Last updated January 2, 2018
Information We Collect About You
Our Use Of Your Information
Sharing Your Information
Cookies and Other Tracking Devices
Notice To Persons Residing Outside of The United States - Where We Store and Transfer Your Personal Information
Access Rights and Correction
User Generated Content
The Family Educational Rights and Privacy Act ("FERPA")
Purposes, Legal Basis and Retention Term
Disclosure and Transfers
Student Video and Audio Monitoring
Storage, Transfer, and Disclosure of Information
Your Rights, Questions, and Complaints
Information We Collect Directly From You: We collect information, including personal information, directly from you when you create an account with us, sign up for our online classes, request information from us, purchase products from us, and otherwise interact with our Site and our Services. The type of information that we collect from you varies based on your particular interaction with our Site, but may include: your name, email address, home / mailing address, telephone number, and, where applicable, payment information, and information relevant to your educational history, among other information. Please note that your educational account may not be used for certain purchases/other purposes on our Site, and you may be requested to create a secondary account.
Third Parties. On our Site, you may email a friend about Services that you believe would be of interest. We will collect your name, email address, as well as your friend’s name and email address. We use the information collected from you to complete your request, but we will not use that information for future marketing efforts.
Information We Collect Automatically:
- Through our Mobile Applications:
- GIA 4Cs Guide for iPhone and iPad (English and Simplified Chinese): To provide the highest quality experience, GIA collects anonymous information about usage of our mobile applications. If you prefer not to participate in Flurry Analytics, our analytics data collection service, please follow the instructions provided at www.flurry.com to opt-out.
- Gems & Gemology for iPad: GIA uses Google Analytics to collect anonymous information about the use of the Gems & Gemology iPad application (app). This tool helps us to identify any recurring technical issues and to provide the most user-friendly experience to our readers. The only method for preventing Google Analytics from capturing your usage is to disable the internet connection on your device while reading the content. This method may, however, adversely affect the performance of the app and prevent it from functioning as expected.
We use the information that we collect about you:
- To provide you with requested products and Services, including participation in our online learning program, to respond to your inquiries, and for other customer services purposes;
- To enhance your experience using the GIA Site;
- For marketing and advertising purposes, such as to send you emails about products and services that we believe would be of interest to you;
- To communicate with you about your enrollment, including notifying you of upcoming classes that we believe would be of interest to you;
- To solicit donations;
- For research purposes;
- To better understand how users access and use our Site and our Services, both on an aggregated and on an individualized basis;
- To improve our Site and Services; and
- To further your relationship with GIA.
GIA may enhance or merge your Personal Information with data from third parties for purposes of marketing GIA’s products or services to you.
We will not disclose your personal information with non-affiliated third parties for their own marketing purposes. We will, however, share your information, including personal information (collectively, “information”), to assist us in providing our Services to you and with the persons and for the purposes described below:
Special Notice to Students. If you participate in our online learning, we offer an opportunity for students to communicate with one another. Certain information that you post as part of that program will be available to other students and our faculty.
- Service Providers. We may disclose the information that we collect about you to third party vendors, service providers, contractors, professional advisors or agents that perform functions on our behalf (together "service providers"). These service providers are contractually required to protect your information.
- Affiliated Entities. We will share your information among our affiliated entities, as applicable, to facilitate your experience with GIA. For example, if you are enrolled in our online learning, then we will share your information with our affiliates located in the country in which you reside (if applicable), and/or with our affiliates that may be able to offer courses that are appropriate to your education. Where permitted by law, and unless you have requested otherwise, from time to time, our affiliates may send you email and/or postal mail regarding products and services (including courses and events) that they believe would be of interest to you based on your course of study.
- Business Transfers. If we are acquired by or merge with another entity, if substantially all of our assets are transferred to another company, or as part of a bankruptcy proceeding, we may transfer the information we have collected from you to the acquiring entity.
- In Response to Legal Process. We also may disclose the information we collect from you to comply with the law, a judicial proceeding, court order or other legal process, such as in response to a subpoena.
Aggregate and Anonymized Information. We may share aggregate or anonymized information about users with third parties for marketing, advertising, research or similar purposes.
We may periodically send you electronic communications about GIA’s various products, services, newsletters or general updates. You may opt-out of some or all of these communications by using “unsubscribe” options or by sending a request to firstname.lastname@example.org. If you opt out of receiving marketing communications from us, please note that we will continue to communicate with you via email regarding your ongoing education and for customer service related purposes (e.g., to notify you about the status of a purchase that you have made with us).
Your online transactions with GIA are designed to give you options concerning the privacy of your credit card information and any other personal information you provide. GIA is committed to data security with respect to Personal Information collected on our Site. If you would like to make a purchase, but do not want to provide your credit card information online, you may contact a GIA representative over the telephone.
Web cookies, web beacons (including clear GIFs), Flash LSOs, and similar technologies are used to track user activity and collect Site and mobile application data. We may combine this data with the personal information we have collected from you.
Your Consent. By continuing to use our Site, you are agreeing to our placing cookies on your computer or electronic portable device in order to analyse the way you use our Site. Please read this cookie section carefully for more details about the information we collect when you use this Site.
If you do not wish to accept cookies in connection with your use of this Site, you must stop using our Site.
Cookies. Cookies allow a web server to transfer data to a computer for record keeping and other purposes. We and our third party service providers use “cookies” on our Site and similar devices designed for mobile applications, to, among other things, better serve you with tailored information and facilitate your ongoing access to and use of the Site. There are two types of cookies: session-based and persistent cookies.
- Session Cookies. Session cookies exist only during an online session. They disappear from your computer when you close your browser or turn off your computer. We use session cookies to allow our systems to uniquely identify you during a session or while you are logged in to the Site. This allows us to process your online transactions and requests and verify your identity, after you have logged in, as you move through our Site.
- Persistent cookies. Persistent cookies remain on your computer after you have closed your browser or turned off your computer. We use persistent cookies to track aggregate and statistical information about user activity, which may be combined with other user information.
Disabling Cookies. Most web browsers automatically accept cookies, but if you prefer you can edit your browser options to block them in future. The Help portion of the toolbar on 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. Visitors to our Site who disable their web browsers’ ability to accept cookies will be able to browse the Site; however, many site features, such as the shopping cart will not function if you disable cookies.
Local Storage Objects. We may use Flash Local Storage Objects (“Flash LSOs”) in order to store your Site preferences and to support individual applications. Flash LSOs are different from browser cookies because of the amount and type of data stored. In addition, you cannot control, delete or disable the acceptance of Flash LSOs through your browser. For more information on Flash LSOs, or to learn how to manage your settings for Flash cookies, go to the Adobe Flash Player Help Page, choose “Global Storage Settings Panel” and follow the instructions. To see the Flash LSOs currently on your computer, choose “Website Storage Settings Panel” and follow the instructions to review and, if you choose, to delete any specific Flash LSO.
Web Beacons, Pixel Tags and Other Technologies. Our third party service providers use web beacons in HTML e-mails to our customers, to help us track e-mail response rates, measure the success of our marketing campaigns, identify when our e-mails are viewed and track whether our e-mails are forwarded.
Site Analytics. We work with third party service providers who use the technologies described in this section to conduct website analytics to help us track and understand how visitors use our Site and our mobile application. For example, we use a variety of third party web analytics, to help us improve our Site and mobile application’s performance and user experiences.
To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.aboutcookies.org or www.allaboutcookies.org.
Aside from the GemKids area of the site which is designed for minors and never asks for personal data, all other areas of the website are intended for users over the age of 18. GIA is committed to protecting the privacy of minors under 18 years of age. We do not knowingly collect personal data from minors. If we become aware that a child has submitted personal information to us through any part of the site, we delete such personal information as soon as reasonably practical after we discover it.
NOTICE TO PERSONS RESIDING OUTSIDE OF THE UNITED STATES - WHERE WE STORE AND TRANSFER YOUR PERSONAL INFORMATION
We may transfer the information that we collect about you, including your personal information, whether collected through this Site, mobile application, or in person to locations worldwide, such as in each country in which GIA has an office. We also may transfer customer information to a third party service provider, which may use a cloud solution and store data in a country outside of your country of origin, such as in the United States. Please note that your information may be subject to access by law enforcement and other government entities, including courts and tribunals in accordance with laws applicable in those jurisdictions. GIA (and its affiliated entities) have procedures in place designed to safeguard your information.
GIA will take reasonable steps to ensure the personal information it holds is accurate, complete and up to date. Please ensure you check your account regularly to ensure that we hold accurate personal information about you.
You have the right to access and correct certain information that we hold about you. Any access request must be made in writing and where permitted by law, may be subject to a small fee to meet our costs in providing you with the details of the information that we hold about you. Please send any requests for access, questions, or comments regarding our privacy practices to the contact listed below.
Certain portions of our Site may permit user generated content, such as blogs and forums. Any information that you post to a publicly facing blog or forum may be viewable by other visitors to our Site. Information that you submit through our student/educational blogs, will be available by other registered users of those services, at a minimum. We are not responsible for the privacy of any information that you choose to post to our Site, or for the accuracy of any information contained in those postings. Any information that you disclose becomes public information. We cannot prevent such information from being used in a manner that may violate this Policy, the law or your personal privacy.
The controller of your personal data is GIA, Inc., The Robert Mouawad Campus, 5345 Armada Drive, Carlsbad, CA 92008 USA and the GIA Campus Location to which you are enrolled ("GIA"). Contact details may be found on the GIA List of Data Controllers. You have related rights under Family Educational Rights and Privacy Act (“FERPA”) as described below.
The Family Educational Rights and Privacy Act (FERPA) provides students with certain rights with respect to their education records. All student records are kept in accordance with the provisions of FERPA. Education records include all files, records and documents that contain information directly related to a student’s academic and financial records, placement files and financial aid documents. Transcript information is retained permanently, and other signed documents and specific records are retained according to applicable state and federal regulations.
GIA will not release any student-specific financial aid information to a third party without the student’s permission.
Students may authorize GIA to provide their information to a third party by signing a Consent Form for Disclosure of Student Education Records at our offices.
It is GIA’s policy to release the following directory information to a requesting party upon receipt of a completed Education Verification Form: student name, fields of study; dates of enrollment; degrees, diplomas, and certificates awarded and dates conferred; and academic honors and awards received unless the student has opted out of the release of their directory information. The can be filled out and submitted to the Education Records department at email@example.com.
Students have the right to request that their directory information not be released. Such requests must be submitted in writing to the manager of education records within 30 days of enrollment or within 30 days of receiving notification of this policy. This request remains in place until rescinded in writing by the student.
GIA may disclose personally identifiable information from an education record to appropriate parties, including parents of an eligible student, in connection with an emergency if knowledge of the information is necessary to protect the health or safety of the student or other individuals.
Students may examine their own records by submitting a written request to the manager of education records, who will schedule an appointment with them to view their education records within 45 days of receiving the request.
Students who believe their records are inaccurate, misleading, or violate their privacy may submit a written request to the manager of education records that their record be amended. If the record is not amended, the student may request a hearing to challenge the contents of the record. The student will be informed, in writing, of the decision resulting from the hearing. If the record is not amended as a result of the hearing, the student has the right to place a statement in his or her record commenting on the contested information in the record or stating why he or she disagrees with the decision of the hearing. The student may also submit a written complaint to the Family Policy Compliance Office, U.S. Department of Education, 400 Maryland Avenue, SW, Washington, DC 20202-4605 USA.
Personal Data that may be collected and used about you may include student name; (email) address, phone number and further contact information; details about your enrollment, such as fields of study, dates of enrollment, degrees, diplomas, certificates awarded, dates conferred, academic honors and awards received; financial and payment records; electronic video and audio monitoring records. Providing your Personal Data is voluntary. Please note, however, that without your personal data, we may be unable to provide you with the information and services described in this Policy.
GIA may use the above Personal Data to provide you with education and related services you requested from us on the basis of the performance of our contract with you. We will retain your Personal Data for as long as it is required for purposes for which it was collected. This will be, for example, for as long as necessary in view of the student relationship until the end thereof, plus the length of any applicable statutory limitation period. Furthermore, we may use your Personal Data for security and emergency purposes and to monitor compliance with our existing policies and procedures. We do so on the basis of for compliance with a legal obligation or for our legitimate interests to protect our business, locations, workers and other parties. This data will be retained as long as necessary in view of our legal obligations and legal claims, plus the length of any applicable statutory limitation period. Also, data may be used for direct marketing purposes on the basis of our legitimate interests in keeping you updated about news, offers and related communications, or on the basis of your consent. This data will be retained until you withdraw your consent or opt-out from receiving these communications as described below. We may notify you from time to time if we change the purposes of the use of your Personal Data.
For the purposes described above, your personal data may be accessible by authorized employees of GIA, Inc., GIA-affiliated entities and your GIA Campus Location and service providers acting on our behalf on a need-to-know basis. Also, your Personal Data may be disclosed to law enforcement bodies where required in view of the above purposes. Such access and disclosures may involve transfer of your personal data outside your home country to third countries that do not provide for an adequate level of protection, such as the United States. Where legally required, we use transfer arrangements on the basis of standard data protection clauses adopted by the EU Commission, of which you may request a copy via firstname.lastname@example.org as from 25 May 2018.
Subject to the conditions set forth in applicable law, you may access, update, correct and/or request removal of your Personal Data from our databases and you may request that we restrict the processing of your Personal Data; you may object to the processing of your Personal Data where we rely on our legitimate interests; where we rely on your consent for the use of your Personal Data, you may withdraw your consent at any time; and lastly, you may request that we provide your Personal Data in machine readable format where applicable law requires us to do so. Note that some of these rights only apply as from 25 May 2018. Please see below our contact details for exercising these rights.
Due to the nature of its business, GIA must ensure the integrity and security of its premises and processes, including but not limited to customer service and the handling of valuable customer property. Accordingly, GIA uses both electronic video and audio monitoring in the workplace. The monitored content may include students’ personal data, including without limitation video recordings, audio recordings, footage and photographs of students, casual communications near these locations, and name or any other personal data revealed in video or audio recordings. We do so on the basis of compliance with a legal obligation or for our legitimate interests to protect our business, locations, workers and other parties. Students should not have an expectation of privacy in any public or work areas (GIA does not monitor restrooms or dressing areas). Each facility has signage posted in the locations where video and audio monitoring is/are occurring.
The recorded information of video and audio monitoring will be handled and retained in accordance with legal obligations. GIA will retain recorded information only for as long as reasonably necessary for the uses described above and no longer than the extent permitted by applicable law. Recordings may be disclosed to law enforcement, GIA-affiliated entities (see attached), and other third parties (e.g., to a court of law), as necessary for the purposes described above. Such disclosures may result in the transfer of recorded information outside your home country in connection. GIA may store recorded information in the United States for the purposes above. We may also transfer your recorded information outside your home country to the jurisdictions in which the parties noted above are located, which countries may not have the same level of data protection as in your home country. Where legally required, we use transfer arrangements on the basis of standard data protection clauses adopted by the EU Commission, of which you may request a copy via email@example.com as from 25 May 2018.
In accordance with applicable law, GIA reserves the right to expand its use of video and audio monitoring on its premises, if necessary. Where legally required, you will be informed thereof in advance. If you have any questions regarding this Policy or if you wish to exercise your rights regarding your Personal Data as described, please contact firstname.lastname@example.org. In addition, to object receiving our marketing communications, you can use the unsubscribe link inserted in our communications at any time. You also have the right to lodge a complaint with a supervisory authority if you consider that our use of your personal data infringes this Policy or applicable law.
If you would like to contact us for any reason regarding our privacy practices, please write to the following address:
Gemological Institute of America
The Robert Mouawad Campus
5345 Armada Drive
Carlsbad, CA 92008
You may submit your request concerning your Personal Information by sending it to the above address or email email@example.com.
©2017 Gemological Institute of America Inc.