Focus Education System is committed to ensuring the privacy and accuracy of your confidential information. As part of its commitment to maintain the privacy of its users, FES has developed this privacy statement.
The statement has two purposes:
To educate users about privacy issues.
To inform users about specific privacy policies and guidelines employed at FES.
While FES has not and will not share, provide, or sell Personal Information with third parties for their own marketing purposes the College may actively share your information to facilitate, manage and improve our services.
This may include third parties or vendors whom the College has engaged as School Officials who help the College with marketing, advertising, or promotion. FES may also share your Personal Information with government and law enforcement agencies or regulators to respond to subpoenas, court orders, or any other legal requirements or when it is necessary to protect and defend the legal rights of the College or to protect your safety and/or the public’s safety.
“School Officials” means employees of the College, including faculty and staff, as well as certain individuals such as vendors or contractors, performing work for the College under proper authorization.
“Personal Information” means any non-public information (paper or electronic) that can be used to distinguish, identify, or contact a specific individual. This includes account information, social security numbers, grades, and financial or health data as well as any other information that is not considered public. Also included is all information required to be protected under the Gramm-Leach-Bliley Act (“GBLA”), namely, (a) any non-public personal information (i) a student or other third party provides in order to obtain a financial service from FES, (ii) about a student or other third party resulting from any transaction with FES involving a financial service, or (iii) otherwise obtained about a student or other third party in connection with providing a financial service to that person; and (b) personally identifiable information as defined under state cybersecurity laws.
For State of California residents “personal information” under the CCPA (California Consumer Privacy Act) includes any information that “identifies, relates to, describes, references, or could reasonably be linked, directly or indirectly, with a particular consumer or household,”
“College’s Technology Services” – include all College technologies and related forms such as the College website, mobile applications and text, surveys, college chat boards, etc. where you may provide personal information voluntarily through the use of technology platforms and the completion of forms required for business purposes.
FES also complies with the Family Educational Rights and Privacy Act (“FERPA”) administered by the U.S. Department of Education. FERPA protects students’ personal identifiable information (PII) and prohibits the release of education records without students’ permission or consent. Information on the College’s FERPA policy and practices may be found here.
The law allows us to share your account information or other personal information with non-affiliated companies when the information is used for financial transactions (Gramm-Leach-Bliley Act, Part V, § 14-15). The following are circumstances when non-affiliated parties might be given personal information:
Services providers to the extent necessary to enable us to provide you with the products and services you have requested, process transactions, and maintain accounts.
Credit reporting agencies in accordance with the Fair Credit Reporting Act
In connection with a proposed or actual sale, merger, transfer, or exchange of all or a portion of a business or operating unit.
When legally required to comply with a properly authorized civil, criminal, or regulatory investigation, or subpoena or summons by Federal, State, or local authorities.
When otherwise required to comply with Federal, State, or local laws, rules and other applicable legal requirements
This policy is effective specifically for the Focuseducationsys.com website and domain, and any student information systems learning management systems, or student or public communications platforms utilized by the College, collectively known as the “College’s Technology Services”.
Information Gathered by FES
When you visit theFocuseducationsys.com domain and website our web servers may generate temporary logs that may contain the following Personal Information:
Sites within FES may enable you to pay for products or services online with a credit card. Although FES makes every effort to ensure that the third parties providing these transactions are encrypted, FES is not responsible for the privacy practices of these external third parties.
Although no computer system is 100% secure, FES has deployed extensive security measures to protect against the loss, misuse, or alteration of the information collected through the Colleges’ services and under our control. FES maintains physical, electronic, and procedural safeguards that comply with federal standards to guard your nonpublic Personal Information. We continually review our policy and practices, monitor our computer networks, and independently test the strength of our security to help us ensure the safety of Confidential Information. These security measures and our systems are routinely audited and updated by FES security specialists.
Digital Millennium Copyright Act (DMCA)
The Digital Millennium Copyright Act (DMCA), described as the most dramatic change to copyright law in a generation, was the 105th Congress’s effort to update copyright law for the digital environment. Please be aware that in accordance with Section 512(i)(1)(a) of the DMCA, ACE reserves the right to terminate computing services of users who repeatedly infringe upon the rights of copyright owners.
California Privacy Act (CCPA)
FES student information systems and learning management systems, and similar, the College may collect Personal Information that you knowingly and voluntarily provide when completing applications and forms, sending emails, registering for classes or other programs or responding to surveys, we may collect “Personal Information. “Personal Information” may include:
Email address, account name, Social Security number, driver’s license number, and passport number.
Personal information under California’s records destruction law (Cal. Civ. Code §1798.80(e)).
Characteristics of protected classifications under California or federal law.
Commercial information, including records of personal property, products, or services purchased, obtained, or considered.
Internet or network activity.
Audio, electronic, visual, thermal, olfactory, or similar information.
Professional or employment-related information.
Education information that is not publicly available personally identifiable information, as defined in the Family Educational Rights and Privacy Act (20 USC § 1232(g), 34 CFR Part 99).
Inferences drawn from any of the information listed above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Personal Information under the CCPA does not include aggregate consumer information,” which is defined as data that is “not linked or reasonably linkable to any consumer or household, including via a device,” as well as information that is publicly available from federal, state, or local government records.
As a California resident pursuant to the CCPA, you have certain rights. This Privacy Notice summarizes what these rights are and how you can exercise these rights. More detail about each right, including exceptions and limitations, can be found in Title 1.81.5. California Consumer Privacy Act of 2018.
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