Privacy Policy
THE CHRONICLE OF HIGHER EDUCATION PRIVACY POLICY
Last updated on January 7, 2020
The Chronicle of Higher Education Inc. (“The Chronicle”) values your privacy.
This Privacy Policy ("Policy") describes how The Chronicle and its affiliates (individually Chronicle or collectively "we" or "our") collects, uses, and discloses information that we obtain about you and the services available through our Sites (chronicle.com, community.chronicle.com, aldaily.com, and philanthropy.com and their associated subdomains), as well all other instances during which we collect personal information while performing Business Services (collectively, "Chronicle Services" or "our Services").
Through our Services, we collect information from individuals on their own behalf, and, in certain scenarios, as representatives of an educational institution. Unless we note otherwise, this Policy applies to the information that we collect from all users of our Services, including individuals submitting information on behalf of an educational institution.
By visiting our Sites, or using any of our Services, you agree that your personal information will be handled as described in this Policy. If you do not agree with our policies and practices, you may choose not to use our Services. Your use of our Services, and any dispute over privacy, is subject to this Policy and our User Agreement incorporated by reference into this Policy.
We do not actively market to anyone under 18. If you are under 18 and have provided us with your information, you may contact us to opt-out of our Services and have your information deleted.
NOTICE TO CALIFORNIA RESIDENTS: This notice provides additional information and privacy options for California residents. Learn more about your options here.
1. What Information Do We Collect About You?
We collect information directly from you, automatically as you use our Services, and, in certain situations, from third parties. The type of information that we collect varies based on the particular Site that you visit and your use of our Services. If you do not consent to the collection, use, or sharing of this type of information in the manner described in the Privacy Policy, please do not provide us with such information. By providing such information, you are "opting in" to the collection, use, and sharing of this information in accordance with this Policy.
Information You Provide through our Services. We and our service providers will collect any information that you choose to provide directly through our Services. The information collected will vary but may include your name, email address, postal address, telephone number, password, payment and billing information, geographic location, profession, job history, job title and function, organization, communications, and content preferences. This information may be collected when you:
- Create an account. We require you to create an account to access certain areas, features, or products of our Sites.
- Fill out a promotional form. We may require you to fill out a form to access content, register for events, or to request information. The information we collect in the form depends on the promotion.
- Purchase or access products and services. This includes subscriptions to our digital or printed publications, newsletters and job alerts, or access to paid products or services.
- Contests and special offers. On occasion, The Chronicle collects personal information from users in connection with optional contests or special offers.
- Apply for a job through our job board.
- Complete user and market research surveys. In voluntary surveys, The Chronicle may collect personal information such as location, age, gender, or employment information. You have the right to decline to participate in any survey.
- Choose to share your personal information, like providing your business card.
- Submit content. You may post, upload, comment, or otherwise submit a comment, photo, file, document, story idea, or other content. (See "Managing Your User-Generated Content" for more.)
Information We Collect From You About Third Parties. We may collect information about you from:
- Our partners.
- Publicly available data.
- Privately-held marketing or data analytics resources.
- Other users. For example, Chronicle Community users may upload their contact list to our Site.
Information We Collect Automatically. The Chronicle and our service providers automatically collect information about your device and your use of our Services. We use cookies, web beacons, pixel tags, access logs and other tracking technologies to collect the following information about you:
- Domain name of your service provider
- Browser type and operating system
- Internet Protocol address (IP address) of your devices
- Geographic location
- The web page that led you to our Site (referring URL)
- Dates, times, duration, and frequency of your interactions with our Sites and Services
- Interactions with our email messages (including information about the devices used to access these messages.)
We do not respond to web-browser “do not track” signals or other mechanisms that might enable consumers to opt out of tracking on our Site. As discussed below, you may opt out of tracking by third-party network advertisers. Please see the sections “Our Use of Cookies and Other Tracking Mechanisms” and “Advertising/Third-Party Ad Networks and Online Tracking” for additional information.
Third-Party Analytics. We use third-party service providers, including Inspectlet, Google Analytics, and other companies, to evaluate and analyze the activities of visitors to our Sites, including the use of our Services. We use analytics to help us improve our Sites and our Services, including improving the performance and experience users have on our Sites. These third-party service providers will use cookies and other tracking technologies to conduct the analytics. One of our analytics providers, Inspectlet, will have access to personal information that you submit through this Site. Inspectlet's access to and use of your personal information is governed by its privacy policy, at https://www.inspectlet.com/legal#privacy.
Third-Party Links. Our Services may contain links to third-party websites. Any access to and use of such linked websites is not governed by this Policy but instead is governed by the privacy policies of those third-party websites. We are not responsible for the information practices of such third-party websites.
We may ask you to provide other personal information but will disclose the purpose at the time of collection.
2. How We Use the Information We Collect
We may use the information collected about you (directly, automatically, or by third parties) to:
- Provide access to our Services or fulfill orders.
- Communicate updates or notices to our Services, respond to your inquires, or other customer service purposes. You may be asked to confirm your profile or account, receive reminders about your profile or account, or other types of updates. When we communicate with you, we may contact you using your email address or phone number, your Chronicle Community inbox, or by other means available through our Services.
- Personalize your services. We may use your information to tailor content, offer personalized help and instructions, and to otherwise customize your experience while using our Services.
- Notify you based on your preferences. Depending on your selected preferences, notifications may include employment opportunities, advertising opportunities, newsletters or job alerts, marketing or promotional messages, or other relevant messages.
- Conduct marketing and promotions.
- Recognize you as the same user as you access our Services using different computers, devices, and browsers.
- Generate aggregate information that does not directly identify you as an individual or the devices you use.
- Administer, manage, or improve our Services.
We may use the information collected from you in other ways but will disclose the purpose at the time of collection or otherwise obtain your consent.
3. How We Share Your Information.
We may share the information that we collect about you, including your personal information (collectively, "information") with:
- Affiliates. We may disclose the information we collect from you to our affiliates or subsidiaries; however, if we do so, their use and disclosure of your personal information will be subject to this Policy.
- Service Providers. We may disclose the information we collect from you to third-party vendors, service providers, contractors, or agents who perform functions on our behalf.
- Non-affiliated third parties. We may share your information with other parties if we have disclosed this to you at the time of collection of the information or if we otherwise have your consent. If you are a subscriber, we share your mailing addresses with selected partners for marketing purposes. You may opt out of any such marketing by contacting us at: help@chronicle.com. If you are a California resident, please see the Special Notice to California Consumers below.
- In response to legal process. We also may disclose the information we collect from you in order to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a court order or a subpoena.
- In cases of potential illegality or policy violations. We also may disclose the information we collect from you when we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our User Agreement or this Policy, or as evidence in litigation in which we are involved.
- Aggregate and de-identified information. We may share aggregate or de-identified information about users with third parties for marketing, advertising, research, or similar purposes.
- Business transfers. If we are acquired by or merged with another company, if substantially all of our assets pertaining to services provided on a Chronicle website are transferred to another company, or become part of a bankruptcy proceeding, we may transfer the information we have collected from you to the other company.
Be aware that any information that you post to our Sites, including, without limitation, reviews, comments, and text, will be available to, and searchable by, all users of the Sites. Some of our websites, such as Chronicle Community, enable you to limit your privacy settings. The public availability of information will be based on the privacy settings that you establish.
In addition to the disclosures described above, information from your Chronicle Community profile will be visible to:
- Other Chronicle Community users. Unless you choose otherwise, your User Profile in its entirety will be available to all other members of Chronicle Community. Your username and any information that you post will be available to, and searchable by, all Chronicle Community users, to the extent that you have chosen to make your information public.
- Academic institutions and recruiters. If you “follow” an institution, express an interest in learning about career opportunities or research opportunities, or about other things we view as reasonably consistent with your expressed interests, we may share your information, including your User Profile, with academic institutions and recruiters (as applicable).
- Employment applications. If you apply for an open position posted on Chronicle Jobs, we will provide the employment materials that you select to the recruiter, educational institution, or other entity that is involved in the hiring process, as is applicable based on the particular posting. Additionally, some educational institutions (and/or the companies that the institution may use to manage applications through a hosted applicant or other tracking system) may offer you the option to upload certain application information (such as contact information, education, experience, or other sections from your profile), by using Chronicle Jobs.
- Letters of recommendation. The Family Educational Rights and Privacy Act (FERPA) affords eligible students certain rights with respect to their education records, including the right to provide written consent before the educational institution discloses personal information from the student’s education records. In addition, the student has a right to read a letter of recommendation containing such personal information provided by a representative of an educational institution. If you are a student or otherwise qualify under FERPA, you understand and acknowledge that by requesting a letter of recommendation or otherwise using the Services to secure employment your information may be transferred to the prospective employer. You understand and agree that The Chronicle cannot be responsible for the subsequent distribution of this information by the recruiter, educational institution, or other entity other than to provide the information for the stated purpose. You are consenting to the disclosure of any information contained in your education record, and to waive the right to read the letter of recommendation.
4. Our Use of Cookies and Other Tracking Mechanisms.
We use cookies and other tracking mechanisms to track information about your use of our Sites. Cookies are alphanumeric identifiers that we transfer to your computer's hard drive through your web browser for record-keeping purposes.
We use these technologies to recognize you and to provide personalization, as well as to help us understand which parts of our Sites are the most popular, where our visitors are going, and how much time they spend there. We also use cookies to ensure that your browser does not see the same advertisement repeatedly, to present ads in a series or sequence, and to measure the number of unique visitors who have viewed a particular ad. We use cookies to store user preferences, record past activity on a site in order to better service you when you return and to customize web page content based on users' browser type or other information that you have provided.
We may combine this information with other personal information we collect from you. There are two types of cookies: session and persistent cookies. We also permit third-party cookies on our Sites.
- 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 into the Sites. This allows us to process your online transactions and requests and verify your identity after you have logged in, as you move through our Sites..
- 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 and to display advertising both on our Sites and on third-party sites.
Disabling Cookies. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the 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, and how to disable cookies altogether. Visitors to our Site who disable cookies will be able to browse certain areas of the Site but will not have access to most areas of our Site.
Local Storage Objects. We may use Flash Local Storage Objects (“Flash LSOs”) to store your Site preferences and to personalize your visit. Flash LSOs are different from browser cookies because of the amount and type of data stored. Typically you cannot control, delete, or disable the acceptance of Flash LSOs through your web browser. For more information on Flash LSOs, or to learn how to manage your settings for Flash LSOs, 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.
Clear GIFs, Pixel Tags, and Other Technologies. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer's hard drive, clear GIFs are embedded invisibly on web pages. We may use clear GIFs (a.k.a. web beacons, web bugs, or pixel tags), in connection with our Sites to, among other things, track the activities of Site visitors, help us manage content, and compile statistics about Site usage. We and our third-party service providers also use clear GIFs in HTML emails to our customers, to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.
Advertising/Third-Party Ad Networks and Online Tracking. We, advertisers, sponsors, and our third-party service providers may use third parties such as network advertisers to display advertisements on our Site. Network advertisers are third parties that display advertisements based on your visits to our Sites as well as other websites. We, advertisers, our third-party service providers, and the ad networks may track your behavior on our Sites. Specifically, third-party ad-network providers, advertisers, sponsors, and/or traffic-measurement services may use cookies, JavaScript, web beacons (including clear GIFs), Flash LSOs, and other technologies to measure the effectiveness of their ads and to personalize advertising content to you. This enables us and these third parties to target advertisements by displaying ads for products and services in which you might be interested. These third-party cookies and other technologies are governed by each third party’s specific privacy policy, not this one. We may provide these third-party advertisers with information about your usage of our Sites and our Services, as well as aggregate or non-personally identifiable information about visitors to our Sites and users of our Service.
You may opt out of many third-party ad networks, including those operated by members of the Network Advertising Initiative ("NAI") and the Digital Advertising Alliance ("DAA"). For more information regarding this practice by NAI members and DAA members, and your choices regarding the use of this information used by these companies, including how to opt out of third-party ad networks operated by NAI and DAA members, please visit their respective websites: www.networkadvertising.org/optout_nonppii.asp (NAI) and www.aboutads.info/choices (DAA).
Opting out of one or more NAI member or DAA member networks (many of which will be the same) means only that those members no longer will deliver targeted content or ads to you. It does not mean that you will no longer receive any targeted content or ads on our Site or other websites. You may continue to receive advertisements based, for example, on the particular website that you are viewing. Also, if your browsers are configured to reject cookies when you visit the opt-out page, or if you subsequently erase your cookies, use a different computer, or change web browsers, your NAI or DAA opt-out may no longer be effective. Additional information is available on NAI's and DAA's websites, accessible by the links above.
5. Managing Your User-Generated Content.
You can post, upload, comment, ask questions, or otherwise submit content to our Sites and services, social media networking services, at live events or webinars.
Any User-Generated content that you post can be seen, collected, and used by The Chronicle and anyone else who has access to the applicable service. Such information may become public, and we cannot prevent this information from being used in a manner that may violate this Policy, the law, or your personal privacy.
Any User-Generated Content you submit may be used and shared by The Chronicle and its affiliates in accordance with our Terms of Use.
6. Securing Your Personal Information.
We have taken commercially reasonable precautions to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our best reasonable efforts, no data security measures can guarantee 100% security.
You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.
7. Options for Managing Your Privacy Settings.
If you have an account, log in or contact us at help@chronicle.com to update your information or opt-out of newsletters. If you are a Chronicle Community user, log in to edit who can view your User Profile, activity feed, and other information you post to our Site and through our Services.
For promotional emails, we provide a link to unsubscribe or manage your preferences at the bottom of every email. If you need assistance, please contact us at help@chronicle.com.
To delete your account, please contact us at help@chronicle.com. For your protection, we may ask you to verify your identity before implementing a request.
As outlined in the previous section, you can edit your cookie preference through your browser. Note that if you disable or delete cookies, you may lose access to certain features of our Sites and Services.
Log into your account to update your privacy settings.
For Chronicle Community Users, you may receive additional emails from us or third parties (such as educational institutions or recruiters) based on your preference settings. Log into your account to edit your preferences.
8. Notice to Non-U.S. Users.
The Chronicle is based in the United States. The use of your information by The Chronicle is intended for use only within the United States and its territories. If you use our Sites and our Services, your information will be stored in the United States. We may, however, use third-party service providers that are located outside of the United States. Content and use of that content is intended to conform to United States law and practices. Use of our Services outside the United States is at your risk, and you agree to comply with all applicable laws and use or nonuse of content.
9. Special Notice for Chronicle Community Users
Chronicle Community may collect additional information about you and provide additional options for sharing your information as a part of this service.
- Chronicle Community User Profile. As part of creating a Chronicle Community user profile, you may choose to include additional information beyond your name, such as education, experience, awards, a photograph, current location, research, and presentations. Be aware that your User Profile will be available to other Chronicle Community users. Please login to your account and edit your Privacy Settings to learn how you can control who may view your User Profile.
- Address Book, Connections. You may use our contacts importer to upload individual contacts or your address book from certain applications, including, without limitation, Microsoft Outlook, Gmail, and Yahoo Mail. We may use this information to help you identify contacts within our network. From time to time, we may add functionalities that will facilitate your ability to add contacts and to synchronize your account with third-party services. Please login to your account and edit your Privacy Settings to learn how you can control who may view your contact information.
10. Special Notice to California Consumers.
This section provides specific information for residents of California ("consumers" in this section), as required under California privacy laws, including the California Consumer Privacy Act ("CCPA"). The CCPA requires that we provide certain information to California consumers about how we handle their personal information that we have collected, whether online or offline. Under the CCPA, "personal information" is any information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, device or household, including the categories identified in the table below to the extent they identify, relate to, describe, are capable of being associated with, or could be reasonably linked, directly or indirectly, with a particular consumer, device or household. Personal information does not include publicly available information from government records; De-identified or aggregated consumer information; Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994. Any terms defined in the CCPA have the same meaning when used in this section.
Categories of Personal Information that We Collect, Disclose, and Sell
The table below discloses the categories of personal information about California consumers that we have collected, sold, and disclosed for a business purpose within the twelve (12) months preceding the date of this privacy policy. The information in this section is tailored to meet the disclosure requirements of the CCPA.
Categories of personal information Last Updated: December 31, 2019 |
Collected? | Disclosed for business purpose? | Sold? | |
---|---|---|---|---|
A. | Contact information. This includes real name, postal address, email address, and phone number. | Yes | Yes | Yes |
B. | Professional or employment information. | Yes | Yes | Yes |
C. | Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, 34 C.F.R. Part 99). | Yes | Yes | Yes |
D. | Identifiers such as account name, social security number, driver's license number, passport number, or other similar identifiers. | No | No | No |
E. | Signature, physical characteristics or description, financial information, medical information, or health insurance information. | No | No | No |
F. | Race, ethnicity, color, sex, age, national origin, or disability. (Characteristics of protected classifications under California or federal law.) | Yes | Yes | No |
G. | Religion, citizenship status, and genetic information. (Characteristics of protected classifications under California or federal law.) | No | No | No |
H. | Commercial information, including products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | Yes | Yes | Yes |
I. | Biometric information. | No | No | No |
J. | Internet or other electronic network activity information, including, but not limited to, Internet Protocol address, browsing history, search history, and information regarding a consumer's interaction with an Internet Web site, application, or advertisement. | Yes | Yes | No |
K. | Geolocation data. | Yes | Yes | Yes |
L. | Audio, electronic, visual, thermal, olfactory, or similar information. | No | No | No |
M. | Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer's preferences, characteristics, predispositions, behavior, attitudes. | Yes | Yes | No |
N. | N. Psychological trends, predispositions, behavior, attitudes, intelligence | No | No | No |
Categories of Sources of Personal Information. We obtain the categories of information listed above from the following categories of sources:
- Directly from you. For example, when you create a profile or account, fill out a promotional form purchase products and services, enter contests, or complete surveys.
- Indirectly from you. The Chronicle uses cookies, web beacons, and other technologies to collect automatically information about your use of our Site or Services. Examples include your domain name, your browser type and operating system, web pages you view, links you click, your IP address, the length of time you visit our Site and/or use our Services; and the referring URL, or the web page that led you to our Site.
- From third parties. We collect information about you from our partners, publicly available data, privately-held marketing or data analytics resources, or other users of our Services.
California Consumer Rights. California law grants consumers certain rights and imposes restrictions on particular business practices as set forth below.
Do-Not-Sell. California consumers have the right to opt-out of our sale of their personal information. If we sell your personal information, you may exercise your opt-out rights by visiting our Do-Not-Sell page located on our website at https://www.chronicle.com/#CCPA or https://www.philanthropy.com/#CCPA.
Requests for a Copy, Deletion, and Right to Know. Subject to certain exceptions, California consumers have the right to make the following requests, at no charge, up to twice every 12 months:
Deletion. The right to request deletion of your personal information that we have collected about you, subject to certain exemptions, such as where the information is used to complete the transaction for which the personal information was collected, detect security incidents, debug to identify and repair errors that impair existing intended functionality or comply with a legal obligation.
Copy. The right to request a copy of the categories or specific pieces of personal information that we have collected about you in the prior 12 months.
Right to Know. The right to request that we disclose specific information about our data practices with regard to your personal information over the prior 12 months, including the:
- categories of personal information collected
- categories of sources of personal information collected
- business and/or commercial purpose(s) for collecting and selling 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 personal information we have sold
- categories of third parties to whom the consumer's personal information has been sold and the specific categories of personal information sold to each category of the third party
Submitting Requests. You can submit a copy, deletion, and right-to-know request online at https://www.chronicle.com/account/profile or https://www.philanthropy.com/account/profile, by contacting us at 202-466-1000, or by emailing us at help@chronicle.com.
Incentives and "Non-Discrimination". The CCPA prohibits discrimination against California consumers for exercising their rights under the CCPA and imposes requirements on financial incentives, including loyalty programs offered to California consumers related to their personal information.
Non-Discrimination. If consumers exercise their rights under CCPA, businesses may not discriminate against them including by denying or providing a different level or quality of goods or services or charging or suggesting that a business will charge different prices or rates or impose penalties, unless doing so is reasonably related to the value provided by the consumer's data.
Disclosure of Incentives. If businesses offer any financial incentives for the collection, sale, or deletion of their personal information, consumers have the right to be notified of any financial incentives offers and their material terms, as well as to opt-out of such offers at any time. Businesses may not offer unjust, unreasonable, coercive or usurious financial incentives. We do not offer any financial incentives in exchange for personal information.
Shine The Light. California residents may request, free of charge, a list of what personal information (if any) we provided to third parties in the preceding year for that third party’s direct marketing purposes. You may make one request per calendar year. In your request, please attest that you are a California resident and provide a current California address for your response. You may request this information in writing by contacting us as set forth in the User Agreement. Please allow up to thirty (30) days for a response.
11. How to Contact Us.
If you have questions about the privacy aspects of our Services or would like to make a complaint, you can contact us in the following ways:
- Write to us at 1255 23rd Street, N.W., Washington, DC 20037
- Email us at help@chronicle.com
- Call us at 202-466-1000
12. Changes in This Policy.
WE RESERVE THE RIGHT TO CHANGE THESE TERMS FROM TIME TO TIME. ALL CHANGES ARE EFFECTIVE IMMEDIATELY WHEN WE POST THEM, AND APPLY TO ALL ACCESS TO AND USE OF THE WEBSITE THEREAFTER. YOUR CONTINUED USE OF THE SITE FOLLOWING ANY CHANGE WILL BE CONCLUSIVELY DEEMED ACCEPTANCE OF ANY CHANGE TO THE TERMS AND CONDITIONS. YOU ARE EXPECTED TO CHECK THIS PAGE FROM TIME TO TIME SO THAT YOU ARE AWARE OF ANY CHANGES, AS THEY ARE BINDING ON YOU.