Last Updated (March 25, 2022), v. 2.2
GIA Alumni Association, LLC (hereinafter “GIA Alumni Collective,” “we,” “us,” or “our”) values the privacy of your personal data. This GIA Alumni Association, LLC Privacy Notice (“Notice”) describes GIA Alumni Collective’s policies and practices regarding GIA Alumni Collective’s processing, including collection, use, and handling, of your personal data in connection with your relationship with GIA Alumni Collective as an alum or your other interaction with GIA Alumni Collective.
If you have any questions or concerns about this Notice or our use of your personal data, please contact us at:
GIA Alumni Association, LLC
The Robert Mouawad Campus
5345 Armada Drive
Carlsbad, California 92008 USA
When you have successfully completed a GIA on-campus program or GIA Distance Education course (this does not include lab classes), you automatically become a member of the GIA Alumni Collective. You will also receive GIA alumni–related communications and ePublications and be connected with your global alumni network. Local GIA alumni chapters may be operated by third parties who have their own privacy policies, for which GIA is not responsible. You will have the opportunity to opt out of receiving communications from the GIA Alumni Collective.
Personal Data Collection, Use, and Processing
In connection with your relationship with GIA Alumni Collective, we collect personal data about you (whether online, in-person, or through other means) from the following sources: directly from you; from our affiliated entities; from alumni chapters; and automatically as you visit GIA Alumni Collective’s websites and mobile applications.
We use your personal data for the purposes described in further detail below, including to facilitate your experience with GIA Alumni Collective and to provide you with products and services. We share your personal data with GIA-affiliated entities and others as described in this Notice.
Providing your personal data is voluntary. Please note, however, that without your personal data, we may be unable to provide you with the products and services that you request.
Types of Personal Data We Collect
In connection with your relationship with GIA Alumni Collective, we collect the following categories of personal data, as permitted by applicable law:
- General contact information: title, first name, last name, suffix, home address, mailing address, phone number(s), email address, date of birth, residency
- Business information: business name, doing business as (“DBA”) name, address, phone number(s), business email address, company website (Note: business information is only considered personal data to the extent it identifies an individual, unless otherwise stipulated by applicable law)
- Government identifiers: driver’s license, passport, government-issued identification with photograph, tax identification number, business license number, business license document, GSTIN number with code (India only), voter registration card, permanent resident alien card, national identity card, vehicle license plate number (if entering GIA campus)
- Financial information: billing information, payment information, bank account number, banking institution, payment card information, third-party payer information
- Education/Training: details about your enrollments such as fields of study, dates of enrollment, degrees, diplomas, and certificates awarded, dates conferred, academic honors and awards received
- Social Network Form Fill: GIA Alumni Collective may process your personal data when you authorize your social network to prefill a form on a GIA Alumni Collective website (e.g., by signing into your social media account(s) through a button that appears on a GIA Alumni Collective website). In that case, GIA Alumni Collective will receive personal data about you from the social network pursuant to the policies of that social network. Examples of the personal data that we may receive includes your display name, first name, last name, profile URL, profile photo URL, social reach (number of followers), gender, email, date of birth, job title, and company. Your personal data will be processed by us in accordance with this Privacy Notice.
- Images and recordings: call recording, electronic video and audio monitoring and surveillance, film, photographs
- Other information we may collect from or about you from time to time
Purposes for Which We Use Personal Data
We may use your personal data for the following purposes:
- Assist with quality assurance, training, respond to inquiries and provide customer service
- Review and process your submissions
- Provide you with information, products, and services
- Deliver publications and subscriptions
- Combine your personal data with other information that we obtain from third parties
- Assist us in advertising our services, including on non–GIA Alumni Collective websites or through other channels
- Comply with applicable laws, including sharing your data with law enforcement and service providers
- Monitor compliance with our existing policies and procedures
- Respond to formal or informal government or regulatory body requests
- Provide for the integrity and security of our premises and processes
- Help us understand your needs and interests
- Improve our products and services
- Direct marketing as permitted by applicable law, for example, to send you news and newsletters, special offers and promotions, or to contact you about products or information we think may interest you in accordance with our opt-in/opt-out practices. We may send these communications through postal mail, email, SMS (available in some markets only), or other available channels.
- Help us determine what advertisements to direct to you, to place on websites, and where to advertise our services
As applicable based on your interaction with us, we use and share your personal data as follows:
GIA Alumni Collective
- To deliver the GIA Alumni Collective information, products, and services you request and connect you with your global alumni network
- Administration of scholarships and awards through alumni and donor relationships
- To provide for the security and integrity of physical premises and for the safety of our employees, clients, students, alumni, visitors, and others, and for emergency security purposes
Video and Audio Monitoring
- To provide for the integrity and security of our premises and processes
We use both video and audio monitoring in public and work spaces. Appropriate signs are displayed in all areas where video and audio monitoring are used.
Persons Under the Age of Majority
Aside from the GemKids area of the Site, and offline at career fairs, our Services do not target users under the age of majority in their country (“minors”).
Automatically Collected Data
Our websites collect certain information automatically and store it in log files. The information includes Internet Protocol (“IP”) addresses, the region or general location where your computer or device is accessing the Internet, browser type, operating system, and other usage information about your use of our websites. We use this information to help us design our services to better suit our users’ needs. We may also use your IP address to help diagnose problems with our server and to administer our websites, analyze trends, track visitor movements, and gather broad demographic information that assists us in identifying visitor preferences.
Information About Our Use of Other Technologies (web beacons, pixel tags, and other technologies): Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. Clear GIFs are small pieces of code embedded invisibly on web pages, not stored on your hard drive, which often work in conjunction with cookies. We may use clear GIFs in connection with our websites to, among other things, track the activities of users, help us manage content, and compile statistics about use of these sites. We and our service providers also use web beacons in HTML emails to you to help us track email response rates, measure the success of our marketing campaigns, identify when our emails are viewed, and track whether our emails are forwarded.
Opting In and Out of Email and SMS Marketing Communications
In certain cases, when we obtain your contact information, we may send you marketing communications via direct mail, email, SMS (available in select markets only), or other available channels about various products, services, newsletters, or general updates of GIA Alumni Collective and GIA Alumni Collective’s affiliated entities. If you no longer wish to receive marketing and promotional communications from us, you may opt out by emailing our Privacy Office or as follows:
- for email: click the “unsubscribe” option; and
- for SMS: text STOP in response to the text message.
If you opt out of receiving marketing communications from us, please note that we will continue to communicate with you regarding your ongoing relationship with us and for customer service–related purposes.
Retention of Personal Data
As a general matter, we do not retain personal data for longer than is required or appropriate for the purposes for which it was collected, unless a longer or shorter period is necessary for our legal obligations; or customs of the industry; or to defend a legal claim; or to comply with legal, accounting, regulatory or reporting requirements; and consistent with applicable law.
Security of Personal Data
We take reasonable steps to protect your personal data by using technical, physical, and organizational measures that are designed to protect against unauthorized or unlawful use, alteration, unauthorized access or disclosure, accidental or wrongful destruction, and loss.
We take steps to limit access to your personal data to those persons who need to have access to it for one of the purposes listed in this Notice.
Disclosure, Transfer, and Storage of Personal Data
We share and jointly use your personal data with other GIA-affiliated entities for the following purposes: to provide the products and perform the services that you have requested; for billing and collections; to host your data; for marketing efforts; to assist us in performing our legal compliance obligations; to protect our rights and property and the rights and property of others; and for any other purpose as set forth in this Notice and permitted by applicable law. We will rely on agreements based on the standard contractual clauses or another legally valid mechanism to validly transfer your personal data outside the European Economic Area.
We also share your personal data with non-affiliated vendors and suppliers that provide products and services to GIA Alumni Collective or its affiliated entities (e.g., payment processing, transmission of marketing emails, web hosting, couriers). These entities do not use your information for their own purposes, including marketing purposes, but rather act on the instructions of GIA Alumni Collective or its affiliated entities. As an example of our sharing with third-party service providers, we may disclose certain information (such as your email address) with non-affiliated parties such as Facebook (more information on Facebook Custom Audience here or see above) so that we can better target ads and content to you, and others with similar interests on these non-affiliated parties’ platforms or networks (“Custom Audiences”). We may also work with ad networks and marketing platforms that enable us and other participants to target ads to Custom Audiences submitted by us and others. To opt out of being included in our Custom Audiences going forward, email us at firstname.lastname@example.org.
We may also disclose your personal data to another entity in connection with, including during negotiations of, an acquisition or merger, sale or transfer of a business unit or assets, bankruptcy proceeding, or as part of any other similar business transfer. We may also disclose your personal data 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, or violations of this Notice. GIA Alumni Collective may also make personal data available to other parties such as legal and regulatory authorities and law enforcement upon their request and/or where we believe it appropriate to do so. When transferring personal data to GIA Alumni Collective –affiliated entities and non-affiliated entities (which may be located outside the country in which your personal data was collected and may not guarantee the same level of protection) we have executed legally necessary contracts with the recipients of your data.
Updates to this Notice
GIA Alumni Collective may amend this Notice from time to time as laws change and as our organization, products, and services change. The revisions will take effect on the publication date of the amended Notice, as stated, and supersede all previous Notices regarding our privacy practices.
Unless prohibited by applicable law, we reserve the right to amend the Notice at any time, for any reason, without notice to you, other than the posting of the amended Notice at this site.
RIGHTS OF CALIFORNIA RESIDENTS
Pursuant to Section 1798.83 of the California Civil Code, residents of California have the right to request from a business, with whom the California resident has an established business relationship, certain information regarding the types of personal information the business shares with third parties for direct marketing purposes by such third party, and the identities of the third parties with whom the business has shared such information during the immediately preceding calendar year. To see a copy of the information disclosure provided by GIA Alumni Collective pursuant to Section 1798.83 of the California Civil Code, please contact email@example.com.
Additional Information for Residents of the European Union (“EU”), or where applicable and required by the laws of your jurisdiction
To the extent the GDPR or other law granting particular rights to data subjects applies to you, you have the following rights with regard to our processing of your personal data:
- Right to access, correct, and delete your personal data: GIA Alumni Collective will use reasonable measures designed to ensure that all personal data is correct. You also have a responsibility to ensure that changes in personal circumstances (for example, change of address, bank account, etc.) are notified to GIA Alumni Collective so that we can ensure that your personal data is up to date.
You have the right to request access to any of your personal data that GIA Alumni Collective may hold and to request correction of any inaccurate personal data relating to you. You furthermore have the right to request deletion of personal data we hold about you.
- Right to withdraw consent: In the event your personal data is processed on the basis of your consent, you have the right to withdraw consent at any time by sending an email to firstname.lastname@example.org specifying your request, without affecting the lawfulness of processing based on consent before its withdrawal.
Data portability: To the extent that we use your personal data on the basis of consent or for the performance of a contract and that personal data is processed by automatic means, you have the right to receive all such personal data that you have provided to GIA Alumni Collective in a structured, commonly used, and machine-readable format, and also to require us to transmit it to another data controller where this is technically feasible.
Right to restrict personal data use: You have the right to restrict our use of your personal data where (i) you contest the accuracy of the personal data; (ii) the use is unlawful but you do not want us to erase the personal data; (iii) we no longer need the personal data for the relevant purposes, but you require it for the establishment, exercise, or defense of legal claims; or (iv) you have objected to our personal data use justified on our legitimate interests pending verification as to whether GIA Alumni Collective has indeed compelling interests to continue the relevant personal data use.
Right to object to processing justified on legitimate interest grounds: To the extent that we are relying upon legitimate interest to process data, then you have the right to object to such processing, and we must stop such processing unless we can either demonstrate compelling legitimate grounds for the processing that override your interests, rights, and freedoms or where we need to process the data for the establishment, exercise, or defense of legal claims. Normally, where we rely upon legitimate interest as a basis for processing, we believe that we can demonstrate such compelling legitimate grounds, but we will consider each case on an individual basis.
Lodge a complaint: You also have the right to lodge a complaint with a supervisory authority, in particular in your country of residence, if you consider that the collection and use of your personal data violates this Notice or applicable law.
Legal Bases We Rely on When Processing Your Personal Data
Where EU data protection law applies, and where applicable under other applicable data protection laws, we process your personal data under the following legal bases:
- Our Contract With You. Our processing is necessary to perform our obligations under a contract with you or to perform steps requested by you prior to entering into a contract with you (e.g., to verify the information you have provided to us).
- Our Legitimate Interests. Our processing is necessary for our legitimate interests, including to protect the security of our services; to protect the health and safety of you or others; to establish, protect, and defend our legal rights and interests; to prevent fraud and verify identity and authorization of clients; to understand and analyze usage trends; and to improve our products and services.
- Legal Compliance. Where our processing is required to comply with applicable law (e.g., to maintain your payment transaction history for tax reporting purposes, in response to subpoenas, court orders, and other lawful requests by regulators, courts, and law enforcement agencies, or related to national security requests).
- Your Consent. When we have your express consent as defined by applicable law.
Privacy Questions and Complaints
Please note that certain personal data may be exempt from the requests described above pursuant to applicable laws, and that certain rights may only be exercisable in certain jurisdictions, in accordance with applicable laws. If you have any questions or concerns about this Notice or our use of your personal data, please contact GIA Alumni Collective’s Privacy Office, at any time. In your local jurisdiction, you may also have the right to lodge a complaint with a supervisory authority if you consider that our processing of your personal data violates applicable law.
GIA Alumni Association, LLC Privacy Notice for California Consumers
Effective date (September 20, 2021), v. 1.0
GIA Alumni Association, LLC (hereinafter, “GIA Alumni Collective,” “we,” “us,” or “our”) provides this Privacy Notice for California Consumers (the “CCPA Privacy Notice”) to supplement the information contained in the GIA Alumni Association, LLC Privacy Notice. This CCPA Privacy Notice sets forth our privacy practices as required by the California Consumer Privacy Act of 2018 (“CCPA”).
The CCPA Privacy Notice applies only to individuals residing in the State of California who are considered “Consumers” under the CCPA and from whom we collect “Personal Information” as described in the CCPA (“Consumers”).
Information We Collect
We may collect Personal Information from you in a variety of different situations, including but not limited to on our website, your mobile device, through email, through the mail, and/or over the telephone. More specifically, we collect the following categories of Personal Information from our Consumers:
Examples of Personal Information Collected
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
A name, address, telephone number, date of birth, gender
C. Protected classification characteristics under California or federal law
Age, date of birth, gender
D. Commercial information
E. Biometric information
F. Internet or other similar network activity
Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement
G. Geolocation data
H. Sensory data
I. Professional or employment-related information
Employment or professional history
J. Education information, as defined by the Family Educational Rights and Privacy Act
Courses and programs completed
K. Inferences drawn from other personal information
We obtain the categories of Personal Information listed above from the following categories of sources:
- Directly from you. For example, from forms you complete or products and services you purchase.
- Indirectly from you. For example, from observing your actions on our website or from information your computer or mobile device transmits when interacting with our website or mobile applications.
How We Use and Share Personal Information
We use and share your Personal Information as described in the GIA Alumni Association, LLC Privacy Notice. We also use and share your Personal Information to act in accordance with your direction. For example, where you intentionally direct GIA Alumni Collective to share Personal Information with GIA Alumni Collective’s affiliated entities to receive information from GIA Alumni Collective’s affiliated entities. We may also disclose your Personal Information to a third party for a business purpose, including to our service providers.
We share your personal information with the following categories of third parties:
- Service providers.
- Third parties with whom you direct us to share your personal information (for example, GIA Alumni Collective’s affiliated entities).
Disclosures of Personal Information for a Business Purpose
In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose: Categories A, B, C, D F, G, I, and J (see Information We Collect chart above).
Sales of Personal Information
In the preceding twelve (12) months, GIA Alumni Collective has not sold Personal Information.
Your Consumer Rights and Choices
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:
- The categories of Personal Information we collected about you.
- The categories of sources for the Personal Information we collected about you.
- Our business or commercial purpose for collecting that Personal Information.
- The categories of third parties with whom we share that Personal Information.
- The specific pieces of Personal Information we collected about you.
- If we disclosed your Personal Information for a business purpose, a list disclosing the disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.
Deletion Request Rights
You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.
In accordance with the CCPA, we may deny your deletion request under certain circumstances, and will inform you of the basis for the denial, which may include, but is not limited to, if retaining the information is necessary for us or our service provider(s) to:
- Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please contact us at:
GIA Alumni Association, LLC
The Robert Mouawad Campus
5345 Armada Drive
Carlsbad, California 92008 USA
Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative. Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm that the Personal Information relates to you. Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password-protected account sufficiently verified when the request relates to Personal Information associated with that specific account. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Response Timing and Format
We try to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to an additional 45 days), we will inform you of the reason and extension period in writing. If you have an account with us, we may deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
If you have any questions or comments about this notice, the ways in which we collect and use your information described above, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:
GIA Alumni Association, LLC
The Robert Mouawad Campus
5345 Armada Drive
Carlsbad, California 92008 USA