Your Privacy Rights
Full Sail (also known as Full Sail, LLC and Full Sail University) (“Full Sail,” “we,” “us” or “our”), is committed to making your experience online satisfying and safe. Your privacy on the Internet is of utmost important to us.
3. TRANSPARENCY/NOTICE – TYPES OF INFORMATION WE COLLECT AND HOW WE USE IT
- You may provide Personal Information directly to Full Sail through interacting with the Services, participating in surveys, during events, contests, and requesting Services, or information.
- As you navigate the Services, certain passive information may also be collected about your visit, including through cookies and similar technologies as described below.
- We may collect information using various offline information collection methods including without limitation the completion of lead forms sourced by Third-Party data aggregators.
We endeavor to collect only that information which is relevant for the purposes of Processing.
3.1 TYPES OF PERSONAL INFORMATION WE COLLECT
Full Sail collects Personal Information regarding its current, prospective, and former customers, users, visitors, guests, and employees (collectively “Individuals”).
- Information You Provide Directly to Us. When you use the Sites and Mobile Apps, we may ask you to provide us with Personal Information. These voluntary submissions include making an online request that Full Sail send you additional information about its programs, via email, regular mail, telephone, SMS, and other messaging apps, and submitting an application to Full Sail degree programs online.
- Communications With Us. We may collect Personal Information from you such as email address, phone number or mailing address when you choose to request information about us and our programs, register for Full Sail’s newsletter, request to receive customer or technical support, or otherwise communicate with us, including the on-line chat live function on our Sites. We also collect the other information that you provide as part of use of the Sites and Mobile Apps (e.g., without limitation, zip code (on its own), city and state, age and individual preferences).
- Surveys. From time to time, we may contact you to participate in online surveys. If you do decide to participate, you may be asked to provide certain information which may include Personal Information. All information collected from your participation in our surveys is provided by you voluntarily. We may use such information to improve our products, Sites and/or services and in any manner consistent with the policies provided herein.
- Automatic Data Collection. We may collect certain information automatically through our Services or other methods of web analysis, such as your Internet protocol (IP) address, cookie identifiers, mobile carrier, mobile advertising identifiers, MAC address, IMEI, Advertiser ID, and other device identifiers that are automatically assigned to your computer or device when you access the Internet, browser type and language, geo-location information, hardware type, operating system, Internet service provider, pages that you visit before and after using the Services, the date and time of your visit, the amount of time you spend on each page, information about the links you click and pages you view within the Services, and other actions taken through use of the Services such as preferences.
- Information Submitted Via Services. You agree that Full Sail is free to use the content of any communications submitted by you via the Services, including any ideas, inventions, concepts, techniques, or know-how disclosed therein, for any purpose including developing, manufacturing, and/or marketing goods or Services. Full Sail will not release your name or otherwise publicize the fact that you submitted materials or other information to us unless: (a) you grant us permission to do so; (b) we first send notice to you that the materials or other information you submit to a particular part of a Service will be published or otherwise used with your name on it; or (c) we are required to do so by law.
- Information From Other Sources. We may receive information about you from other sources, including through Third-Party services and organizations to supplement information provided by you.
3.2 HOW FULL SAIL USES YOUR INFORMATION
We acquire, hold, use, and Process Personal Information about Individuals for a variety of purposes, including:
- To Provide Products, Services, or Information Requested. Full Sail may use information about you to administer and provide the Sites and Mobile Apps to you, and to administer your inquiries and fulfill requests for products, Services, or information, including information about potential or future Services, including to:Generally manage Individual information and Accounts;
Respond to questions, comments, and other requests;
Provide access to certain areas, functionalities, and features of Full Sail’s Services;
Create an account;
Contact you to answer requests for customer support or technical support;
Allow you to register for events.
- Administrative Purposes. Full Sail may use Personal Information about you for its administrative purposes, including to:Measure interest in Full Sail’s Services;
Develop new products and Services;
Ensure internal quality control;
Verify Individual identity;
Communicate about Individual Accounts and activities on Full Sail’s Services and systems, and, in Full Sail’s discretion, changes to any Full Sail policy;
Send email to the email address you provide to us to verify your Account and for informational and operational purposes, such as Account management, customer service, or system maintenance;
Process payment for products or services purchased;
Process applications and transactions;
Prevent potentially prohibited or illegal activities.
- Marketing Full Sail Products and Services. Full Sail may use Personal Information to provide you with materials about offers, products, and Services that may be of interest, including new content or Services. Full Sail may provide you with these materials by phone, SMS, messaging apps, postal mail, facsimile, and email, as permitted by applicable law. Such uses include:To tailor content, advertisements, and offers;
To notify you about offers, products, and services that may be of interest to you;
To provide Services to you and our sponsors;
For other purposes disclosed at the time that Individuals provide Personal Information; or
Otherwise with your consent.
You may contact us at any time to opt out of the use of your Personal Information for marketing purposes, as further described below.
- Research and Development. Full Sail may use Personal Information to create non-identifiable information that we may use alone or in the aggregate with information obtained from other sources, in order to help us to optimally deliver our existing products and Services or develop new products and Services. From time to time, Full Sail may perform research (online and offline) via surveys. We may engage Third-Party service providers to conduct such surveys on our behalf. All survey responses are voluntary, and the information collected will be used for research and reporting purposes to help us better serve Individuals by learning more about their needs and the quality of the products and services we provide. The survey responses may be utilized to determine the effectiveness of our Services, various types of communications, advertising campaigns, and/or promotional activities. If an Individual participates in a survey, the information given will be used along with that of other study participants. We may share anonymous Individual and aggregate data for research and analysis purposes.
- Direct Mail, Email and Outbound Telemarketing. Individuals who provide us with Personal Information, or whose Personal Information we obtain from Third Parties, may receive periodic emails, SMS text messages, messages via messaging apps, newsletters, mailings, or phone calls from us with information on Full Sail’s or our business partners’ products and services or upcoming special offers/events we believe may be of interest. We offer the option to decline these communications at no cost to the Individual by following the instructions below.
- Anonymous and Aggregated Information Use. Full Sail may use Personal Information and other information about you to create anonymized and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access Full Sail’s Services, or other analyses we create. Anonymized and aggregated information is used for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the Services. Anonymized or aggregated information is not Personal Information, and Full Sail may use such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes. We may share this information within Full Sail and with Third Parties for our or their purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you.
- Sharing Content with Friends or Colleagues. Full Sail’s Services may offer various tools and functionalities. For example, Full Sail allows you to provide information about your friends through our referral services, such as “Tell a Friend.” Our referral services may allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Services. Email addresses that you may provide for a friend or colleague will be used to send your friend or colleague the content or link you request, but will not be collected or otherwise used by Full Sail or any other Third Parties for any other purpose.
- Other Uses. Full Sail may use Personal Information for which we have a legitimate interest, such as direct marketing, individual or market research, anti-fraud protection, or any other purpose disclosed to you at the time you provide Personal Information or with your consent.
3.3 COOKIES, PIXEL TAGS/WEB BEACONS ANALYTICS INFORMATION, AND INTERNET-BASED ADVERTISING
- Usage Tracking Information. Full Sail collects aggregated information regarding user traffic patterns mainly by tallying page views throughout the Sites and Mobile Apps (“Usage Tracking Information”). Full Sail does break down overall Usage Tracking Information according to a user’s domain name, browser type, IP address and MIME type by reading this information from the browser string (information contained in every user’s browser). Usage Tracking Information may also include the pages you were visiting before you came to our Sites or Mobile Apps, the time spent on those pages, search terms that you enter into our Search function, access times and dates, and other statistics. Nevertheless, we do not correlate Usage Tracking Information with data about individual users. We use Usage Tracking Information to determine which areas of our Sites and Mobile Apps that users visit based on traffic to those areas. We do not track what individual users read, but rather how well each page performs overall. This helps us continue to build better Sites and Mobile Apps for you.
Our uses of such Technologies fall into the following general categories:
- Advertising or Targeting Related. We may use first-party or Third Party cookies and web beacons to deliver content, including ads relevant to your interests, on our Sites or on Third Party sites. This includes using technologies to understand the usefulness to you of the advertisements and content that has been delivered to you, such as whether you have clicked on an advertisement.
We use Third-Party software development kits (“SDKs”) relating to advertising and/or to add functionality of our Services. Third-Party SDKs may allow Third Parties including advertisers to collect your personal information to provide content that is more relevant to you. You may opt out of tracking by emailing email@example.com.
If you would like to opt out of the Technologies we employ on our Sites, Services, applications, or tools, you may do so by blocking, deleting, or disabling them as your browser or device permits.
3.4 LINKS TO OTHER SITES
The Sites may include links to other websites maintained or controlled by Third Parties unrelated to Full Sail. If you click on such a link, you will be directed to that Third Party’s website. The fact that we link to a website is not an endorsement or representation of our affiliation with that Third Party, nor is it an endorsement of their privacy or information security policies or practices. We do not exercise control over Third Party websites. These other websites may place their own cookies or other files on your computer, collect data or solicit personally identifiable information from you. Other websites follow different rules regarding the use or disclosure of personally identifiable information. We advise you to review the individual privacy policies of each external site that you use. Visiting these other websites or applications is at your own risk.
Full Sail’s Services may include publicly accessible blogs, community forums, or private messaging features. The Site and our other Services may also contain links and interactive features with various social media platforms (e.g., widgets). If you already use these platforms, their cookies may be set on your device when using our Site or other Services. You should be aware that Personal Information which you voluntarily include and transmit online in a publicly accessible blog, chat room, social media platform or otherwise online, or that you share in an open forum may be viewed and used by others without any restrictions. We are unable to control such uses of your information when interacting with a social media platform, and by using such services you assume the risk that the Personal Information provided by you may be viewed and used by third parties for any number of purposes.
3.5 THIRD-PARTY PAYMENT PROCESSING
We may sell merchandise through our Services. When you make purchases through the Services, we process your payments through a Third Party application, including the Apple App Store, Google Play App Store, Amazon App Store (together with any similar applications, “App Stores”) and Social Networking Sites (“SNS”) such as Facebook. The Third Party application may collect certain financial information from you to process a payment on behalf of Full Sail, including your name, email address, address and other billing information.
4. ONWARD TRANSFER – FULL SAIL MAY DISCLOSE YOUR INFORMATION
4.1 INFORMATION WE SHARE WITH THIRD PARTIES
- Service Providers. We may engage certain Third Party companies and individuals to facilitate the Sites, Mobile Apps and Services on our behalf, to perform Site and Mobile Apps-related services (e.g., without limitation, hosting and maintenance services, customer relationship services, web analytics, payment processing and database storage and management services). Full Sail also shares information about prospective students with Third Party services that Full Sail uses to evaluate potential applicants. We will share your Personal Information with these Third Parties, but only to the extent necessary to perform these functions and provide such services, and only if such Third Parties are obligated not to use or disclose your Personal Information for any other purpose.
- Marketing – Internet Based Advertising and Third Party marketing. We may share aggregated information that includes your Personal Information, non-identifying information and Usage Tracking Information with Third Parties for industry analysis and demographic profiling and to deliver targeted advertising about other products and services. Through our Services, Full Sail may allow Third Party advertising partners to set tracking tools (e.g., cookies) to collect information regarding your activities (e.g., your IP address, page(s) visited, time of day). We may also share such de-identified information (such as demographic information and past purchase history) as well as selected Personal Information we have collected with Third Party advertising partners. These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit non-Full Sail related websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising. We may allow access to other data collected by the Sites to facilitate transmittal of information that may be useful, relevant, valuable or otherwise of interest to you. If you prefer that we do not share your Personal Information with Third Party advertising partners, you may opt out of such sharing at no cost by following the instructions in below.
- Affiliated Schools. If you contact us to request information regarding our courses or degree programs, we may share your Personal Information with our affiliated schools including the Los Angeles Film School, Rocky Mountain College of Art and Design, DC3 Education, and Full Sail Labs. Our affiliated schools may use your Personal Information to contact you to provide information regarding their courses and degree programs; for more information, see the Privacy Policies of affiliated schools.
- Compliance with Laws and Law Enforcement. Full Sail cooperates with government and law enforcement officials and private parties to enforce and to comply with applicable law or valid legal process. Full Sail may disclose information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect the property and rights of Full Sail or a Third Party, to protect the safety of the public or any person or to prevent or stop activity we may consider to be, or to pose a risk of being, any illegal, unethical or legally actionable activity, or if we in good faith, believe that disclosure is otherwise necessary or advisable.
4.2 INTERNATIONAL DATA TRANSFERS
5. OPT-OUT RIGHT (RIGHT TO OBJECT TO PROCESSING)
You have the right to object to and opt out of certain uses and disclosures of your Personal Information. Where you have consented to Full Sail’s Processing of your Personal Information or Sensitive Personal Information, you may withdraw that consent at any time and opt out of further Processing by contacting:
- Full Sail University
3300 University Boulevard
Winter Park, FL 32792
You can use the same contact information above to request information under California Civil Code Section 1798.83.
Even if you opt out, we may still collect and use non-Personal Information regarding your activities on our Sites and/or information from the advertisements on Third-Party websites for non-interest based advertising purposes, such as to determine the effectiveness of the advertisements.
5.1 EMAIL, SMS, AND MESSAGING APP COMMUNICATIONS
For details on how to opt-out from SMS text messages, click here.
To opt-out of receiving messages from Full Sail via messaging apps (e.g., WhatsApp, Skype, and WeChat), please send the word “opt-out” to the Full Sail representative communicating with you. If you have any issues or questions, please contact us at firstname.lastname@example.org.
5.2 MOBILE DEVICES
Full Sail may occasionally send you push notifications through our mobile applications with notices that may be of interest to you. You may at any time opt out from receiving these types of communications by changing the settings on your mobile device. Full Sail may also collect location-based information if you use our Mobile Apps. You may opt out of this collection by changing the settings on your mobile device.
5.3 COOKIES AND INTEREST-BASED ADVERTISING
As noted above, you may stop or restrict the placement of cookies on your computer or remove them from your browser by adjusting your web browser preferences. Please note that cookie-based opt outs are not effective on mobile applications. However, on many mobile devices, application users may opt out of certain mobile ads via their device settings.
The online advertising industry also provides websites from which you may opt out of receiving targeted ads from our data partners and our other advertising partners that participate in self-regulatory programs. You can access these, and also learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/managing/opt_out.asp, or www.youronlinechoices.eu and www.aboutads.info/choices. You can also choose not to be included in Google Analytics here.
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
6. RIGHTS OF ACCESS, RECTIFICATION, ERASURE AND RESTRICTION
Although we make good faith efforts to provide Individuals with access to their Personal Information, there may be circumstances in which Full Sail is unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the Individual’s privacy in the case in question or where it is commercially proprietary. If Full Sail determines that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, Full Sail will take commercially reasonable steps to verify your identity before granting access to or making any changes to your Personal Information.
7. DATA RETENTION
8. SECURITY OF YOUR INFORMATION
The security of your Personal Information is important to us. But remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure, and we cannot ensure or warrant the security of any information you provide to us. When you enter sensitive information (such as credit card number or social security number) on our registration or order forms, we encrypt that information using secure socket layer technology (SSL). In some cases, we also encrypt sensitive information where it is stored on our systems. We do not accept liability for unintentional disclosure.
By using the Sites or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Sites. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Sites or sending an e-mail to you. You may have a legal right to receive this notice in writing.
Identity theft and the practice currently known as “phishing” are of great concern to Full Sail. Safeguarding information to help protect you from identity theft is a top priority. We do not and will not, at any time, request your credit card information, your login information, or national identification numbers in a non-secure or unsolicited e-mail or telephone communication. For more information about phishing, visit the Federal Trade Commission’s website.
9. INTERNATIONAL USERS
If you are visiting from the European Union or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your information to the United States and to Processing of your data globally. By providing your Personal Information, you consent to any transfer and Processing in accordance with this Policy.
10. OUR POLICY TOWARD CHILDREN
The Sites and Mobile Apps are not directed to children under 13, or other age as required by local law. We do not knowingly collect Personal Information from children, or other age as required by local law. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, he or she should contact us at email@example.com. If we become aware that a child under the age of 13 (or other age as required by local law) has provided us with Personal Information without verifiable parental consent, we will promptly take steps to delete such information from our files and terminate the child’s account.
11. OTHER RIGHTS AND IMPORTANT INFORMATION
- New Uses of Personal Information. Additionally, before we use Personal Information for any new purpose not originally authorized by you, we will endeavor to provide information regarding the new purpose and give you the opportunity to opt out. Where consent of the Individual for the Processing of Personal Information is otherwise required by law or contract, Full Sail will endeavor to comply with the law or contract.
11.2 CALIFORNIA PRIVACY RIGHTS
The following capitalized terms shall have the meanings herein as set forth below:
- “Agent” means any Third Party that Processes Personal Information pursuant to the instructions of, and solely for, Full Sail or to which Full Sail discloses Personal Information for use on its behalf.
- “Personal Information” is any information relating to an identified or identifiable natural person (“Individual”) such as your name, home address, email address, telephone number or payment card number, social security number, and official, or government-issued, ID information.
- “Process” or “Processing” means any operation which is performed upon Personal Information, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction. As used in this policy, the terms “using” and “processing” information include using cookies on a computer, subjecting the information to statistical or other analysis and using or handling information in any way, including, but not limited to collecting, storing, evaluating, modifying, deleting, using, combining, disclosing and transferring information within our organization or among our affiliates within the United States or internationally.
- “Third Party” is any company, natural or legal person, public authority, agency, or body other than the individual, Full Sail, or Full Sail’s Agents.