Ducerus Website Privacy Notice
Last updated: 23rd May 2018
Scope and consent
Ducerus respects your right to privacy. This Privacy Notice explains who we are, how we collect, share and use personal information about you, and how you can exercise your privacy rights. This Privacy Notice applies to personal information that we collect through our website at https://ducerus.com/ (our "Website") and via your use of our client portal.
The company you are contracting with is your data controller, and is responsible for the collection, use, disclosure, retention and protection of your personal information in accordance with our global privacy standards as well as any applicable national laws. Your data controller may transfer data to other members of the Ducerus corporate family as described in this Privacy Notice. We may process and retain your personal information on servers in the USA and elsewhere in the world where our cloud servers may be located.
"Personal information" is information that can be associated with a specific person and could be used to identify that specific person whether from that data or from that data and other information that Ducerus has or is likely to have access to. We do not consider personal information to include information that has been made anonymous or aggregated so that it can no longer be used to identify a specific person, whether in combination with other information or otherwise.
If you have any questions or concerns about our use of your personal information, then please contact us using the contact details provided at the bottom of this Privacy Notice.
1. What does Ducerus do?
Ducerus is a college planning service and financial planning provider. We operate as a franchise group headquartered in Carlsbad, CA (USA) with additional offices independently owned and operated under our licensed franchise agreements throughout the United states.
For more information about Ducerus, please see the "about" section of our Website at https://ducerus.com/about.
2. What personal information does Ducerus collect and why?
The personal information that we may collect about you broadly falls into the following categories:
Information that you provide voluntarily
Certain parts of our Website may ask you to provide personal information voluntarily: for example, we may ask you to provide your contact details in order to contact us about our services, to subscribe to marketing communications from us, and/or to submit enquiries to us, including via our chat feature. Depending on the portion of our website you are seeking information for, the data collected can be as limited as name, email, and phone, or as in depth as a full financial summary.
Information that we collect automatically
When you visit our Website, we may collect certain information automatically from your device. In some countries, including countries in the European Economic Area, this information may be considered personal information under applicable data protection laws.
Specifically, the information we collect automatically may include information like your IP address, device type, unique device identification numbers, browser-type, broad geographic location (e.g. country or city-level location) and other technical information. We may also collect information about how your device has interacted with our Website, including the pages accessed and links clicked.
Collecting this information enables us to better understand the visitors who come to our Website, where they come from, and what content on our Website is of interest to them. We use this information for our internal analytics purposes and to improve the quality and relevance of our Website to our visitors.
Some of this information may be collected using cookies and similar tracking technology, as explained further under the heading “Cookies and similar tracking technology” below.
In general, we will use the personal information we collect from you or your designated users only for the purposes described in this Privacy Notice or for purposes that we explain to you at the time we collect your personal information. However, we may also use your personal information for other purposes that are not incompatible with the purposes we have disclosed to you (such as archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes) if and where this is permitted by applicable data protection laws.
When we collect personal information from other legitimate sources, such as third-party data aggregators, Ducerus marketing partners, public sources or social media platforms. We only use this data if you have given your consent to them to share your personal data with others.
Where you have given your consent or where we have a justifiable reason for doing so (and are permitted to do so by law) we will use your information to let you know about our other products and services that may be of interest to you and we may contact you to do so by email or phone. You can control your email marketing preferences by scrolling to the bottom of any email marketing piece you have received from us, clicking "manage subscription" and updating your settings when prompted.
3. Who does Ducerus share my personal information with?
We use the personal information we collect to: provide and improve our Services, to provide you with a personalized experience on our website, to contact you about your account and our Services, to provide you customer service, to provide you with personalized advertising and marketing, and to detect, prevent, mitigate and investigate fraudulent or illegal activities. We may disclose your personal information to the following categories of recipients:
- to our group companies, third party services providers, contractors and partners who provide marketing or data processing services to us (for example, to support the delivery of, provide functionality on, or help to enhance the security of our Website), or who otherwise process personal information for purposes that are described in this Privacy Notice or notified to you when we collect your personal information;
- to any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person
- to any other person with your consent to the disclosure.
4. Legal basis for processing personal information (EEA visitors only)
If you are a visitor from the European Economic Area, our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.
However, we will normally collect personal information from you only where we have your consent to do so, where we need the personal information to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person.
If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).
Similarly, if we collect and use your personal information in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.
If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under the “How to contact us” heading below.
5. Cookies and similar tracking technology
6. How does Ducerus keep my personal information secure?
We use appropriate technical and organizational measures to protect the personal information that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information. For example, some of the measures we use include storing all information on a secured drives, deploying protected passwords, ensuring data is protected by passwords and that all individuals who undertake work for Ducerus are vetted and bound by confidentiality.
7. International data transfers
Ducerus is committed to adequately protecting your information regardless of where the data resides and to providing appropriate protection for your information where such data is transferred outside of the EEA.
Your personal information may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country (and, in some cases, may not be as protective).
Specifically, our Website and servers are located in the United States, and our group companies and third party service providers and partners operate around the world. This means that when we collect your personal information we may process it in a variety of countries.
However, we have taken appropriate safeguards to require that your personal information will remain protected in accordance with this Privacy Notice.
We will do our best to protect your information, however we cannot guarantee the security of your information transmitted to our site or sent to us by email or other non-secure electronic methods. Any such transmission is at your own risk. Once we have received your information, we will use protective procedures and security features to try to prevent unauthorized access. We recommend contacting us before attempting to transmit any materials via an unsecured route.
8. Data retention
We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable regulatory, legal, tax or accounting requirements).
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymous it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
9. Your data protection rights
We take steps to ensure that the personal information we collect is accurate and up to date, and that you have the ability to access and make corrections to it. Depending on your particular circumstances, you have the following data protection rights:
If you wish to access, correct, update or request deletion of your personal information, you can do so at any time by contacting us using the contact details provided under the “How to contact us” heading below.
We will honor any statutory right you might have to access, modify or delete your personal information.
Where you have a statutory right to request access or request the modification or erasure of your personal information, we can still withhold that access or decline to modify or erase your personal information in some cases in accordance with applicable national laws, but will give you reasons if we do so.
In addition, if you are a resident of the European Union, you can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. Again, you can exercise these rights by contacting us using the contact details provided under the “How to contact us” heading below.
You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us using the contact details provided under the “How to contact us” heading below.
Similarly, if we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
10. Updates to this Privacy Notice
We may update this Privacy Notice from time to time in response to changing legal, technical or business developments. When we update our Privacy Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Privacy Notice changes if and where this is required by applicable data protection laws.
You can see when this Privacy Notice was last updated by checking the “last updated” date displayed at the top of this Privacy Notice.
11. How to contact us
If you have any questions or concerns about our use of your personal information, please contact us using the following details:
By using our Services you are accepting the terms of this Privacy Notice and our Terms and Conditions, and you are consenting to our collection, use, disclosure, retention and protection of your personal information as described in this Privacy Notice.