PRIVACY POLICY
Effective date: July 16, 2015

At System, we take privacy issues very seriously, and we have adopted the following privacy policy for the benefit of Users. Capitalized Terms in this Privacy Policy shall have the same meaning and effect as set forth in the System University User Agreement.

System may modify or update this Privacy Policy from time to time, so please review it periodically. System may provide You additional forms of notice of modifications or updates as appropriate under the circumstances. Your continued use of the Sites or the Services after any modification to this Privacy Policy will constitute Your acceptance of such modification.
1. Data & Information. System collects the following types of data and information:
a. Information About You.
i. Your Username, password and e-mail address when You register for a System account.
ii. Profile information that You provide for Your User profile (e.g., first and last name, picture, phone number).
iii. Communications between You and System. For example, System may send You Service-related emails (e.g., account verification, changes/updates to features of the Services, technical and security notices). Note that You may not opt out of Service-related e-mails.

b. Cookies and similar technologies.
i. When You visit the Sites or use the Services, System may use cookies and similar technologies like pixels, Web beacons, and local storage to collect information about how You use System and provide features to You.
ii. System may ask advertisers or other partners to serve ads or services to Your devices, which may use cookies or similar technologies placed by System or the third party.

c. Analytics and Log file information.
i. System may use third-party analytics tools to help System measure traffic and usage trends for the Service. These tools collect information sent by Your device or the Services, including the web pages You visit, add-ons, and other information that assists System in improving the Service. System may collect and use this analytics information with analytics information from other Users in the aggregate so that it cannot reasonably be used to identify any particular individual User.
ii. Log file information is automatically reported by Your browser each time You make a request to access (i.e., visit) a web page or app. It can also be provided when the content of the webpage or app is downloaded to Your browser or device.
iii. When You use the Services, our servers automatically record certain log file information, including Your web request, Internet Protocol (“IP”) address, browser type, referring / exit pages and URLs, number of clicks and how You interact with links on the Services, domain names, landing pages, pages viewed, and other such information. System may also collect similar information from emails sent to Users which then help System track which emails are opened and which links are clicked by recipients. The information allows for more accurate reporting and improvement of the Services.

d. Device identifiers.
i. When You use a mobile device to access the Services, System may access, collect, monitor, store on Your device, and/or remotely store one or more “device identifiers.” Device identifiers are small data files or similar data structures stored on or associated with Your mobile device, which uniquely identify Your mobile device. A device identifier may be data stored in connection with the device hardware, data stored in connection with the device’s operating system or other software, or data sent to the device by System.
ii. A device identifier may deliver information to System or to a third party partner about how You browse and use the Services and may help System or others provide reports or personalized content and ads. Some features of the Services may not function properly if use or availability of device identifiers is impaired or disabled.

e. Metadata. Metadata is usually technical data that is associated with User content. For example, Metadata can describe how, when and by whom a piece of User content was collected and how that content is formatted.
2. Use Of Data/Information.
a. System may use the data and information we collect to:
i. help You efficiently access Your information after You sign in;
ii. remember information so You will not have to re-enter it during Your visit or the next time You visit the Services;
iii. provide personalized content and information to You, which could include advertising and marketing;
iv. provide, improve, test, and monitor the effectiveness of the Services;
v. develop and test new products and features;
vi. monitor metrics such as total number of visitors, traffic, and demographic patterns;
vii. diagnose or fix technology problems; and
viii. automatically update the System application on Your device.
b. You may update Your account at any time by logging in and changing Your profile settings.
c. You may also unsubscribe from email communications from System by clicking on the “unsubscribe link” provided in such communications. As noted above, You may not opt out of Service-related communications (e.g., account verification, purchase and billing confirmations and reminders, changes/updates to features of the Service, technical and security notices).

3. Sharing Of Data And Information.
a. System will not rent or sell Your information to third parties outside System (or the group of companies of which System is a part) without Your consent, except as noted in this Policy.
b. System may share Your information as follows:
i. System may share User content and Your information (including but not limited to, information from cookies, log files, device identifiers, location data, and Usage data) with individuals and companies that are affiliated with System (the “Affiliates”). Affiliates may use this information to help provide, understand, and improve the Services (including by providing analytics) and Affiliates’ own services (including by providing You with better and more relevant experiences).
ii. System also may share Your information as well as information from tools like cookies, log files, and device identifiers and location data, with third-party organizations that help System provide the Services to You (“Service Providers”). The Service Providers will be given access to Your information as is reasonably necessary to provide the Service under reasonable confidentiality terms.
iii. System may also share certain information such as cookie data with third-party advertising partners. This information would allow third-party advertising networks to, among other things, deliver targeted advertisements that they believe will be of most interest to You.
iv. System may remove parts of data that can identify You and share anonymized data with other parties. System may also combine Your information with other information in a way that it is no longer associated with You and share that aggregated information.
c. If System sells or otherwise transfer part or the whole of System or its assets to another organization (e.g., in the course of a transaction like a merger, acquisition, bankruptcy, dissolution, liquidation), Your information such as name and email address, User content and any other information collected through the Services may be among the items sold or transferred. You will continue to own Your User content. The buyer or transferee will have to honor the commitments System has made in this Privacy Policy.
d. System may access, preserve and share Your information in response to a legal request (like a search warrant, court order or subpoena) if we have a good faith belief that the law requires System to do so. This may include responding to legal requests from jurisdictions outside of the United States where System has a good faith belief that the response is required by law in that jurisdiction, affects Users in that jurisdiction, and is consistent with internationally recognized standards. System may also access, preserve and share information when we have a good faith belief it is necessary to: detect, prevent and address fraud and other illegal activity; to protect System, You and others, including as part of investigations; and to prevent death or imminent bodily harm. Information System receives about You may be accessed, processed and retained for an extended period of time when it is the subject of a legal request or obligation, governmental investigation, or investigations concerning possible violations of our terms or policies, or otherwise to prevent harm.

4. Storage And Security.
a. Your information collected through the Services may be stored and processed in the United States or any other country in which System, its Affiliates or Service Providers maintain facilities.
b. System, its Affiliates, or Service Providers may transfer information that System collects about You, including personal information across borders and from Your country or jurisdiction to other countries or jurisdictions around the world. If You are located in the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that System may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as Your jurisdiction.
c. By registering for and using the Services You consent to the transfer of information to the U.S. or to any other country in which System, its Affiliates or Service Providers maintain facilities and the use and disclosure of information about You as described in this Privacy Policy.
d. System uses commercially reasonable safeguards to help keep the information collected through the Services secure and take reasonable steps (such as requesting a unique password) to verify Your identity before granting You access to Your account. However, System cannot ensure the security of any information You transmit to System or guarantee that information on the Service may not be accessed, disclosed, altered, or destroyed.
e. Following termination or deactivation of Your account, System, its Affiliates, or its Service Providers may retain information (including Your profile information) and User content for a commercially reasonable time for backup, archival, and/or audit purposes.

5. Children’s Privacy. System does not knowingly collect or solicit any information from anyone under the age of 13 or knowingly allow such persons to register for the Services. The Services and its content are not directed at children under the age of 13. In the event that System learns that we have collected personal information from a child under age 13 without parental consent, we will delete that information as quickly as possible. If You believe that System might have any inadvertently collected information from or about a child under 13, please contact us.
6. Other Websites. System is not responsible for the practices employed by any websites or services linked to or from the Services, including the information or content contained within them. Please remember that when You use a link to go from the Services to another website or service, the Privacy Policy does not apply to those third-party Websites or services. Your browsing and interaction on any third-party Website or service, including those that have a link on the Sites, are subject to that third party’s own rules and policies. In addition, You agree that System is not responsible for and does not have control over any third-parties that You authorize to access Your User content. If You are using a third-party website or service and You allow them to access Your User content You do so at Your own risk.

Please contact System at 262 Upper Ferry Road, Ewing, NJ 08628 if You have any questions or concerns about the Privacy Policy.