear information about the types of cookies used and obtain affirmative actions from users to indicate their consent.

1.4 Global Privacy Control (GPC)
The Global Privacy Control is an initiative that aims to provide users with a universal mechanism to exercise their privacy preferences across websites. GPC allows users to signal their preference for not having their data sold or shared by enabling a browser setting or extension. Website operators are expected to respect this signal and honor users’ privacy preferences.

1.5 Do Not Track (DNT)
Do Not Track is a browser feature that allows users to indicate their preference for not being tracked across websites. However, DNT is not universally recognized or enforced by website operators. It is up to individual websites to decide whether or not to respect the DNT signal.

1.6 Other Information

In addition, Franklin may have the occasion to collect non-personal anonymous demographic information such as age, gender, household income, political affiliation, race, and religion, as well as the type of browser you are using, Internet Protocol (IP) address, or type of operating system, which will assist us in providing and maintain superior quality service. This data is collected through cookies, web beacons, flash cookies, and similar technologies. The University uses different types of cookies, to include:

• First-party cookies – are those used by the University when you visit our website. We use these to make your experience on our website better and to ensure our website functions as expected. Only the University can access this data. 
• Third-party cookies – are those from third parties that we place on our website. We use these to track our advertising effectiveness, improve advertising that we may deliver to you after you leave our site and support your experience on our site. The third parties have access to this data, often, the pages you visited on our website and your location. 
• Cookie Duration – a session cookie is temporarily stored in your browser on your computer, phone, or other device. It is deleted after you leave the website or when you close the browser.
• Persistent cookie – is stored on your browser on your computer, phone or other device. It is active until you delete it, or it expires.  
• Social Media cookies – are used to connect a website to a third-party social media platform. They remember a user’s details after the user signs into a social media account from a website. Many social media cookies are set through plugins, widgets, and sharing buttons. 

The following types of cookies are used to collect data after consent: 

• Strictly Necessary Cookies – are those that enable a website to function without them, it will either not work at all or will not work properly. These cookies include ones that enable users to log into secure areas of the website and use a shopping cart. These cookies do not track any personal data of visitors.
• Performance Cookies – are used for collecting data on how visitors behave on a website. This performance, also called analytics cookies, can count page visits, how much time a user has spent on a website, count errors on damaged websites, as well as bounce rates and loading speeds to improve performance.
• Functional Cookies – allow websites to remember the user's site preferences and choices they make on the site including username, region, and language. This allows the website to provide personalized features like local news stories and weather if you share your location.
• Targeting Cookies – are small, encrypted files that track users' actions and are used to identify users between different websites. Targeting cookies collect user information and use it to build a profile of users' interests and then show personalized ads for that specific user.

2.1 Personal Information
Franklin may collect and make use of personal information to assist in the operation of our website and to ensure delivery of the services you need and request. We may use your personal information to communicate with you, respond to inquiries, and send relevant updates or newsletters. At times, we may find it necessary to use personally identifiable information as a means to keep you informed of other possible products and/or services that may be available to you from Franklin University. 

2.2 Usage Data
Franklin may also be in contact with you with regards to completing surveys and/or research questionnaires related to your opinion of current or potential future services that may be offered. We also use usage data to analyze trends, improve our website, and enhance user experience. This data helps us understand how visitors interact with our site and allows us to make necessary improvements.

3. Disclosure of Information
We do not sell, trade, or rent your personal information to third parties. However, we may share your information with trusted service providers who assist us in operating our website or delivering services to you. These providers are obligated to keep your information confidential and are not permitted to use it for any other purpose.

We may also disclose your personal information if required by law or to protect our rights, safety, or property.

4. Data Security
We implement appropriate security measures to protect your personal information from unauthorized access, alteration, disclosure, or destruction.

While we strive to protect your personal information, please note that no method of transmission over the Internet or electronic storage is 100% secure. We cannot guarantee absolute security.

5. Third-Party Links
Our website may contain links to third-party websites. We are not responsible for the privacy practices or content of these websites. We encourage you to review the privacy policies of any third-party sites you visit.

6. Children's Privacy
Both Ohio law and federal law prohibit the disclosure of a student's personally identifiable information (including most of the education record) without the written consent of the parent, or of the student, if the student is over the age of 18. 

Our website is not directed to, and does not knowingly collect personal identifiable information from, children under the age of thirteen (13). If you believe we have inadvertently collected information from a child, please contact us to have it removed.

If we learn we have collected or received personal data from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information about a child under 13, please contact us at privacy@franklin.edu . Residents of certain states that are under 16 years of age may have additional rights regarding the collection and sale of their personal data. Please see Your State Privacy Rights section below, for more information.

7. FERPA Statement
The Family Educational Rights and Privacy Act (FERPA) is a federal law that protects the privacy of student education records. At Franklin University, we are committed to complying with FERPA regulations and safeguarding the privacy of our students' educational information. Refer to the following URL for the University’s Notice of Privacy Rights: https://www.franklin.edu/about-us/policy-information/notice-privacy-rig…;

8. Changes to the Privacy Policy
We reserve the right to modify or update this Privacy Policy at any time. Any changes will be effective immediately upon posting on our website. We encourage you to review this policy periodically.

9. Data Retention
The data we collect from you will be stored for no longer than necessary. The length of time we retain said information will be determined based upon the following criteria: 1. The length of time your personal information remains relevant; 2. The length of time it is reasonable to keep records to demonstrate that we have fulfilled our duties and obligations; 3. Any limitation periods within which claims might be made; 4. Any retention periods prescribed by law or recommended by regulators  professional bodies or associations; and 5. The type of contract we have with you, the existence of your consent, and our legitimate interest in keeping such information as stated in this Policy. 

10. Contact Information
If you have any questions, concerns, or requests regarding this Online Privacy Policy, or want to see additional details on how we collect or use data, please contact us at privacy@franklin.edu. 
 
By using our website, you acknowledge that you have read and understood this Privacy Policy and agree to its terms.

Last updated: February 7, 2024