Important Information for Residents of the EEA, Switzerland and the UK
1. Information about Cengage
Cengage is providing this supplemental privacy notice to give individuals in the European Economic Area (EEA) the additional information required by the EU General Data Protection Regulation. These provisions, together with the statements in the Cengage Privacy Notice, explain our practices with regard to EEA personal data.
This information is being provided by Cengage, Inc. for itself and its subsidiaries:
200 Pier 4 Boulevard, Suite 400
Boston, MA. 02210
Cengage, Inc. is based in the United States.
Our representative in the EEA is:
Cengage Learning (EMEA) Limited
Walworth Business Park
Registration Number: Z2487772
2. The Purposes and Legal Basis for Processing, including Legitimate Interests
The Cengage Privacy Notice explains the reasons why we process your Personal Information. We only process Personal Information when we have a legal basis for the processing, such as:
- To fulfill a contract with you or your school
- For closely-related purposes, such as payment processing and financial account management, contract management, website administration, business continuity and disaster recovery, security and fraud prevention, corporate governance, reporting and legal compliance
- With your consent (or provided you have not objected, as may be appropriate under applicable law), such to provide you with marketing communications
We may also process your Personal Information for the purposes of our legitimate interests (or for the legitimate interests of your school, provided that such processing shall not outweigh your rights and freedoms.) In particular, we may process your Personal Information as needed to:
- Protect you, us or others from threats (such as security threats or fraud) or cheating,
- Comply with the laws that are applicable to us around the world,
- Enable or administer our business, such as for quality control, consolidated reporting, and customer service,
- Manage corporate transactions, such as mergers or acquisitions, and
- Understand and improve our business or customer relationships generally.
3. Automated Decision-Making and Profiling
We may use profiling and analytics to understand how individuals interact with our educational materials, such as assess engagement and improve learning outcomes, and product development purposes. For example, we may use analytics to study the amount of time that individuals spend on specific content items and we may infer engagement from this process. These analytics also help us understand and improve our materials, as we can determine what materials are more or less accessible to students. We may also use analytics for course integrity purposes, such as to identify individuals that may be cheating.
We will not make automated decisions about you that may significantly affect you, unless (1) the decision is necessary as part of a contract that we have with you, (2) we have your explicit consent, or (3) we are required by law to use the technology.
4. When You are Required to Provide Personal Information to Cengage
In most cases, you are not required by law to provide any Personal Information to Cengage. You are required to provide certain Personal Information to enable us to enter into a contract with you so that you can use our products and services. Our registration forms indicate which data elements are required for our contracts. If you do not provide these data elements, we cannot do business with you.
5. International Transfers
As noted in the Cengage Privacy Notice, your Personal Information may be transferred to, stored at or processed in the United States and other countries which may not have equivalent privacy or data protection laws.
We generally use approved Standard Contractual Clauses to assure that Personal Information is adequately protected when it is transferred out of the European Economic Area or Switzerland, but we may also make transfers to recipients with approved Binding Corporate Rules or to recipients in the United States who have certified to the EU-US and/or Swiss-US Privacy Shield Framework.
Please contact us via email to firstname.lastname@example.org if you would like more information about cross-border transfers or to obtain a copy of the Standard Contractual Clauses.
6. Data Retention
We will retain your Personal Information for as long as the information is needed for the purposes set forth in Section 3 above and for any additional period that may be required or permitted by law. You may request that we delete your Personal Information. To do so, submit a “right to be forgotten” form and follow the instructions and prompts. Unless we are required by law to retain your information, we will delete it within 30 days of your request.
7. How to Contact Us
Please contact us if you have any questions or comments about our privacy practices or this Privacy Notice. You can always reach us via email to email@example.com. You can also reach us via mail to the addresses given above.