Privacy Policy

Last Updated: May 11, 2023.

This Privacy Policy (the “Privacy Policy” or the “Policy”) describes the principles and practices that apply to the collection, use, disclosure and protection of Personal Information (defined below) obtained by Holberton Tulsa, LLC (“Holberton”, “we” or “us”) and our affiliates, subsidiaries and partners, as well as the choices and rights individuals have with respect to their Personal Information. “Personal Informaiton” is 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.

Certain states provide for different privacy rights and disclosures. These rights and disclosures are set forth in addenda to this Privacy Policy.

Scope

This Privacy Policy applies to Personal Information we collect from users of our Sites, Apps, Wi-Fi hotspots, and other online services, as well the Personal Information we collect about individuals, including current and prospective students, alumni, learners, visitors to our campuses, and others with whom we interact (e.g., Business-to-Business Representatives, as defined below), whether online, via phone, or offline in the course of providing our courses, programs, and services (collectively, our “Services”).

If you are an employee, contractor, or job applicant, then this Privacy Policy only applies to you when you are using our Services outside of those roles. Certain Services may be subject to additional privacy policies or privacy disclosures relating to the Services provided on the Site(s) (collectively, “Additional Policies”). In the event of a conflict between any Additional Policies and this Privacy Policy, the Additional Policies will take precedence.

Student Educational Records. If you become a student, your educational information that is part of your educational record with us is subject to the U.S. Federal Family Educational Rights and Privacy Act (“FERPA”), state laws, and the University’s policies (collectively, “Student Educational Records Requirements”). In the event of any conflict between Student Educational Records Requirements and this Privacy Policy, the Student Educational Records Requirements will take precedence. Students have the right to limit access to their Student Educational Records and to request a copy of such records, as set forth in the University’s FERPA policy. You may also contact us via one of the below methods:

Mail
Holberton Tulsa
Attn: Registrar
15 N Cheyenne Ave.
Tulsa, Oklahoma 74103

Phone
918-392-5530

Definitions

As used in this Privacy Policy, the following terms have the following meanings:
Anonymized” means information that has been de-identified so that it no longer reasonably identifies, relates to, describes, and is no longer reasonably capable of being associated with, or linked, directly or indirectly, to an individual. Anonymized information is no longer Personal Information.
Apps” means software which may be utilized on our Sites and downloaded to or accessed through our Services.
Business-to-Business Representatives” means agents or representatives of other companies or associations who may be contacted as part of or in relation to our Services.
Education Partners“ means other companies or institutions who may participate in various initiatives (e.g., companies making courses, programs, or other product/service offerings available to their customers, employees, potential employers, institutions conducting academic research or providing academic reporting, etc.).
Service Providers” means entities that Holberton contracts with to provide services on our behalf.
Site” means any website owned or operated by Holberton, which links to or displays this Privacy Policy.
Social Network” or “Social Networking” means various Internet communication technologies provided on the Services as well as on third-party social networking websites such as LinkedIn, Facebook, Twitter, etc., that facilitate conversation and interaction between people online and includes, but is not limited to, blogs, discussion forums, wikis, chat sessions, news groups, etc.
Social Network Content” (or “SNC”) means user-generated content you consent to share via a Social Network and includes, but is not limited to, Personal Information, digital sounds, and pictures that you upload to a Social Network. It also includes your Personal Information that may be displayed on other users’ Social Network pages.

Collection of Personal Information

For the purpose of this Policy, “personal information” or “information” means information that identifies you or could reasonably be associated or linked, directly or indirectly, to you.

We may collect different categories of personal information depending on how you use our Website or interact with us.

Directly Collected Information

We collect Personal Information that you provide to use voluntarily (online or offline), including when you: respond to an advertisement, participate in a survey or a drawing; submit a form on our website; register for an event; request information; apply for admission; enroll in classes; or otherwise interact with us online or offline. The exact nature of the Personal Information may vary depending on the type of response or service requested, but could include name, contact details, date of birth, education history, financial information, employment status, photos, interests, demographic information, and other information.

Automatically Collected Information

The Services may have and use cookies, pixels, third-party tags, scripts, log files and other means to automatically collect information about the use of our Services and services including (but not limited to): device information (type of device, operating system version, unique device identifier, browser type and version, mobile network information);  log information (IP address, smart phone identifier, screen resolution, and referring domain); day of week and time of day; language settings; country, state, city (relating to IP address, if available); domain (.com, .net, .mil, .org, .edu, etc.); web pages viewed; and email clicks or other actions taken. See the “Cookies and Similar Technologies” section below for more information. Automatically collected information may be linked with Personal Information to accomplish the purposes described in this Privacy Policy. In addition, we may use CCTV and other security monitoring to secure our premises, which may lead to the collection of Personal Information about visitors to our campuses. Further, when you call us, we may record calls for quality and training purposes.

Information Collected from Other Sources.

We may also obtain Personal Information from Education Partners, Service Providers, and publicly available sources, which may be combined with other Personal Information we have collected. For example, we may receive Personal Information about you from educational institutions you have attended; financial institutions (related to tuition payment); government entities (related to grants); employers (related to education or career initiatives); third-party platforms or accounts that you connect to or integrate with one or more of our Services; Service providers that we work with to verify, update, or append data to the information that we have otherwise collected about you and to identify prospective students or other individuals who may be interested in our Services.

Use of Personal Information

We use your personal information for several business or commercial purposes, among which:

Administering applications, enrollment, registration, and financial services.

To review and process applications and registrations; to verify the information you provide us, determine your eligibility for admission, register you for selected educational programs, and contact you relating to your academic status, to provide financial services related to tuition payments and financial aid, to maintain student records; and other related purposes

Providing support and services

Communicating with you and answering your requests submitted on our Website or by email; Managing your information and account; Processing applications; Providing access to certain areas, functionalities, and features of our Website; Giving you information about our services, activities and changes in policies; Allowing you to register for events; Access to the intranet

Personalizing content and experiences

To tailor content we send or display on the Services in order to offer personalized help and instruction; to reach you with more relevant ads and measure ad campaign performance

Marketing and promotional purposes

Conducting analytics that will allow us to count ad impressions, verify the positioning and quality of our ad impressions, and audit compliance with our standards; Measuring interest and engagement in our Services and short-term, transient use, such as contextual customization of ads; To administer promotions and contests; to promote our school and the services we offer; to send you newsletters, offers, or other information regarding products or services we think may interest you.

Analyzing and improving our services and operations

To better understand how users access and use the services we offer
Undertaking internal research for technological development and demonstration;
Improving, upgrading or enhancing our Website’s features;
Developing new products or services.

Securing and protecting our assets and rights and preventing misconduct

Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity and prosecuting those responsible for that activity; Debugging to identify and repair errors that may impair existing intended functionality; Undertaking activities to verify the quality or safety of a service or our Website.

Complying with legal obligations

Cooperating with law enforcement and protecting our rights (including free speech), interests, safety or property and those of our customers, service providers and other third parties; Complying with and enforcing applicable legal and regulatory obligations, and responding to governmental requests; Defending against or pursuing claims, disputes, or litigation – in court or elsewhere.

Supporting our general business operations

Support the administration of our general business, accounting, record keeping, and legal functions including to analyze operational and business results and risks, to collect outstanding amounts owed, and to maintain records; Carrying out any other purpose readily apparent to you or described to you at the time the personal information is collected; Enforcing our policies, terms and conditions, or other agreements.

Anonymized Information

We may also de-identify information to create Anonymized data sets and reports in order to assess, improve, and develop our business, products, and Services, among other research and analytics purposes

Disclosure of Personal Information

We try to share your personal information with as few third parties as possible. We may need to disclose your personal information for one of the legitimate purposes disclosed in previous section “Use of Personal information” as follows:

Service Providers

Vendors, consultants and other service providers who need access to such personal information to perform services on our behalf;

Business Partners

with whom we jointly offer products or services; our affiliates and subsidiaries. In connection with, or during negotiations of, any merger, sale of company assets, financing or transfer of all or a portion of our business to another company;

Advertising Partners

to set tracking tools to collect information regarding your activities and your device (e.g., your IP address, mobile identifiers, page(s) visited, location, time of day). We may also combine and share such information and other information (such as demographic information) with third party advertising partners. These advertising partners may use this information together with similar information collected from other websites for purposes of delivering targeted advertisements to you when you visit third party websites within their networks. If you prefer not to share your personal information with third party advertising partners, you may follow the instructions below;

Legal Entities

Government or law enforcement officials or private parties as we, in our reasonable discretion, believe necessary or appropriate to respond to and defend against legal claims, respond to legal process (including a facially valid subpoena, warrant, court order or other legal process), or otherwise as required by law. Please note that we may not be able to notify you of a request for the disclosure of your information as described above, because doing so might be prohibited by law, or because doing so would jeopardize an investigation into illegal or fraudulent activity, or because we do not have your contact information.

FERPA Permitted

We may disclose your Personal Information as permitted under FERPA.

We also may disclose your Personal Information with your consent or at your direction.

Anonymized Data

We may also share aggregated or de-identified information, which cannot reasonably be used to identify you. This aggregated information is used for industry analysis, demographic profiling, and other purposes.

International Transfers

We are based in the U.S. and the information we collect is governed by U.S. law. If you are accessing the Service from outside of the U.S., please be aware that information collected through the Service may be transferred to, processed, stored, and used in the U.S. and other jurisdictions. Data protection laws in the U.S. and other jurisdictions may be different from those of your country of residence. Your use of the Website or provision of any information therefore constitutes your consent to the transfer to and from, processing, usage, sharing, and storage of information about you in the U.S. and other jurisdictions as set out in this Policy.

Cookies and Similar Technologies

We use cookies, pixels, tags, local storage objects (also called Flash cookies), web beacons, and other technologies (which may be provided by third parties) on our Services to enable certain functionality on our Services; for security and fraud detection and prevention; to collect usage information about our Services and the emails that we send; and to personalize content and provide more relevant ads and information. We may combine the information we collect via these technologies with other information that we collect, including Personal Information.

Cookies.

We may send some cookies to your computer. This allows us to uniquely identify your browser and lets us help you log in faster and enhance your navigation through the Website. Cookies also help us understand what information is of interest to you and improve your navigation and our services. Cookies are alphanumeric identifiers that are transferred to your computer through your web browser for record-keeping purposes. Some cookies enable you to log in to our Services or save certain settings and preferences, while others allow us to identify usage and activities on our Services, personalize content on our Services, or deliver more relevant ads on third-party websites.
Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help tab on the toolbar of most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. If you disable cookies, however, certain features may not be available or function properly.

Pixel tags and embedded script (also called clear GIFs and web beacons).

Our Website may also use tags to monitor the traffic patterns of users from one page within our Website to another, to deliver or communicate with cookies, to understand whether you have come to our Website from an online advertisement displayed on a third-party website, and to improve Website performance. We also may allow our service providers to use tags to analyze visitor traffic and actions on our Website and to help us understand which pages are more attractive to Users, or which emails have been opened by recipients. This helps us measure the effectiveness of our content and other offerings.
We may also use Google Analytics, Facebook Ads conversion tracking (Facebook pixel) and Google Ads conversion tracking that collect information through cookies and your usage data, in order to analyze visitors behavior and demographics. For more information:
About Google Analytics: please visit www.google.com/policies/privacy/partners/.
About Facebook Ads: please visit https://www.facebook.com/privacy/explanation.

Local Storage Objects (LSOs)

LSOs are data files that are stored locally in your browser by the websites you visit. LSOs can be used in a similar manner as cookies for a variety of purposes, such as keeping track of information you provided and remembering your preferences. Our Services may include LSOs used to track applicant progress through the admissions process.

Do-Not-Track Signals

Do-Not-Track (DNT) is a browser-based signal that, when set, signifies your desire not to be tracked online. For more information about DNT signals, please click here. Our Services may not respond to all web browser based DNT signals. Some browsers and browser extensions support the Global Privacy Control (“GPC”) that can send a signal to the websites you visit indicating your choice to opt-out from certain types of data processing, including data sales.

Information collected through third parties

Your interaction with external social networks and platforms such as Twitter, LinkedIn or Facebook through their respective “Tweet” or “Like” buttons and social widgets may also cause such third parties to pass certain information about your use of their service(s) to us. This information may include cookies and usage data.

Interest-Based Advertising

We may work with Service Providers (including, but not limited to, Microsoft, Google, LinkedIn, and Facebook) to display advertising on our Sites or to manage our advertising on other websites. These third-party networks and platforms use cookies, pixel tags, and other technologies to collect information about your activities on our Services and other websites over time to provide you targeted advertising based upon your interests. Some ads are targeted to your interests and preferences, based on your browsing history and other information. Your browsing history may be followed in these cookies even if ads are not being displayed.

Individual Rights and Choices

In this section, we describe your rights and choices regarding our use and disclosure of your Personal Information.

Marketing Communications.

You may opt out of receiving marketing communications from us here. Additionally, you may follow the opt-out instructions in the footer of any marketing email we send or inform us of your decision to opt-out while on a call with us. Opt-out requests will only remove you from our marketing list, not from the list of any other third parties. You can opt out by submitting this form.

Cookies and Similar Technologies.

Using our Preference Center, you can opt out of or change your preferences for most third-party cookies and tags on our Sites, except those that are “necessary” to the proper functioning of our Sites or particular features available to you on our Sites. In addition, you may block or disable cookies for the device and browser you are using through your browser settings; however, if you do so, certain features on our Sites may not be available or function properly.

Children’s Information

Our Service is generally not directed at children under the age of 16 and we do not knowingly collect or solicit personal information (as defined by the U.S. Children’s Privacy Protection Act, or “COPPA”) from anyone under the age of 13 in a manner not permitted by COPPA. If you are a parent or guardian and you believe we have collected information from your child in a manner not permitted by law, please contact via one of the methods listed in the “Contact Us” Section below. We will remove the data to the extent required by applicable law.

Security Measures

We have implemented security measures to protect against the loss, misuse, and alteration of the Personal Information under our control. However, no data transmission over the Internet can be guaranteed to be completely secure. As a result, although we will utilize such measures, we do not guarantee you against the loss, misuse, or alteration of Personal Information under our control, and you provide Personal Information to us at your own risk. You should always take care how you handle and disclose your Personal Information and should avoid sending Personal Information through insecure email, Social Networks, or other Internet channels.

Monitoring of Communications & Data Retention

We may monitor, record, and retain all incoming and outgoing communications for training of our representatives, for quality assurance purposes, as necessary for our records retention policy, and as required for legal purposes.
Our retention periods for personal information are based on business needs and legal requirements. We retain personal information for as long as is necessary for the processing purpose(s) for which the personal information was collected and any other permissible, related purpose.

Third-party Websites and Links

The Services may, from time to time, contain links to and from websites, platforms, and other services not operated or controlled by us. If you follow a link to any of these locations, please note that these locations have their own privacy policies and that we do not accept any responsibility or liability for their policies. Please check the individual policies before you submit any information to those locations. We are not responsible for the privacy practices or the content of any websites or services that are not operated by or exclusively for us, and the collection, use, and disclosure of Personal Information about you will be subject to the policies applicable on those websites.

Privacy Policy Changes

We reserve the right to modify or update this Privacy Policy from time to time to reflect the changes in our business and practices, and so you should review this page periodically. When we change the policy we will reflect the ‘last modified’ date at the top of this Privacy Policy.

Contact Us

Should you have any questions about our privacy practices, please contact us at tul-legal@holbertonschool.com or by mail.

Mail
Holberton Tulsa
Attn: Ethics, Compliance, and Data Privacy
15 N Cheyenne Ave
Tulsa, Oklahoma 74103

Additional Disclosures for California Residents

CCPA

California Consumer Privacy Act or “CCPA” (California Civil Code Section 1798.100 et seq) grants specific rights to consumers who reside in California. If you are a California resident, please read this section for additional disclosures and information on rights you may have under California law. Terms used in this section and not defined have the meaning given in the CCPA.

Personal Information Collected, Disclosed, or Sold In the past 12 months:

We may have collected information listed under the section “Collection of Personal Information” of this Policy, for the purposes detailed under section “Use of Personal Information”.
We may have disclosed the personal information to a limited number of third parties. For more information about such disclosure, please refer to the section “Disclosure of Personal Information” of this Policy.

Your Rights

California residents have the right to request:

More information about the categories and specific pieces of personal information we have collected, sold and disclosed for a business purpose in the last 12 months, and Deletion of their personal information.

You may make these requests by calling 918-392-5530 or sending an email at tul-legal@holbertonschool.com. We may request that you provide additional information regarding yourself in order to verify your identity.

Sale or Sharing of Personal Information

While we do not disclose Personal Information to third parties in exchange for monetary compensation, we do disclose or make available Personal Information to third parties in order to receive certain services or benefits from them, such as when we allow third-party tags to collect information such as your browsing history when using our Services, in order to improve and measure our ad campaigns. California law may consider these activities to be the “sale” or “sharing” of Personal Information for cross-contextual behavioral advertising.

The categories of Personal Information that we may “sell” or “share” as defined under California law include:

Name, contact information, and other identifiers
Customer records
Protected classifications
Internet or other electronic network activity information
Geolocation data
Education information
Inferences drawn from any of above
We do not have any actual knowledge that we have sold or shared Personal Information of any consumer under the age of 16.

Sensitive Personal Information

We do not use Sensitive Personal Information for any purpose other than that reasonably anticipated to accomplish the purpose for which it is collected.

Retention

For each category of Personal Information collected, we only retain such Personal Information for as long as necessary to fulfill the purposes outlined in this Privacy Policy and as otherwise needed to address tax, corporate, compliance, litigation, and other legal rights and obligations.

Authorized agent

If you would like to use an authorized agent registered with the California Secretary of State to exercise your rights, we may request evidence that you have provided such agent with power of attorney or that the agent otherwise has valid written authority to submit requests on your behalf.

Individual Rights Under California Law

California law grants California consumers certain rights and imposes restrictions on businesses as set forth below. If you are a resident of California, you have the following rights:

Do Not Sell or Share

The right to opt out of the “sale” or “sharing” of your Personal Information (as those terms are defined in the CCPA).

Right to Opt-Out

To the extent Holberton sells your personal information as the term “sell” is defined under the California Consumer Privacy Act, you have the right to opt-out of the sale of your personal information by us to third parties at any time. You may submit a request to opt-out by clicking Do Not Sell My Personal Information. You may also submit a request to opt-out by contacting us at tul-legal@holbertonschool.com.

Verifiable Requests to Delete, Requests to Know, and Requests for Correction

Subject to certain exceptions, California residents have the right to make the following requests at no charge:

Request to Delete

The right to request deletion of their Personal Information we have collected and to have such Personal Information deleted, except where an exemption applies.

Request to Know

The right to request and, subject to certain exemptions, receive a copy of the specific pieces of Personal Information that we have collected about them and to have this delivered, free of charge, either (a) by mail or (b) electronically in a portable and, to the extent technically feasible, readily useable format that allows the individual to transmit this information to another entity without hindrance.

California residents also have the right to request that we provide them certain information about how we have handled their Personal Information, including the:
Categories of Personal Information collected;
Categories of sources of Personal Information;
Business and/or commercial purposes for collecting, selling, or sharing their Personal Information;
Categories of third parties with whom we have disclosed or shared their Personal Information;
Categories of Personal Information that we have disclosed or shared with a third party for a business purpose;
Categories of third parties to whom their Personal Information has been sold and the specific categories of Personal Information sold to each category of third party.

Request to Correct

The right to request that we correct inaccurate Personal Information.
Submitting a Verifiable Request

You may submit your verifiable request through channels outlined in “Contact Us”.

Who May Exercise Your Rights

You may make a request to exercise the above rights on behalf of yourself or on behalf of a minor if you are the parent or legal guardian of the minor. In addition, you may authorize an agent to exercise your rights on your behalf, if you provide the agent with written signed permission.

Verification of Your Request

Once we receive your request, we will contact you to confirm receipt of your request, unless your request is a “Do Not Sell or Share My Personal Information” request submitted through our automated processes. We will require sufficient information from you in order to verify your identity and the authenticity of your request. If you do not provide us with sufficient information, we may request additional information to verify your identity, the identity of the data subject of the request, and the authenticity of the request. Certain types of requests may require additional verification, as we are subject to higher standards of authentication for such requests.

If an authorized agent contacts us to exercise the above rights, we will need to verify their identity as well as your identity. We will also require proof of your written authorization to the agent to act on your behalf, unless the agent holds a lawful Power of Attorney under applicable laws, in which case we will require evidence of such Power of Attorney.

We may deny your request as permitted or as required by law. We may charge a fee to process or respond to your request if it is excessive, repetitive, or manifestly unfounded.

Right to Non-Discrimination

You also have the right to not receive discriminatory treatment if you elect to exercise the above rights.

Shine the Light

Residents of California may request (i) a list of the categories of personal information disclosed by us to third parties during the immediately preceding calendar year for those third parties’ own direct marketing purposes; and (ii) a list of the categories of third parties to whom we disclose such information.

To exercise a request, please write to us at the email or postal address set out in “Contact Us” above and specify that you are making a “California Shine the Light Request.” We may require additional information from you to allow us to verify your identity and are only required to respond to requests once during any calendar year.

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Learn More About Holberton

We strive to create an open, welcoming, and transparent community where students, faculty, and staff can thrive and be themselves. Find out more about Holberton below.

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