Effective Date: November 13, 2020

 

1. PRIVACY POLICY

 

1.1 Introduction

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Mars University (“MarsU, “we,” “us,” and “our”) takes your privacy seriously. This Privacy Policy has been designed to answer your questions about your privacy rights while you engage MarsU’s websites ( “Sites”), as well as when you participate in MarsU programs and events and/or license our content and/or software products (collectively, “Solutions”). If you need more information, please refer to the Contact Section of this Policy below.

 

1.2 Purpose

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This Policy applies to MarsU Sites and Solutions that link or reference this Policy. This Policy describes how MarsU collects, uses, shares, and otherwise processes Personal Data, as defined in the section below, and the choices available to you regarding: (1) how we collect, use, and access your Personal Data; and (2) how to confirm your Personal Data is updated, corrected, and/or deleted. Additional terms and information about MarsU’s Personal Data handling practices may be provided in offer descriptions, supplement statements, or contract terms, or notices provided prior to or at the time of information collection.

 

1.3 Definition of Personal Data

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“Personal Data” is any information that can be used to identify an individual, and may include, but is not limited to, for example, name, address, email address, phone number, login information (account number, password), marketing preferences, social media account information, IP addresses, location data (if combined with other identifiers), personal identification numbers (passport numbers, social security numbers, etc.), photos, video footage, audio recordings, payment card number, criminal record, educational and professional records, and any form of biometric, health, genetic, racial, religion, political affiliation, gender-based, sexual preference, age-related, or other identifying personal data. If we link other data with your personal information, we will treat that linked data as Personal Data. We also collect Personal Data from trusted third-party sources and engage third parties to collect Personal Data to assist us.

 

Our Site may contain links to other websites, applications and services maintained by third parties. The information practices of such other services, or of social media networks that host our branded social media pages, are governed by third parties’ privacy statements, which we encourage you to review to better understand those third parties’ privacy practices.

 

MarsU acts as a “data controller” (defined terms used that are not otherwise defined in the Policy are defined terms used in the EU General Data Protection Regulation (“GDPR”)). For more information on the GDPR, please go to https://gdpr-info.eu/.

 

1.4 Collection and Use of Your Personal Data

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We may collect a variety of information, including Personal Data, about you as you use our Sites and Solutions and interact with us. A summary of what we collect and how we use the Personal Data associated with our Sites and Solutions is compiled for your convenience below. 

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2. Information You Give Us

 

2.1 Community Membership Profile. 

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When you become a MarsU community member, we collect information about you including (but not limited to) your name, your employer’s name, your work address (including your country location), and your email address. We may also collect your personal email address, a personal mailing address, and a mobile phone number. We ask members to voluntarily provide additional information in their membership profile, such as information about their educational background, professional experience, interests in research and technologies, a photo, social media identifiers, and some other information. Members may edit their profile at any time to change, add, or remove Personal Data.

 

We process your Personal Data for admissions and administration purposes, to deliver benefits to you, and to inform you of MarsU-related events, content, and other benefits or opportunities associated with your MarsU membership. We may also use this information to help us understand our students’ and members’ needs and interests to better tailor our Site and Solutions to meet your needs.

 

We may collect registration information from MarsU users, community members and their guests, which we may share with a sponsoring MarsU partner and location hosts for purposes of verifying registration and to ensure only registered guests are allowed attendance.

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2.2 Personal Data Provided at Live or Web Programs and Events

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MarsU hosts many events throughout the year. These include in-person and web-based conferences, summits,seminars series, and other in-person as well as virtual gatherings (collectively, “events”). If you register for one of our events and you are a member, we will access the information in your member account to provide you with information and services associated with the event. If you are not a member and you register for one of our events, we will collect your name, telephone number, address, email address and select other information, which we will store in our database(s) and use to provide you with information and services associated with the current and future events, MarsU community membership and MarsU content.

 

If you are a presenter or speaker at one of our events, we will collect information about you including your name, employer, educational and professional background, contact information, and photograph. We may collect information provided by event attendees who evaluated your performance as a presenter. We may also make and store a recording of your voice in certain instances.

 

Some of our events are sponsored. We may provide an attendee list to certain sponsors. If you do not wish to have your information shared with a sponsor or to receive information from sponsors, you can express your preferences when you register for events.

 

2.3 Personal Data Provided to Acquire Content Access

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We offer exciting content for MarsU’s community members and non-community members. In addition to producing original content, we also subscribe to news feeds and blogs produced by others, which we link to and from our website. This means you may find yourself on an MarsU site or reading MarsU content and we will offer you a link to another organization’s website where you will find content on research and technologies that our faculty and/or staff find relevant and useful to you. At these times, you will be leaving the MarsU Site(s). MarsU is not responsible or liable for content provided by these third-party websites or Personal Data they may happen to gather from you.

 

You may manage your MarsU subscriptions by subscribing or unsubscribing at any time. Please note that if you have set your browser to block cookies, this may have an impact on your ability to unsubscribe. If you have any difficulties managing your email or other communication preferences with MarsU, please contact us at info@mars.university.

 

We use Google Analytics to track how often people gain access to or read our content. We use this information in the aggregate to understand what content our community members find useful or interesting, so we can produce the most valuable content to meet your needs.

 

We also conduct surveys that we use to evaluate content quality and relevance to our MarsU community. We do not track individuals but look at information in the aggregate only. Participation in surveys is voluntary.

 

2.4 Personal Data Provided in Site or Solution Forums and Chat Rooms

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If you participate in an MarsU community member or cohort forum or chat room on an MarsU Site or Solution, the information, including Personal Data, you provide there will be made available to others, and could be used to contact you, send you unsolicited messages, or for other purposes over which neither MarsU nor you will have control. Forums, chat rooms, and social media controlled by individual members of the MarsU member community may have additional rules and conditions or none at all. As further described in the Terms and Conditions Contract applicable to Sites and Solutions, MarsU is not responsible for the Personal Data or any other information you choose to submit in these forums. To request removal of your Personal Data from forums and chat rooms located on MarsU Sites, please contact us using the Personal Data Access Request Form. In some situations, due to current technology limitations, it may not be feasible to remove some or all of your Personal Data from these forums.

 

2.5 Personal Data Provided for Training

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You may sign up directly with us to participate in our in-person or on-line training courses delivered over a learning management system (LMS), in which case we collect your name and contact information directly from you. Alternatively, your employer or an MarsU partner may register you to participate in the training. Your Personal Data will be stored in our database (hosted by a cloud service provider) and may also be shared with a delivery partner or co-sponsor of the training program (to verify numbers and attendance rates), trainers (to determine the experience level, industry, and the demographics of the target audience(s)), and/or vendors supporting event delivery (to verify your identity).

 

2.6 Personal Data Provided in Correspondence with MarsU

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If you correspond with us by email, the postal service, or other form of communication, we may retain the correspondence and the information contained in it and use it to respond to your inquiry and to keep a record of the complaint, accommodation, or other request.

 

If you ask us not to contact you by email at a certain email address, MarsU will retain a copy of that email address on its “master do not send” list in order to comply with your no-contact request.

 

2.7 Personal Data Provided to Process Payment

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You may purchase Solutions using a payment card. Payment card information may be provided directly by users, via a MarsU Site or authorized third party event registration vendor site, into the PCI/DSS-compliant payment processing service to which MarsU subscribes. We do not process or store the card information. Occasionally, members or customers ask MarsU employees or MarsU volunteers to enter payment card or other financial account information into the payment processing service to which MarsU subscribes. We strongly encourage you not to submit this information by email. When MarsU employees receive payment card or other financial account information from customers or members by email, phone, or mail, it is entered as instructed and then deleted or destroyed.

 

2.8 Personal Data Received from Third Parties

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Periodically, MarsU receives Personal Data about individuals from third parties. For example, this may happen if your employer is participating in a program and signs you up for an event, training, MarsU membership, or MarsU Solution access. MarsU may also collect Personal Data about prospective employees, faculty, vendors, contractors, and partners from due diligence vendors who conduct business and criminal history background checks on information available from the public domain. Additionally, MarsU may combine or append information it receives from third parties, including Personal Data, with other Personal Data it has collected.

 

3. Personal Data Collected Electronically

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3.1 Personal Data Collected on Sites

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We use common information-gathering tools, such as log files, embedded web links, web beacons, and cookies, to automatically collect certain standard information that your browser sends back to our Site(s). Examples include:

 

Browser type and version

Address of the website from which you arrived at our Site

Your Internet Protocol (IP) Address

Clickstream behavior, meaning the pages you view and the links you click.

These tools help make your visit to our Sites easier, more efficient, and more valuable by providing you with a customized experience and recognizing you when you return.

 

3.2 Use of Google Analytics and Other Backend Analytics Tools

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We use Google Analytics, a service that transmits our Site traffic to Google servers in the United States of America. Google Analytics does not identify individual users or associate your IP address with other data held by Google. We use reports and data provided by Google Analytics and other website traffic tracking services to help us understand our Site traffic trends and usage. For more information regarding how Google collects and processes data, please visit www.google.com/policies/privacy/partners.

 

3.4 Do Not Track Option

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Some web browsers may give you the ability to enable a “do not track” feature that sends signals to the MarsU Sites you visit, instructing that you do not want your online activities to be tracked; however, these features are not yet uniform and there is no common standard that has been adopted by industry groups, technology companies or regulators. Be aware that this is different from blocking or deleting cookies, and that browsers with “do not track” features enabled may still accept cookies. MarsU takes privacy and meaningful choice seriously and will make efforts to continue to monitor developments around DNT browser technology and the implementation of a standard. While MarsU Sites do not currently recognize and respond to “do not track” signals, if we do in the future, we will describe how in this Policy.

 

3.5 MarsU Cookies Statement

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To learn more about how to update your choices in relation to cookies and other web browsing technologies, please go to the MarsU Cookies Statement.

 

3.6 Personal Data Use Summary

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Personal Data you provide to us is used either to respond to requests that you make or to aid us in serving you better. For additional information about the type(s) of Personal Data we typically collect and how we use it by Site and Solutions, please visit this link. A summary of the ways we may use your Personal Data is set forth below:

 

• To create and secure your community membership account;

• To deliver the Solutions, products, and services you request;

• To manage your accounts and maintain our business operations;

• To identify you as a user and allow you access into our proprietary system;

• To optimize and improve our Sites, Solutions, and services;

• To protect the security and effective functioning of our Sites and information technology systems;

• To send you administrative email notifications;

• To contact you, and to respond to and track progress of your inquiries;

• To detect, investigate, and prevent illegal or non-compliant activities;

• To address our compliance and legal obligations and exercise our legal rights;

• To make phone calls to you, from time to time, to solicit feedback or provide secondary fraud protection; and

• To send you marketing information, product recommendations, newsletters, and other non-transactional communications about us, our affiliates and partners for purposes of conducting legitimate direct marketing. Please see “Your Rights and Choices Regarding Your Personal Data” to learn how you can control the processing of your Personal Data by MarsU for marketing purposes.

 

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4.0 Sharing Your Personal Data with Third Parties

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We may share your Personal Data with third parties for the purposes of operating our business, delivering, improving, and customizing our Sites, Products, Services, Solutions, sending marketing and other communications related to our business, and for other legitimate purposes permitted by applicable law or otherwise with your consent. We may share Personal Data in the following ways:

 

• Within MarsU and any of our subsidiaries or affiliates for purposes of data processing, storage, and/or marketing;

• With business partners, service vendors, or contractors to provide a requested Site content or enhancements, a Solution, a service or a transaction. Examples include, but are not limited to: processing of orders and credit/debit card transactions, hosting websites, customer and faculty relationship management, admissions, hosting event and program planning and registration, assisting with sales-related efforts or post-sales support, delivering content, Solutions, or services, and providing customer support;

• With service vendors focused on the provision, payment, and auditing of employee, vendor, contractor, faculty and moderator benefits;

• With search engine, web analytics, and survey providers engaged to track trends and other statistics to enhance the user and member experience;

• In connection with, or during negotiations of, any merger, sale of MarsU assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or to another company;

• In response to a request for information by a competent authority if we believe disclosure is in accordance with, or is otherwise required by, any applicable law, regulation or legal process;

• With law enforcement officials, government authorities, or other third parties as necessary to comply with legal process or meet national security requirements; protect the rights, property, or safety of MarsU, its partners, you, or others; or as otherwise required by applicable law.

• In aggregated, anonymized, and/or de-identified form which cannot reasonably be used to identify you; and/or if we otherwise notify you and you consent to the sharing.

 

MarsU Sites and select Solutions use interfaces with social media sites such as Facebook, LinkedIn, Instagram, Twitter and others. If you choose to “like” or share information from MarsU Sites or Solutions through these services, you may review the privacy policy of that service. If you are a member of a social media site, the interfaces may allow the social media site to connect your site visit to your Personal Data.

 

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5. International Sharing of Personal Data

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MarsU is headquartered in the United States and Personal Data we collect from you will be processed in the United States. The United States has not sought nor received a finding of “adequacy” from the European Union under Article 45 of the GDPR. We aim to collect and transfer Personal Data only: i) with your consent; ii) to perform a contract with you; or iii) to fulfill a compelling legitimate interest in a manner that does not outweigh your rights and freedoms.

 

By providing us with your Personal Data, you acknowledge and agree that we may from time to time transfer any of your Personal Data to any of our offices, agents, partners, or appointed representatives located around the world. We are implementing appropriate safeguards for transfers of Personal Data originating from the European Economic Area (EEA) to countries located outside of the EEA. These safeguards include implementing standard data protection clauses that have been approved by the European Commission or (in relation to transfers from the European Union to the USA) transferring Personal Data to entities that have signed up to the EU-U.S. Privacy Shield. Please do not submit any Personal Data to us if you do not wish for your data to be transferred internationally.

 

6. Your Rights and Choices Regarding Your Personal Data

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MarsU encourages you to keep your Personal Data accurate and current. In addition, you have the right to ask us not to process your Personal Data for marketing purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data, clicking the unsubscribe button on any communication we have sent to you or by contacting us.

 

Where you have consented to allowing us to use your Personal Data, you can withdraw that consent at any time. If the information we hold about you is inaccurate or incomplete, you can notify us and ask us to correct or supplement it. You may request that we erase that Personal Data or cease processing it, subject to certain exceptions. You also have the right, with some exceptions and qualifications, to ask us to provide a copy of any Personal Data we hold about you.

 

You may also request information about: (i) the purpose of the processing; (ii) the categories of Personal Data concerned; (iii) who else other than MarsU might have received the Personal Data; (iv) what the source of the information was (if you didn’t provide it directly to us); and (v) how long it will be stored.

 

Where you have provided your data to us and it is processed by automated means, you may be able to request that we provide it to you in a structured, readable format.

 

We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to enable us to deal with your request or to speed up our response.

 

Reasonable access to a record of your Personal Data will be provided at no cost on request made via any communication means. We may charge a reasonable fee if your request(s) is clearly unfounded, repetitive, or excessive; alternatively, we may refuse to comply with your request(s) in these circumstances. If access cannot be provided within a reasonable time frame, we will provide you with an estimated date when a record of the Personal Data will be provided. If for some reason we cannot supply you with a record of the Personal Data we have collected, used, and/or stored, we will provide an explanation as to why we cannot provide the record.

 

If you have a complaint about how we have handled your Personal Data, you may be able to ask us to restrict how we use it while your complaint is resolved. In some circumstances you can ask us to erase your Personal Data:

 

• by withdrawing your consent for us to use it;

• if it is no longer necessary for us to use your Personal Data;

• if you object to the use of your Personal Data and we don’t have a good reason to continue to use it; or

• if we haven’t handled your Personal Data in accordance with our obligations.

 

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7. Security of Your Personal Data

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MarsU will protect the Personal Data entrusted to us and treat it securely in accordance with this Policy. MarsU implements various physical, administrative, and technical measures designed to protect your Personal Data from unauthorized access, use or disclosure. We contractually require our critical vendors to protect such information from unauthorized access, use and disclosure. We restrict access to your Personal Data to those who need to know that information to provide Solutions or other benefits to you. In addition, we train our employees about the importance of confidentiality and maintaining the privacy and security of your information. We commit to taking appropriate disciplinary measures to enforce our employees’ privacy responsibilities.

 

We may require you to enter a password to access Personal Data associated with your MarsU account and membership. Please do not disclose your account password to unauthorized people. Note, however, that no method of transmission over the Internet, or method of electronic storage, is 100% secure. While we use reasonable efforts to protect your Personal Data, we cannot ensure or warrant the security of any Personal Data you provide to us.

 

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8. Retention of Personal Data

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We will retain your Personal Data for the period required to fulfill the purposes for which it has been collected. These purposes may include the need to fulfill various commercial and legal requirements. Key requirements driving the need for collection, analysis and storage of Personal Data may include but not be limited to the following: business strategy, student outreach and engagement, resource planning, legal compliance, financial reporting, dispute resolution, asset protection, agreement enforcement, etc.

 

Your Personal Data is stored by MarsU on servers of the cloud-based database management services we engage, located primarily in the United States. Unless you request otherwise, we will retain data for the duration of your business relationship with us or for as long as is required by law. For more information on where and how long your Personal Data is stored, please contact info@mars.university.

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9. Children’s Privacy

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We encourage parents and guardians to take an active role in their children’s online activities. We do not knowingly collect Personal Data from minors under the age of eighteen (18) without appropriate parental or guardian consent. If you believe that we may have collected Personal Data from someone under the applicable age of consent in your country without proper consent, please let us know and we will take appropriate measures to investigate and address the issue promptly.

 

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10. Changes to this Policy

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By using this Site and/or Solutions, you agree to the terms and conditions contained in this Policy and Terms and Conditions and/or any other agreement that we might have with you. If you do not agree to any of these terms and conditions, you should not use this Site, Services, Products, and/or Solution.

 

We may revise this Policy on occasion. If we make any significant changes to the way we intend to use your Personal Data we will notify you by sending you an email to the current email address you provided and by prominently posting the changes on our Sites and Solutions. Changes will be effective no later than thirty (30) days following notification. You are responsible for making certain that we have your current email address on file. If the email address we have on file is invalid, our dispatch of the email to your last known email address along with posting the notice of Policy changes on our Sites will constitute effective notice of the changes. If you do not wish to permit the changes in the use of your Personal Data, you must notify us prior to the effective date of the changes. Continued use of our Services or Solutions following notice will indicate your acknowledgement of, and agreement to be bound by, the changes until such time that you notify us you would like to deactivate your account and/or have your Personal Data deleted as set forth in the “How to Contact Us” section of this Policy.

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11. Additional Policies

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Certain services and solutions provided by or through MarsU may be subject to additional privacy terms or Personal Data disclosures (collectively, “Additional Policies”). In the event of any direct conflict between any Additional Policies and this Policy, the Additional Policies will control.

 

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12. California Privacy Rights

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Under California’s “Shine the Light” law, California residents may request once annually that MarsU disclose select information we have shared about them, if any, with other businesses for their own direct marketing uses. If applicable, responses will include categories of customer information and the names and addresses of the businesses with which we shared information for the immediately prior calendar year (e.g., requests made in 2021 will receive information regarding 2020 sharing activities, if any). Note that not all Personal Data or information sharing is covered by the “Shine the Light” requirements.

 

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How to Contact Us

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1. Questions about this Policy

Should you have any queries regarding this Policy or how your information is collected, used and stored, please contact info@mars.university or mail us at the following location:

 

Mars University

4646 13th St N

Arlington, VA, 22207

 

2. Contacting MarsU to Request Access to Personal Data or to Report a Suspected Breach of Personal Data

a) If you wish to engage your rights to access, correct, modify, or delete your Personal Data, please contact us.

 

b) If you want to report a suspected breach of your Personal Data, please notify MarsU faculty and/or staff.