MHEC Privacy Policy

Effective as of November 22, 2022

This “Privacy Policy” describes the privacy practices of the Midwestern Higher Education Compact (MHEC), in connection with the https://www.mhec.org website and any other website(s) that we own or control and which posts or links to this Privacy Policy as well as, without limitation,

• MHEC’s Interactive Dashboard
• Midwest Student Exchange Program (MSEP)
• Graduate Credit Quest (GCQ)

This Privacy Policy also describes the use and disclosure of Your information when You use the Service. MHEC may provide additional or supplemental privacy policies to individuals for specific services that we offer at the time we collect personal information. These supplemental privacy policies will govern how we may process the information in the context of the specific service.

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

• Account means a unique account created for You to access our Service or parts of our Service.
• Business,  refers to the Company as the legal entity that collects Your personal information and determines the purposes and means of the processing of Your personal information, or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of Your personal information
• Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to Midwestern Higher Education Compact (MHEC) .
•  Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.
• Country refers to: Minnesota, United States
• Device means any device that can access the Service such as a computer, a cell phone or a digital tablet.
• Do Not Track (DNT) is a concept that has been promoted by US regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites.

Personal Data is any information that relates to an identified or identifiable individual.

• Personal Data means any information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with You.
• Sale means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, your personal information to another business or a third party for monetary or other valuable consideration.

Service refers to the Website.

• Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.
• Third-party Social Media Service refers to any website or any social network website through which a User can log in or create an account to use the Service.
• Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
• Website refers to MHEC, accessible from https://www.mhec.org
• You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

Collecting and Using Your Personal Data

MHEC offers a variety of Services and correspondingly, we collect personal information from a variety of sources and for a variety of reasons, and not all of the below categories of information or sources of information will be relevant to all Service users.  Rather, the scope and sources of information are dependent upon the particular Service and your engagement with MHEC.

Types of Data Collected

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

• Organizational, personal, and emergency contact information, such as:
  • Your first and last name, phone number, email and mailing addresses, phone number, professional title, institutional/organizational name and digital signature.
  • Content you choose to upload to the Service, such as text, images, audio, and video, along with the metadata associated with the files you upload.
• Account information, such as username and access credentials for an online account to access the Service.
• Registration information, such as information that may be related to a service, an account or an event for which you register.
• Feedback or correspondence, such as information you provide when you contact us with questions, feedback, or otherwise correspond with us online.
• Testimonial information, such as information you provide when you submit a testimonial regarding your experience with the Service.
• Educational information, such as educational institutions attended, student identification number, target field of study, program year.
• Demographic Information, such as your gender, ethnicity, race, city, state, territory, country of residence, and postal code.
• Financial information, financial account number and payment card information.
• Transaction information, such as information about payments to and from you and other details of the services or educational engagements.

Usage Data

• Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
• When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.
• We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.
• Marketing information, such as your preferences for receiving communications about our activities, events, and publications, and details about how you engage with our communications staff.
• Other information that we may collect which is not specifically listed here, but which we will use in accordance with this Privacy Policy or as otherwise disclosed at the time of collection.

Information from Third-Party Services

• We may maintain pages for MHEC on social media platforms, such as Facebook, LinkedIn, Twitter, Google, YouTube, Instagram, and other third-party platforms. When you visit or interact with our pages on those platforms, the platform provider’s Privacy Policy will apply to your interactions and their collection, use and processing of your personal information. You or the platforms may provide us with information through the platform, and we will treat such information in accordance with this Privacy Policy.
• Information we obtain from other third parties. We may receive personal information about you from third-party sources. For example, educational institutions and/or state agencies may share your information with us if you have expressed interest in learning about our services or the types of services we offer.

Tracking Technologies, Cookies, and Other Information Collected by Automated Means

We, our service providers, and our partners may automatically log information about you, your computer or mobile device, and activity occurring on or through the Service, including but not limited,  your computer or mobile device operating system type and version number, manufacturer and model, device identifier (such as the Google Advertising ID or Apple ID for Advertising), browser type, screen resolution, IP address, the website you visited before browsing to our website, general location information such as city, state or geographic area; information about your use of and actions on the Service, such as pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and length of access; and other personal information. Our service providers and partners may collect this type of information over time and across third-party websites and mobile applications.

On our webpages, this information is collected using cookies, browser web storage (also known as locally stored objects, or “LSOs”), web beacons, and similar technologies, and our emails may also contain web beacons.

A “cookie” is a text file that websites send to a website visitor‘s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. Browser web storage, or LSOs, are used for similar purposes as cookies. Browser web storage enables the storage of a larger amount of data than cookies. A “web beacon,” also known as a pixel tag or clear GIF, is typically used to demonstrate that a webpage was accessed or that certain content was viewed, typically to measure the success of our marketing campaigns or engagement with our emails and to compile statistics about usage of our websites.

Web browsers may offer users of our websites or mobile apps the ability to disable receiving certain types of cookies; however, if cookies are disabled, some features or functionality of our websites may not function correctly. Please see the “Targeted online advertising” section for information about how to exercise choice regarding the use of browsing behavior for purposes of targeted advertising.

Remarketing

A system that allows an advertiser to reach people who have previously visited their website or used an app, and match the right people with the right message.

From time-to-time MHEC does use re-engagement of audiences who have participated in MHEC events and/or programs and services in order to make them aware of similar events and programs and services based upon past participation.

At this time, MHEC does not use third-party vendors like Google (or specifically Google ads) for the purposes of advertising. Third-party vendors that MHEC works with, however, may be using cookies or other device identifiers to serve ads based on someone's past visits to their website or use of their app.

Visitors can opt out of Google's use of cookies or device identifiers by visiting Google's Ads Settings.
Google Signals. Google Signals is a feature of Google Analytics which provides insights into users' cross-device behavior. It uses aggregate data to reveal how people use their devices and better understand how users engage with websites and apps. This data is used to further personalize ad campaigns.

Referrals

Service users may have the opportunity to refer family members, professional contacts, colleagues, fellow students, or other contacts to us. If you are an existing user, you may only submit a referral if you have permission to provide the referral’s contact information to us so that we may contact them.

How We Use Your Personal Information

We use your personal information for the following purposes and as otherwise described in this Privacy Policy or at the time of collection.

To operate the Service. We use your personal information to:

• provide, operate and improve the Service;
• provide information about our services including, without limitation, our student access programs, collaboration with higher-education partners, and administrative and educational programs;
• establish and maintain your user profile on the Service;
• communicate with you about the Service, including by sending you announcements, updates, security alerts, and support and administrative messages;
• communicate with you about events in which you participate;
• enable security features of the Service, such as by sending you security codes via email or SMS or other means and remembering the devices from which you have previously logged into the Service;
• facilitate your ability to interact with others who use the Service such as by identifying and suggesting individuals with whom you should connect;
• understand your needs and interests, and personalize your experience with the Service and our communications;
• provide support and maintenance for the Service; and
• respond to your requests, questions and feedback.

For research and development. We analyze use of the Service to improve the Service and to develop new services, including by studying user demographics and use of the Service.  We may use this information for any purpose in our discretion information, including to inform educational and governmental decisions.
To send you marketing and promotional communications. We may send you MHEC-related marketing communications as permitted by law. You will have the ability to opt-out of our marketing and promotional communications as described in the Opt out of marketing communications section below.

To comply with law. We use your personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.

For compliance, fraud prevention, and safety.  We may use your personal information and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate to: (a) protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); (b) enforce the terms and conditions that govern the Service; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.

With your consent. In some cases we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.

To create anonymous, aggregated or de-identified data. We may create anonymous, aggregated or de-identified data from your personal information and other individuals whose personal information we collect.  We make personal information into anonymous, aggregated or de-identified data by removing information that makes the data personally identifiable to you. We may use this anonymous, aggregated or de-identified data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our functions.

How We Share Your Personal Information

• Service providers. We may share your personal information with third-party companies and individuals that provide services on our behalf or help us operate the Service (such as customer support, hosting, analytics, payment processing, event registration, email delivery, marketing, and database management services).
• Partners. We may share your personal information with partners. For example, if you attend an event that we host, we may share your information with other event sponsors. You should review the Privacy Policy of any such partner as we do not control how these partners may use your personal information.
• Educational institutions. We may share your personal information with your originating educational institution or the educational institutions in which you are interested in enrolling.  We may allow these educational institutions to collect information directly via our service. We do not control how these institutions may use your personal information. For information on how these institutions may use your personal information, please review the relevant institution’s Privacy Policy.
• State agencies. We may share your personal information with state educational agencies in your state of residence or the state/territory in which you are interested in enrolling in an educational institution. We do not control how these state agencies may use your personal information. For information on how these agencies may use your personal information, please refer to the specific agency to whom your personal information is disclosed.
• Other users of the Service and the public. We may provide functionality that enables you to disclose personal information to other users of the Service or the public. For instance, you may submit a testimonial or other content to the Service (such as comments, reviews, surveys, blogs, photos, and videos), and we will display your information such as your name and educational information along with the content you submit. We may also display your information in association with events that we host. We do not control how other users or third parties use any personal information that you make available to such users or the public.
• Professional advisors. We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.
• For compliance, fraud prevention and safety. We may share your personal information for the compliance, fraud prevention and safety purposes described above.
• Organizational change. We may transfer or otherwise share some or all of our organizational assets, including your personal information, in connection with an organizational change (or potential organizational change) such as a merger, consolidation, reorganization or sale of assets, or in the event of bankruptcy or dissolution.

Detailed Information on the Processing of Your Personal Data

The Service Providers We use may have access to Your Personal Data. These third-party vendors collect, store, use, process and transfer information about Your activity on Our Service in accordance with their Privacy Policies.

• Google Analytics. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy
• Dynamics 365 Marketing. Their Privacy Policy can be viewed at https://privacy.microsoft.com/en-us/privacystatement
• EventsAIR. Their Privacy Policy can be viewed at https://eventsair.com/privacy-policy/
• SimpleLists. Their Privacy Policy can be viewed at https://www.simplelists.com/privacy/
• Google Business Profile. The information gathered by Google Places is held in accordance with the Privacy Policy of Google: https://policies.google.com/privacy
• Usage, Performance and Miscellaneous. We may use third-party Service Providers to provide better improvement of our Service.

Your Choices

In this section, we describe the rights and choices available to all Service users. Access or Update Your Information. If you have registered for an account with us, you may review and update certain personal information in your account profile by logging into the account.

• Opt out of marketing communications. We may use Your Personal Data to contact You with newsletters, marketing, or promotional materials and other information that may be of interest to You. You may opt-out of receiving any, or all, of these communications from Us by following the unsubscribe link or instructions provided in any email We send or by contacting Us at privacy@mhec.org. You may continue to receive service-related and other non-marketing emails.
• Cookies and browser web storage. We may allow service providers and other third parties to use cookies and similar technologies to track your browsing activity over time and across the Service and third-party websites. Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that if you set your browser to disable cookies, the Sites may not work properly.  Similarly, your browser settings may allow you to clear your browser web storage.
• Targeted online advertising. Some of the business partners that collect information about users’ activities on or through the Service may be members of organizations or programs that provide choices to individuals regarding the use of their browsing behavior or mobile application usage for purposes of targeted advertising. Users may opt out of receiving targeted advertising on websites through members of the Network Advertising Initiative or the Digital Advertising Alliance []. European users may opt out of receiving targeted advertising on websites through members of the European Interactive Digital Advertising Alliance by selecting the user’s country, and then clicking “Choices” (or similarly titled link). Please note that we also may work with companies that offer their own opt-out mechanisms and may not participate in the opt-out mechanisms that we linked above. In addition, your mobile device settings may provide functionality to limit our, or our partners’, ability to engage in ad tracking or targeted advertising using the Google Advertising ID or Apple ID for Advertising associated with your mobile device. If you choose to opt-out of targeted advertisements, you will still see advertisements online but they may not be relevant to you. Even if you do choose to opt out, not all companies that serve online behavioral advertising are included in this list, so you may still receive some cookies and tailored advertisements from companies that are not listed.

• Do not track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit.  We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

• Choosing not to share your personal information. Where we are required by law to collect your personal information, or where we need your personal information in order to provide the Service to you, if you do not provide this information when requested (or you later ask to delete it), we may not be able to provide you with our services.  We will tell you what information you must provide to receive the Service by designating it as required at the time of collection or through other appropriate means.

Other Sites, Mobile Applications, and Services

The Service may contain links to other websites, mobile applications, and other online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or in mobile applications or online services that are not associated with us. We do not control third party websites, mobile applications or online services, and we are not responsible for their actions. Other websites, mobile applications and services follow different rules regarding the collection, use and sharing of your personal information. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.

Security Practices

The security of your personal information is important to us. We employ a number of organizational, technical and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies. We cannot guarantee the security of your personal information.

International Data Transfers

We are headquartered in the United States and may have service providers in other countries, and your personal information may be transferred to the United States or other locations outside of your state, province, or country where privacy laws may not be as protective as those in your state, territory, province, or country.

Sale of Personal Information of Individuals Under 16 Years of Age

We do not knowingly collect personal information from minors under the age of 16 through our Service, although certain third party websites that we link to may do so. These third-party websites have their own terms of use and privacy policies and we encourage parents and legal guardians to monitor their children's Internet usage and instruct their children to never provide information on other websites without their permission.

We do not sell the personal information of individuals We actually know are less than 16 years of age, unless We receive affirmative authorization (the "right to opt-in") from either the individualwho is between 13 and 16 years of age, or the parent or guardian of a individualless than 13 years of age. Individualswho opt-in to the sale of personal information may opt-out of future sales at any time. To exercise the right to opt-out, You (or Your authorized representative) may submit a request to Us by contacting Us.

If You have reason to believe that a child under the age of 13 (or 16) has provided Us with personal information, please contact Us with sufficient detail to enable Us to delete that information.

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service. We may, also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via e-mail (if you have an account where we have your contact information) or another manner through the Service.

Any modifications to this Privacy Policy will be effective upon our posting the new terms and/or upon implementation of the new changes on the Service (or as otherwise indicated at the time of posting). In all cases, your continued use of the Service after the posting of any modified Privacy Policy indicates your acceptance of the terms of the modified Privacy Policy.

How to Contact Us

Please direct any questions or comments about this Privacy Policy or privacy practices to privacy@mhec.org.

You may also write to us via postal mail at:

Midwestern Higher Education Compact
Attn: Legal - Privacy
105 Fifth Avenue South, Suite 450
Minneapolis, MN 55401