MIU Privacy Policy

This Privacy Policy (the “Privacy Policy”) describes how MIU (as owned and operated by educatingly Ltd) (“MIU”, “we”, or “us”) collects, uses and discloses information from and about you when you visit and use MIU.education and MIU’s associated websites, applications and virtual learning environments/online campus platforms (collectively, the “Websites”), as well as your ability to control certain uses of that information. It also describes certain data protection rights which may apply under applicable law, including a right to object to some of the processing which MIU carries out. More information about your rights, and how to exercise them, is set out in the “Your Rights Regarding Your Personal Information” section below. MIU respects your privacy and is committed to protecting it through our compliance with this Privacy Policy. By accessing or otherwise using the Websites, you agree, where permitted by applicable law, to MIU collection, use and disclosure of your information, as data controller, in accordance with this Privacy Policy, which is incorporated into MIU Terms of Use. We regularly review our compliance with this Privacy Policy and whenever we receive a formal complaint, we will make best efforts to contact the person who made the complaint to attempt to resolve his or her concerns. If you have any questions about the use of your information, or the contents of this Privacy Policy, please feel free to contact us.

Collection of Information

Information You Provide

MIU collects information from you when you choose to provide it to us. For example, we may collect your information when you submit a form requesting information about one of our course offerings (“Course”) or about other courses offered at other schools, otherwise provide information to us through the Websites, or otherwise contact us. The information we collect may include personal information – such as your contact details, government issued identifier, or other information that can be used to identify you or can be attributed to you – or non-personal information. In some cases, you may choose not to provide us with your information, but we may require it when necessary to perform a contract or to comply with a legal obligation. We also may use information about you for reasons not described in this Privacy Policy where the reason is compatible with the purpose for which we originally collected your information and where such use is lawful.

Children’s Information

We do not direct the Website to, nor do we knowingly collect any personal information from, children under 16.

Information Automatically Collected

When you visit the Websites or interact with e-mails that we send to you, we may passively collect information from you and store that information on our server logs, including your internet protocol address (“IP address”), browser type, operating system, device identifier, device model, software version, or mobile or ISP carrier information. We also use Cookies and other technologies to collect information about your visit to the Websites, such as the date and time of your visit, the information you searched to find the Websites, or your activity on the Websites. “Cookies” are small files which may be stored on your computer during your use of the Websites and contain data about your use of the Websites. We may use session Cookies (which expire when you close your browser) or persistent Cookies (which stay on your computer until you delete them) to understand more about your activity on the Websites or on other websites. Please see our Cookie Policy for details on how we use Cookies and your ability to control the Cookies we set on your browser.

Tracking Options and California Do Not Track Disclosures. You may adjust your browser or operating system settings to limit this tracking or to decline or delete Cookies, but by doing so you may be unable to access or use certain areas of the Websites. Check the “Help” menu of your browser or operating system to learn how to change your tracking settings or Cookie preferences. On your mobile device, you can adjust your privacy and advertising settings to limit your tracking for advertising or control whether you receive more relevant advertising. Note that our systems may not recognize Do Not Track headers or requests from some or all browsers.

To learn more about your choices for receiving interest-based advertising or to opt out, please see our Cookie Policy.

Information Collected from Other Sources

We may collect or receive information about you from other sources with which you interact (e.g., Facebook), companies that are our partners, or other entities within the Educatingly family of companies to update or supplement the information that you provide or that we collect automatically. We may use this information to help us maintain the accuracy of the information we collect, to target our communications so that we can inform you of products, services or other offers that may be of interest to you, and for internal business analysis or other business purposes.

Our Combination of Your Information

We may combine the information we receive from and about you, via the Websites and from third parties, to help us tailor our communications to you and to improve the Websites.

Failure to Provide Personal Information

Failure to provide certain information may make it difficult or impossible for you to access some services through the Websites (for example, to register for and complete Courses). You will need to ensure that personal information submitted to us is accurate and up to date. For example, we need a current email address to communicate with you about the Course in which you are enrolled.

How We Use Your Information

Legal Basis for Collecting and Processing Personal Information

We process personal information for the following purposes:

To fulfil a contract or take steps linked to a contract. This includes:
1. Providing our services, including the set up and management of accounts and profiles;
2. Verifying your identity;
3. Taking payments;
4. Communicating with you.
To conduct MIU’s business and pursue our legitimate interests. This includes:
1. Using your information to provide products and services you have requested and to respond to any comments or complaints you may send us;
2. Personalizing your experience on the Websites and in any Course in which you choose to enrol and to help us to better respond to your individual needs;
3. Using information we collect about you through the Websites to deliver advertising that is targeted for individuals with similar interests or characteristics through third party service providers, such as Facebook Custom Audiences or other similar business tools;
4. Developing new products or services or conducting analysis to enhance current products and services;
5. Reviewing the usage and operations of the Websites and to analyse and improve the Websites (we continually strive to improve the Websites based on the information and feedback we receive from you);
6. Contacting you for legitimate business purposes;
7. Using personal information to invite individuals to take part in market research;
8. Where consent is not required by applicable law, for direct marketing purposes.

We conduct balancing tests for the data processing we carry out on the basis of our legitimate interests, which we have described above.

To protect the security and functionality of the Websites. This includes:
1. If you provide a credit or debit card as payment, using third parties to check the validity of the sort code or routing number, account number and card number you submit in order to prevent fraud ;
2. Monitoring customer accounts to prevent, investigate and/or report fraud, misrepresentation, security incidents or crime, in accordance with applicable law;
3. Using personal information, you provide to investigate any complaints received from you or from others about our Websites or our products and services.
Where you give us consent. This includes:
1. Where consent is required by applicable law, sending you direct marketing in relation to our relevant products and services, or other products and services provided by MIU, its parent company, educatingly Ltd, and the Educatingly Ltd’s family of companies.
2. Placing cookies and using similar technologies in accordance with our Cookie Policy and the information provided to you when those technologies are used;
3. on other occasions where we ask you for consent, using the data for the purpose which we explain at that time.
For purposes which are required by law. This includes:
1. in response to requests by government or law enforcement authorities conducting an investigation;
2. using personal information in connection with legal claims, compliance, regulatory and investigative purposes as necessary (including disclosure of such information in connection with legal process or litigation).

MIU also may use de-identified aggregate or anonymized information to help us analyse the use of the Websites. This Privacy Policy does not limit our use or disclosure of de-identified aggregate or anonymized information, and we reserve the right to use and disclose such information to our partners, advertisers, and other third parties at our discretion.

How We Disclose Your Information

MIU may share your information with other entities or individuals in the following circumstances:

University Partners: We may share your information with the relevant college or university with which we collaborate on Courses (“University Partner”) in order to process your information, track your participation in the Course, and/or fulfil our contracted responsibilities to the University Partner.
The Educatingly Ltd Family of Companies: Where you have expressed interest and given your consent, we may share your information with our parent company, educatingly Ltd, and within the family of companies to provide you with information about other educational programs.
Service Providers: We may share your information with our service providers that provide business, professional, or technical support functions for us. In particular, we use third-party providers of website hosting, maintenance, marketing services, courier services, certification services, business operations, payment services, and identity verification services. These service providers are only given access to your information to the extent necessary to process your information and/or provide services to MIU, and they are prohibited from using or share your information for any other purposes. MIU may disclose limited information about you to Service Providers to serve relevant advertising on third party platforms to you or to other audiences.
Your Employer: We may share your information with your employer, in the event that the employer is paying for your Course. Information disclosed in this case shall include Course performance information, unless otherwise expressly agreed in writing with MIU.
Legal Matters; Safety: We may access or share your information to satisfy any applicable law, regulation, legal process, or governmental request; in connection with an investigation on matters related to public safety; as permitted by law; or otherwise as required by law. We may disclose your information to protect the security of the Course, the Websites, servers, network systems, and databases. We also may disclose your information as necessary if we believe that there has been a violation of our Terms of Use (including investigation of potential violations thereof), any other legal document or contract related to the Websites, or the rights of any third party.
Fraud; Security: We may access and disclose your information to detect, prevent, or otherwise address fraud, security or other technical issues.
Consent; Other: We may share information with third parties when we have your consent, or otherwise as described to you at the point of collection.
Sale or Transfer of Business or Assets: MIU may sell or purchase assets during the normal course of our business. If another entity acquires us or any of our assets, information we have collected about you may be transferred to such entity. In addition, if any bankruptcy or reorganization proceeding is brought by or against us, such information may be considered an asset of ours and may be sold or transferred to third parties. Should such a sale or transfer occur, we will use reasonable efforts to try to require that the transferee use your information in a manner that is consistent with this Privacy Policy.
De-Identified Aggregate or Anonymous Information: MIU may also share de-identified aggregate or anonymous information with third parties for their marketing or analytics uses. For example, we provide Google Analytics with de-identified data so that they may provide us with a better understanding of visitors’ interactions with the Websites, including actions a visitor takes while accessing the Websites or sites to which a visitor navigates after leaving the Websites. Learn more about Google Analytics’ use of de-identified data, and how to opt out of such use with a browser add-on, here.

International Transfers: We transfer personal information from the European Economic Area (“EEA”) to other countries, including the United States and some of which have not been designated by the European Commission as having an adequate level of data protection. In these instances, we use Standard Contractual Clauses to meet the adequacy requirement. Where information is transferred outside the EEA to a third party in a country that is not subject to an adequacy decision by the EU Commission, data is adequately protected by Standard Contractual Clauses, an appropriate Privacy Shield certification or a vendor’s Processor Binding Corporate Rules. A copy of the relevant mechanism can be provided for your review on request to privacy@MIU.education or via our contact page.

Information Security and Data Retention

We are committed to protecting the security of your information. We maintain what we believe to be appropriate physical, electronic, and managerial procedures to safeguard and secure your information and to prevent unauthorized access, maintain accuracy, and ensure appropriate use of your information. The accuracy, safety, and security of your information also depend on you. Where we have given you (or where you have chosen) a password for access to certain parts of the Websites, you are responsible for keeping this password confidential. We ask that you not share your password with anyone. Even though we do our best to protect your information, transmission of information via the internet is not completely secure, and we cannot guarantee our security measures. We are not responsible for any unauthorized access to or acquisition of your information. We will retain your personal information for the length of time needed to fulfil the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.

Your Rights Regarding Your Personal Information

You may access and/or update your personal information through your user profile.

In some instances, you may have the right under applicable law to: (a) ask us for a copy of your personal information; (b) correct, delete or restrict processing of your personal information; and (c) obtain the personal information you provide to us in a structured, machine readable format. In addition, you may have the right under applicable law to object to the processing of your personal information in some circumstances. If you would like to inquire about your right to object to the processing of your personal information for direct marketing purposes, you may contact us at privacy@miu.education.

Your rights regarding your personal information may be limited in certain circumstances, for example, if fulfilling your request would reveal personal information about another person or would infringe the rights of a third party (including our rights), or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. We will inform you of relevant exemptions we rely upon when responding to any request you make.

Our use of certain personal information is necessary for us to provide information to you about the Course or to provide services to you through the Websites or otherwise. If you choose not to provide this personal information or request that MIU delete or restrict the processing of this personal information, you may not be able to participate in the Course, and we may not be able to provide you with other services, including those provided through the Websites or advertised about the Course.

If you believe your rights regarding your personal information have been infringed upon, please contact us as set forth in the “Additional Information” section below. If you are located in the EEA or Switzerland and have unresolved concerns, you also have a right to lodge a complaint with the applicable data protection authorities.

To the extent the above rights apply in your country, they may be limited in some situations, for example, if MIU is under a legal requirement to retain certain information. If you wish to make a request described in this section, or if you are otherwise unable to access and/or edit your personal information through your user profile, you may contact us at privacy@miu.education or use the Data Enquiry Form.

Additional Information

Education Records

You may have specific rights relating to the disclosure of any personal information that you provide to us and/or education records that we may create about you under the Family Education Rights & Privacy Act (“FERPA”), or other relevant law or regulation. You also may have specific rights under FERPA related to accessing and/or updating your personal information. If you would like to inspect and review your education records, you may submit a request by emailing privacy@miu.education. Requests for access under FERPA will receive a response within 45 days, although certain records may be excluded from education records made available for inspection (within the bounds of the law and our confidentiality undertakings with third parties). You may also request amendment of records that you believe are inaccurate, misleading or in violation of your rights.

Public Forums; Publicly Available Content

Any information you may disclose through the Websites, such as on message boards, in chat rooms, or on other public areas on the Websites, may be viewed by others, such as your classmates and learning facilitators. Please exercise caution when disclosing personal information in these public areas. You are responsible for ensuring the accuracy of all information submitted to the Websites, and you agree to only publish or share information about a third party with the third party’s consent.
Your content may be made available, and may be accessed, viewed, stored, collected, or used by other users of the Websites, such as your classmates and learning facilitators, subject to your restrictions and the Terms of Use. If you do not want MIU to store metadata associated with your content, please remove the metadata before uploading your content.

Third-Party Content, Links, and Plug-Ins

The Websites may also offer you the ability to interact with plugins from social media sites, which may allow us and/or the social media site to receive data from or about you, to better understand who is using the Websites, how people are using the Websites, how to improve the effectiveness of the Websites, our services and related content, to help us or those third parties serve more targeted advertising to you across the Internet, and to allow “Like” buttons and “Share” buttons to work. In some cases, we may know that you clicked on a social plugin, such as a Twitter Follow button, or receive other information from the social media sites. Similarly, if you have previously provided personal information to a third party operating a plug-in on our Websites, then such third party may recognize you on our Websites. Your use of social network plugins is subject to each social media site’s privacy policy, which may be different from ours. As with linked websites, we have no control over the information that is collected, stored, or used by social network plugins.

Changes to This Policy

We review our privacy practices from time to time and reserve the right to make changes to this Privacy Policy at any time. If we do make material changes, we will give notice via the Website features or by emailing you. We recommend that you check the contents of the Privacy Policy whenever you have questions about privacy and our use of data, referring to the date of the last amendment listed at the bottom of the Privacy Policy.

Date of Last Amendment: 1st February 2020

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