Our Commitment to Privacy

Our Privacy Policy was developed as an extension of our commitment to combine the highest quality products and services with the highest level of integrity in dealing with our customers and partners. The Policy is designed to assist you in understanding how we collect, use, disclose and safeguard personal information, and to assist you in making informed decisions, when you access this website (“our Website”), when you purchase products and services on our Website, or when you otherwise participate in an online program or service through our Website. This statement will be continuously assessed against new technologies, business practices, and our customers’ needs.

What Information Do We Collect
How Do We Use The Information You Provide To Us
To Whom Do We Disclose The Information That You Provide To Us
How We Manage Consent
How Can You Access and Correct Your Information
How We Store and Safeguard Personal Information
Retention of Personal Information
Transfer of Personal Information outside of the Country
Minors
Information for California Consumers
What About Other Websites Linked To Out Website
Changes To The Privacy Policy
How To Contact Us

 
  1. 1. What Information Do We Collect?

When you visit our Website, you may provide Auguste Escoffier School of Culinary Arts, which is owned by Triumph Higher Education Corporation (“AESCA”, “we”, “us” and “our”) with two types of information: (1) personal information you knowingly choose to disclose, which is collected by us on an individual basis, and (2) website use information collected on an aggregate basis as you and others browse our Website. The latter type of information may be considered personal information to the extent it identifies you as an individual.

(1) Personal Information You Choose to Provide

If you choose to access the Website and/or to purchase certain products or services from us, you may need to give personal information and/or authorization for us to obtain your personal information from various third-party sources, such as credit reporting agencies and other credit services. For example, you may need to provide the following information:

    • Name
    • Mailing address
    • Email address and other email information
    • Credit card number and other information
    • Home and business phone number
    • Credit or debit card information
    • Information necessary to process admission and/or to assess eligibility to bursaries, scholarships or financial aid, such as education, employment status, veteran or military status, professional or employment information
    • Other personal information

If you choose to correspond further with us through email, we may retain the content of your email messages to us together with your email address and our responses. We provide the same protections for these electronic communications that we employ in the maintenance of information received through our Website or by mail and telephone.

In addition to providing the foregoing information, when you enroll in our online programs, we collect certain additional personal information, including, but not limited to: which courses you have started and completed, your exchanges with instructors and/or other users of the courses, and materials submitted to satisfy program requirements.

(2) Website Use Information

We may collect certain types of information electronically when you interact with our Website, emails, social media accounts, online advertising or through technologies. The information helps us understand what actions you take on the Website and allows the Website to work correctly.

Similar to other commercial websites, our Website utilizes a standard technology called “cookies” (see explanation below, “What Are Cookies?”) and web server logs to collect information about how our Website is used. Information gathered through cookies and web server logs may include the date and time of visits, the pages viewed, time spent at our Website, and the websites visited just before and just after our Website. This information is collected on an aggregate basis. None of this information is associated with you as an individual.

What Are Cookies?

Cookies are a feature of web browser software that allows web servers to recognize the computer used to access a website. Cookies are small pieces of data that are stored by a user’s web browser on the user’s hard drive. Cookies can remember what information a user accesses on one webpage to simplify subsequent interactions with that website by the same user or to use the information to streamline the user’s transactions on related webpages. This makes it easier for a user to move from webpage to webpage and to complete commercial transactions over the Internet. Cookies should make your online experience easier and more personalized.

 

How Do We Use Information We Collect from Cookies?

We use website browser software tools such as cookies and web server logs to gather information about our Website users’ browsing activities, in order to constantly improve our Website and better serve our customers. This information assists us to design and arrange our webpages in the most user-friendly manner and to continually improve our Website to better meet the needs of our customers and prospective customers.

Cookies help us collect important business and technical statistics. The information in the cookies lets us trace the paths followed by users to our Website as they move from one page to another. Web server logs allow us to count how many people visit our Website and evaluate our Website’s visitor capacity. We do not use these technologies to capture your individual email address or any personally identifying information about you, although they do permit us to send focused online banner advertisements or other such responses to you.

Tracking Options and California Do Not Track Disclosures

Certain websites require cookies to function efficiently. We may use cookies to deliver advertising we believe is relevant to you and to link data collected across other devices you use. You can adjust your settings to limit tracking or decline cookies, but, as a result, you may not be able to use certain features of this Website or take full advantage of all of our offerings. Please refer to your device or browser settings for more information on how to delete or decline cookies and control your tracking preferences.

Collection Through Other Technologies, Third-Party Agencies, and Tracking

We may collect personal information through the following other technologies:

Online Interest-based Advertising. We may also allow a limited number of trusted third parties, including our advertising agencies (including Validated Insights Inc., PRESENCE, LLC dba TELL ME MORE and Education Dynamics) to install cookies on your hard drive from our Website. The Website may include third-party advertising and links to other websites which may be used to generate personalized advertisements. Personalized ads, sometimes referred to as interest-based or behavioral ads, are ads based upon information about you, such as your page views on our Website, your information requests or purchases on the Website. We do not provide any personal information to advertisers or to third party sites that display interest-based ads on our Website. However, advertisers and other third parties (including the ad networks, ad-serving companies, and other service providers they may use) may assume that users who interact with or click on a personalized ad or content displayed on our Website are part of the group that the ad or content is directed towards. Advertisers or ad companies working on their behalf sometimes use technology to serve the ads that appear on our Website directly to your browser. They may also use cookies to measure the effectiveness of their ads and to personalize ad content. We do not have access to or control over cookies or other features that advertisers and third party websites may use, and the information practices of these advertisers and third-party websites are not covered by this Privacy Policy. Please contact them directly for more information about their privacy practices. You can also generally opt-out of receiving personalized ads from third-party advertisers and ad networks who are members of the Digital Advertising Alliance’s (DAA) or Digital Advertising Alliance of Canada if you reside in Canada. Please visit the DAA opt-out page and the DAAC opt-out page for more information.

Google Analytics: Our advertising agencies may use Google Analytics, which allows them to see information on user website activities, including, but not limited to, page views, source and time spent on our Website. This information is depersonalized and is displayed as numbers, meaning that it cannot be tracked back to individuals. You may opt out of our use of Google Analytics by visiting the Google Analytics opt-out page.

Third-Party Social Networks: Third-party social networks that provide interactive plug-ins to enable social network features (e.g., to connect to Facebook) on the Site may use cookies to gather information on your use of the Site. How this collected data is used by a third party is dependent on the privacy policy of the social network, which is available on the appropriate parties’ website. ABC encourages you to review the privacy policies of third parties as well. Third parties involved may use these tracking methods such as but not limited to cookies to achieve their own business goals and purposes by relating and combining information about your usage of the Site to any other personal information they may have collected on you. ABC may also obtain and use analytical and statistical information from third-party social networks to help it measure performance and effectiveness of content displayed by ABC on social networks, for example, by measuring impressions and clicks on the content ABC promotes.

Google Ads: ABC uses Google Ads Remarketing to advertise ABC across the Internet and to advertise on third-party websites (including Google) to previous visitors to the Site. Google Ads remarketing will display ads to you based on what parts of the Site you have viewed by placing a cookie on your web browser. It could mean that ABC advertises to previous visitors who haven’t completed a task on the Site or this could be in the form of an advertisement on the Google search results page, or a website in the Google Display Network. This cookie does not in any way identify you or give access to your computer or mobile device. The cookie is only used to indicate to other websites that you have visited a particular page on the Site, so that they may show you ads relating to that page. If you do not wish to participate in ABC’s Google Ads Remarketing, you can opt out by visiting Google’s Ads Preferences Manager. You may delete or disable certain of these technologies at any time via your browser. However, if you do so, you may not be able to use some of the features on our Website.

 

2. How Do We Use the Information That You Provide to Us?

We may use your personal information to provide you with our products, services, programs and other offers, to manage our business operations, to communicate information and offers we think might interest you, to generally enhance your customer experience, and as otherwise permitted or required by law. Broadly speaking, we may use your personal information for the following purposes:

  • to manage our business operations, including processing applications for admission, scholarships, bursaries and/or financial aid, creating a student account, and authenticating your identify;
  • to respond to an inquiry, to send you materials, and to otherwise communicate with you by email, phone or mail;
  • to provide customer service, products and/or services to you;
  • to customize the content that you see on our Website;
  • to conduct market research and data analytics by tracking and analyzing current or previously collected information;
  • to market and otherwise make available other products and services to our customers and prospective customers;
  • to notify you about important changes to our Website, new products, services and special offers we think you will find valuable;
  • to meet our contractual, legal and regulatory obligations.

Notice of New Services and Changes

Occasionally, we may also use the information we collect to notify you about important changes to our Website, new products, services and special offers we think you will find valuable. The lists used to send you product and service offers are developed and managed under our traditional corporate standards designed to safeguard the security and privacy of our customers’ personal information. As our customer, you will be given the opportunity to notify us of your desire not to receive these offers by clicking on a response box when you receive such an offer or by sending an email to [email protected].

Limiting Use of Personal Information

Our corporate values, ethical standards, policies and practices are committed to the protection of customer personal information. In general, our business practices limit employee access to personal and confidential information, and limit the use and disclosure of such information to authorized persons, for authorized processes and transactions.

 

3. To Whom Do We Disclose The Information That You Provide To Us?

Sharing Information with Strategic Partners

If we enter into strategic marketing alliances or partnerships with third parties, we will not share any personal information about our customers or potential customers.

Do We Disclose Information to Outside Parties?

We may hire service providers, which may be affiliates, to perform services on our behalf. This may include, without limitation, a person or an organization retained by us to perform work on our behalf, including for marketing research, customer service and web-related services, and quality control assessment. We provide them with a limited amount of information which is necessary in order for them to provide the services required. They are prohibited from using the information for purposes other than to facilitate and carry out the services they have been engaged to provide.

We may also disclose personal information to outside parties in the following circumstances:

  • In connection with a sale or transfer of business or assets, an amalgamation, reorganization or financing of parts of our business (including the proceedings of insolvency or bankruptcy). In the event the transaction is completed, your personal information will remain protected by applicable privacy laws. In the event the transaction is not completed, we will require the other party not to use or disclose your personal information in any manner whatsoever and to completely delete such information, in compliance with applicable laws.
  • When legally compelled to do so in response to a law, regulation, court order, subpoena, valid demand, search warrant, government investigation or other legally valid request or inquiry, in other words, when we, in good faith, believe that the law requires it or for the protection of our legal rights.
  • To our accountants, auditors, agents and lawyers in connection with the enforcement or protection of our legal rights.
  • When we have reasonable grounds to believe that such disclosure is reasonably necessary to protect the rights, property and safety of others and ourselves, in accordance with or as authorized by law.
  • Where otherwise permitted or required to do so by law.

To the extent permitted by law, we may also provide aggregate information about our customers, potential customers, sales, website traffic patterns, and related website information to our affiliates or other reputable third parties, but this information will not include personally identifiable information.

4. How We Manage Consent

By visiting our Website (including using our online services, making purchases, creating an account or participating in an online program) and/or submitting information to us in connection with our products and services, you are providing your consent to the collection, use and disclosure of personal information as set out in this Privacy Policy. In some cases, your consent may be “implied” i.e. your permission is assumed based on your action or inaction at the point of collection, use or sharing of your personal information.

We will generally obtain consent when we want to use personal information for a new purpose or for a purpose other than those stated at the time of collection in this Privacy Policy or in the terms and conditions of a specific product, service, program, promotion or event you signed up for, participated in or purchased. Your consent can be withdrawn at any time, except in limited circumstances, including legal or regulatory requirements or as a result of your contractual obligations with us.

If you choose not to provide us with certain personal information or if you withdraw your consent, where such withdrawal is available, we may not be able to offer you the products, services or programs that you requested or that could be offered to you.

 

5. How Can You Access and Correct Your Information?

You may request access to your personally identifiable information that we collect through our Website and maintain in our database, subject to legal restrictions, by emailing us at [email protected]. You can also request to update, add or remove your personal information at any time by emailing us at the above email address. It is your responsibility to provide accurate, correct and complete information.

 

6. How We Store and Safeguard Personal Information

We take the security of your personal information very seriously and are committed to protecting your privacy by using a combination of administrative, physical and technical safeguards implemented by us.

We employ organizational, physical and technological measures to protect the confidentiality of personal information and to safeguard personal information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification, in light of, among other things, the sensitivity of the information and the purposes for which it is to be used. These measures include access restrictions, encryption, and personnel training concerning the importance of preserving the privacy, confidentiality, and security of the personal information collected. These safeguards also apply when we dispose of or destroy your personal information.

Please be careful whenever sending personal information to us electronically. Please note that transmissions over the Internet are never completed protected or exempt from error. It is the reason why we cannot guarantee the security of the information transmitted electronically since such transmissions are conducted at your risk and peril. More specifically, an email sent to our Website or from our Website cannot be protected. We recommend that you keep this in mind when you determine the nature of the information transmitted electronically. Moreover, when you use them, the protection of your login, password and other special access elements of our Website is your exclusive responsibility. Please ensure that they are kept confidential.

 

7. Retention of Personal Information

Personal information will be retained only as long as necessary for the fulfilment of the purposes for which it was collected and for which consent was received, unless otherwise authorized or required by law. Subject to the foregoing, personal information that is no longer required to fulfil the identified purposes will be destroyed, erased or made anonymous.

 

8. Transfer of Personal Information Outside of The Country

Your personal information may be stored and/or processed by us or by our services providers outside of your country of residence. We uses reasonable safeguards, such as contractual requirements, to ensure that our service providers protect your personal information wherever it is used or stored.

As a result of the foregoing, when your personal information is used, access, stored or processed in a country other than your country of residence, it may be subject to the laws of this foreign jurisdiction, including any law permitting or requiring disclosure of the information to the government, government agencies, courts and law enforcement in that jurisdiction.

 

9. Minors

It is neither our goal nor our intention to collect personal information concerning persons under the age of majority in their state, province or territory of residence without their parent or legal guardian’s consent. We do not knowingly provide any personal information collected from such persons, regardless of its source, to any third party for any purpose whatsoever. Notwithstanding the foregoing, it is possible that we nevertheless collect such information if same is provided to it.

We therefore encourage parents to inform their children about the possible consequences of using our Website and disclosing information through the Website. We will not assume any responsibility with respect to the use of our Website or disclosure of information via our Website by children.

MINORS ARE HEREBY REQUIRED TO OBTAIN THE PERMISSION OF THEIR PARENT OR LEGAL GUARDIAN BEFORE PROVIDING ANY PERSONAL INFORMATION TO US.

 

10. Information for California Consumers

The California Consumer Privacy Act of 2018 (“CCPA”) grants a right of privacy certain rights and protections to California residents. This section is intended to further describe the categories presented in the updated act including (a) what personal information is being collected about them; (b) whether or not their personal information is being shared or disclosed and to whom (c) the right to say no to the sale of personal information; and (d) the right to access their personal information.

Categories of Data AESCA Collects from California and Canadian Consumers: We collect the following categories of data: (a) identifiers, such as a name, email address, telephone number, physical address, unique personal identifier (such as student ID), online identifier, IP address, account name, Social Security number or Social Insurance number, driver’s license number; (b) personal identifiers under Cal. Civ. Code § 1798.80(e), such as education, employment status, bank account information, credit card or debit card number, financial information; (c) protected classification characteristics under California law, such as age, marital status, gender, veteran or military status; (d) commercial information, such as products or services obtained, or considered, or other purchasing or consuming histories or tendencies; (e) internet activity, such as browsing history and search history information; (f) geolocation data; (g) professional or employment information, such as consumer-reported current or past job history; (h) inferences drawn from some of the information above (e.g., email open rates and time). The list above is an all-encompassing list of potential information collected from request for information through potential enrollment into the program. Personal information collected as noted in this policy that goes beyond name, address, email, location, or program of interest is collected only if one completes the enrollment process to attend our programs. Our institution is required to complete regulatory reporting that specifically asks for information such as marital status, gender, military status, or previous education. If financial information such as Social Security Number, Social Insurance Number, debit or credit card, bank account information is collected, that is maintained in a secure fashion for any financial aid or payment processing information if one decides to enroll into the program.

CCPA Rights: The CCPA requires certain rights and protections to California residents including: (a) the right to request that we delete any “personal information” that we have collected from you; (b) the right to request that we disclose the categories and/or specific pieces of personal information collected and sold; and (c) the right to direct us not to sell their “personal information”. “Personal information” is defined under the CCPA as “information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.”

California residents who would like to submit a Request to Know, Delete, or Opt-Out should request an opt-out by emailing us at [email protected] or by calling us at (855) 280-3980 . We will use your email address to verify your identity. Provided we are able to confirm your identify, we will respond within 30 days of your request.

Demographic & Personal Information: We may collect your name and address if you have requested information from us or have been an active student with us at any point. We also collect phone numbers and email addresses. We may also collect your information regarding your age, gender, race or ethnicity if that was appropriate information based on your relationship with our institution. We only require information such as age, gender, race or ethnicity if you decide to enroll with our institution to comply with required regulatory reporting requirements.

Educational Platforms: We collect information you post in a public space on our E-learning platforms. This may include posts you make discussion boards, live chat sessions or social media pages.

Device and location information: We collect the type and make of device you use to access our E-learning platforms. We may also collect information about the browser you are using. We might look at what website you came from, or what website you visit when you leave us. We may collect information across the devices you use to access our E-learning platform. If you use our app, we might look at how often you use the app and where you downloaded it. This might include your device identification number, IP address or mobile operating system. We may also collect location information. This may include precise location information from your device such as your location when you are on or near campus. If information on location is collected prior to a decision to enroll into the program, this information is used to ensure that we are contacting you at appropriate times based on your location. If you decide to enroll into the program, we use location information to ensure academic integrity.

Enrollment and payment information: We collect information in your application for admission and your application for financial aid, including Social Security number, date of birth, citizenship and military status, as applicable. We may also collect information about other schools you have attended and income history. We might also collect your credit card or bank account number and billing address. The list above is an all-encompassing list of potential information collected from request for information through potential enrollment into the program. Personal information collected as noted in this policy that goes beyond name, address, email, location, or program of interest is collected only if one completes the enrollment process to attend our programs. Our institution is required to complete regulatory reporting that specifically asks for information such as marital status, gender, military status, or previous education. If financial information such as Social Security Number, Social Insurance Number, debit or credit card, bank account information is collected, that is maintained in a secure fashion for any financial aid or payment processing information if one decides to enroll into the program.

 

11. What About Other Websites Linked to Our Website?

We are not responsible for the practices employed by websites linked to or from our Website nor the information or content contained therein. Links to other websites are provided solely as pointers to information on topics that may be useful to the users of our Website.

 

12. Changes to The Privacy Policy

We may make changes to this Privacy Policy from time to time. Any changes that we make will become effective when we post a modified version of the Policy on our Website. If the changes made are significant, we will provide a more prominent notice when required by applicable laws. By visiting our Website, purchasing a product and/or using services after the modified version of the Privacy Policy has been posted or you have been informed of such update, you are accepting the changes to the Privacy Policy. It is your obligation to ensure that you read, understand and agree to the latest version of the Privacy Policy. The “Effective Date” at the top of the Privacy Policy indicates when it was last updated. If significant changes are expected to occur in our Privacy Policy, we will notify the applicable students in advance and provide a mechanism to opt in or out of these changes.

 

13. How to Contact Us

If you have any questions regarding our data collection and data protection practices or this Privacy Policy, or those of our service providers, or if you have a complaint in connection with matters relating to this Privacy Policy, you can contact our Privacy Officer at the following coordinates:

Email: [email protected]

Phone: (855) 280-3980

Mail:
Triumph Higher Education Corporation
Attn: Privacy Officer, Auguste Escoffier School of Culinary Arts
150 North Martingale Rd., Suite 300
Schaumburg, IL U.S.A. 60173

Effective as of 12/31/2021.