Policy number: PC001
Effective Date: April 15,
Last Reviewed Date: April
Owner: Board of Directors
Summary: This policy
governs the collection of personally identifiable information through Paradigm
Paradigm University is committed to protecting your privacy in
its related websites, and content therein (“Website”) as well as the
services available through this Website (“Services”), and governs
collection of personally identifiable information through the website.
By using the website,
you give your consent to Paradigm University’s data practices and understand that
all personally identifiable information that you submit may be processed by Paradigm
College in the manner and for the purposes described herein. If you do not
agree to the terms and conditions set forth herein, do not use the website.
COLLECTION OF PERSONAL INFORMATION
To apply for admission to Paradigm University (“Paradigm
University”, or the “University”), you must submit personally identifiable
information to Paradigm University website (“Website”). “Personally identifiable
information” (“PII”) refers to data that allows Paradigm University to
identify you, such as your name, gender, mailing address, telephone number,
date and country of birth, government-issued identification number, e-mail
address, and other personal information. If you submit personally identifiable
information through any of Paradigm University’s Communications Services (as
INFORMATION AND HOW WE USE IT
By submitting your PII to the Website, you understand and
agree that Paradigm University may collect, use, transfer, and disclose your
Website may collect process and use the data which includes PII, the legal
basis of which is your consent, which you give when you use the Services. Types
of PII that may be used include the following, without limitation:
We may process data about your use of our
Website and Services (“User Data”). User Data may include your IP
address, location, type of browser and version, operating system, referral
source, visit length, page views and website navigation paths, as well as
information about the frequency and timing of your use of the Service. The
source of the User Data is an analytics tracking system. User Data may be
processed for the purposes of analyzing the use of the Website and Services,
operating our Website, improving and customizing the Services, ensuring the
security of our Services, maintaining back-ups of our databases and
communicating with you.
When registering or inquiring on our Website you may be asked to enter your name, email address, mailing address, telephone number, email address, gender, date of birth, or other details (“Entered Data”). You are the source of such account data, and such data may be processed for the purposes of operating the Website, providing the Services, ensuring the security of the Website and Services, maintaining back-ups of our databases and communicating with you. Paradigm University will use your Entered Data for internal purposes including, but not limited to, academic and financial advising, record-keeping and tracking.
We may process information contained in any
enquiry you submit to us regarding Services (“Enquiry Data”).
We may process information relating to
transactions that you enter into with us and/or through our Website, such as
the purchasing of goods (“Transaction Data”). The Transaction Data
may include your contact details, your card details and the transaction
details. The Transaction Data may be processed for supplying the purchased
goods and Services and keeping records of transactions.
We may process information that you provide to
us for the purpose of subscribing to our email notifications, offering you
services, or promotions which may interest you (“Notification Data”).
The Notification Data may be processed for the purposes of sending you relevant
We may process information contained in or
relating to any communication that you send to us (“Correspondence
Data”), for example, when you sign up for our newsletter or respond to a
survey or remarketing communication. The Correspondence Data may include
communication content and/or metadata associated such communication. The
Correspondence Data may be processed for communicating with you and recordkeeping.
We may process any of the types of data
any legal obligation to which we are subject, or when necessary, for the
establishment, exercise or defense of legal claims. The legal basis for this
processing is our legitimate interests, namely of the Website’s legal rights,
your legal rights and the legal rights of others.
not supply any other person’s PII to us without the specific and explicit
consent of all parties, including the owner of such PII.
INTERNATIONAL TRANSFERS OF YOUR PII
In this Section, we provide
information about the circumstances in which your PII may be transferred to
countries inside and outside the European Economic Area (“EEA”).
You acknowledge that PII
submitted by you for publication through the Services may be available around
the world via the internet. We cannot prevent the use or misuse of published
PII by others once you submit it for publication, nor are we liable for such
third-party use or misuse.
Such use may involve transfer of personally
identifiable information to servers located outside the country from which you
access the Website.
We and our other group companies
have facilities in The United States, the Middle East, and India. “Adequacy
decisions” of the European Commission have been made with respect to the
data protection laws of each of these countries.
Transfers to countries inside and
outside the EEA will be protected by appropriate safeguards, namely the
provisions of applicable law which relate to the protection of individuals with
regards to the processing of PII to which a party may be subject including,
without limitation, the Data Protection Act 1998, the Data Protection Directive
95/46/EC, the Regulation of Investigatory Powers Act 2000, the
Telecommunications (Lawful Business Practice) (Interception of Communications)
Regulation 2000, the Electronic Communications Data Protection Directive
2002/58/EC, the Privacy and Electronic Communications (EC Directive)
Regulations 2003 and, where applicable, the guidance and code of practice
issued by the Information Commissioner’s Office from time to time, directions
of any competent regulatory authority, relevant regulatory guidance and codes
of practice (collectively “Data Protection Regulation”) or to the extent
transfers will cross borders to outside the EEA, such transfer shall be carried
out in accordance with standard contractual clauses annexed to the EU
Commission Decision 2010/87/EU of 5 February 2010 for the Transfer of Personal
Data to Processors established in Third Countries under the Directive (the
The hosting facilities for our
Website are situated in The United States and Europe. The European Commission
has made an “adequacy decision” with respect to the data protection
laws of each of these countries. If you have opted-in and knowingly subscribe
to our newsletter or other forms of correspondence, we may also use your
information to inform you of new services Paradigm College will be providing,
inform you of scholarship applications and academic programs provided by third
parties, and send you requested information and promotional materials for
marketing purposes and research.
COLLECTION AND USE OF NON-PERSONAL INFORMATION
The University automatically
collects non-personal information about your computer hardware and software for
the purpose of improving the administration and content of the Website,
facilitating use of the College’s Website by its users, and to properly
diagnose server problems and other issues. The College may contract with third
party providers to assist in better understanding visitors to the Website.
Third party providers are prohibited from using any information they collect on
behalf of Paradigm College for any purpose other than helping the College
conduct and improve its services to you.
The College does not sell, rent
or lease your personally identifiable information to third parties without your
prior written consent. Personally identifiable information collected in
connection with applications for admission is, however, collected by a
third-party service provider that hosts the Website, and that information is
released to application reviewers who may include College employees,
contractors, volunteers and other parties. These individuals are prohibited
from using your personally identifiable information except in connection with Paradigm
College services and any other products and/or services you have requested, and
they are required to maintain the confidentiality of your information.
Paradigm College may disclose
your personally identifiable information, without notice, (i) if required to do
so by law, or (ii) in the good faith belief that disclosure is necessary to
protect or defend the rights, system, network, property or personal safety of
the College, its personnel or its students. Paradigm College may disclose your
personally identifiable information, with prior notice, subject to your
consent, to a potential or actual partner or buyer in connection with a merger,
acquisition, or any form of sale of some or all of the College’s assets.
The College requires opt-in
consent (meaning, your express permission) to share any sensitive personally
identifiable information, such as medical information or information concerning
race or ethnicity, political or religious beliefs, and sexuality.
In this Section, we have done our best to
summarize the rights that you have under data protection law. These are
complex, and not all of the details have been included herein. In light of
this, you should read the relevant laws and guidance from the regulatory
authorities for a full explanation of these rights.
Your principal rights under data
protection law are:
(a) The right to access;
(b) The right
(c) The right to
(d) The right
to restrict processing;
(e) The right to object to processing;
(f) The right
to data portability;
(g) The right to complain to a supervisory
(h) The right
to withdraw consent.
You have the right to confirmation as to
whether or not we process your personal data and, where we do, access to the
personal data, together with certain additional information. That additional
information includes details of the purposes of the processing, the categories
of personal data concerned and the recipients of the personal data. Providing
the rights and freedoms of others are not affected, we will supply to you a
copy of your personal data. The first copy will be provided free of charge, but
additional copies may be subject to a reasonable fee. You can access your
personal data by visiting Paradigm College Self-Service Portal when logged into
You have the right to have any
inaccurate personal data about you rectified and, taking into account the
purposes of the processing, to have any incomplete personal data about you
completed. Paradigm College will also correct, amend or delete any personal
information that is inaccurate and notify any third-party recipients of the
necessary changes. Paradigm College may decline to process requests that are
unreasonably repetitive or systematic, require disproportionate technical
effort, jeopardize the privacy of others, are extremely impractical, or for
which access is not otherwise required by local law or GDPR.
In some circumstances you have
the right to the erasure of your personal data [by providing adequate evidence
attesting to your identity] without undue delay. Those circumstances include:
the personal data is no longer necessary in relation to the purposes for which
they were collected or otherwise processed; you withdraw consent to
consent-based processing; the processing is for direct marketing purposes; and
the personal data have been unlawfully processed. There are certain general
exclusions of the right to erasure. Those general exclusions include where
processing is necessary: [for exercising the right of freedom of expression and
information; for compliance with a legal obligation; or for the establishment,
exercise or defense of legal claims].
In some circumstances you have
the right to restrict the processing of your personal data. Those circumstances
are: you contest the accuracy of the personal data; processing is unlawful but
you oppose erasure; we no longer need the personal data for the purposes of our
processing, but you require personal data for the establishment, exercise or
defense of legal claims; and you have objected to processing, pending the
verification of that objection. Where processing has been restricted on this
basis, we may continue to store your personal data. However, we will only
otherwise process it: with your consent; for the establishment, exercise or
defense of legal claims; for the protection of the rights of another natural or
legal person; or for reasons of important public interest.
You have the right to object to
our processing of your personal data on grounds relating to your particular
situation, but only to the extent that the legal basis for the processing is
that the processing is necessary for: the performance of a task carried out in
the public interest or in the exercise of any official authority vested in us;
or the purposes of the legitimate interests pursued by us or by a third party.
If you make such an objection, we will cease to process the personal
information unless we can demonstrate compelling legitimate grounds for the
processing which override your interests, rights and freedoms, or the
processing is for the establishment, exercise or defense of legal claims.
To the extent that the legal
basis for our processing of your personal data is consent, and such processing
is carried out by automated means, you have the right to receive your personal
data from us in a structured, commonly used and machine-readable format.
However, this right does not apply where it would adversely affect the rights and
freedoms of others.
If you consider that our
processing of your personal information infringes data protection laws, you
have a legal right to file complaint with a supervisory authority responsible
for data protection. You may do so in the EU member state of your habitual
residence, your place of work or the place of the alleged infringement.
To the extent that the legal
basis for our processing of your personal information is consent, you have the
right to withdraw that consent at any time. Withdrawal will not affect the
lawfulness of processing before the withdrawal. You may exercise any of your
rights in relation to your personal data by written notice to us in addition to
the other methods specified in this Section 5.
When you provide us with PII for
a secondary reason, like marketing or other secondary reasons which we will
convey to you from time to time if applicable, we will ask for your consent.
After you opt-in, you may withdraw your consent anytime, by contacting us at support@Paradigm.edu.et or admissions@Paradigm.edu.et
Or, please go to this site to withdraw your consent to
SECURITY OF YOUR PERSONAL INFORMATION
The University maintains reasonable
measures to protect your personally identifiable information from unauthorized
access, use or disclosure. The College stores the personally identifiable
information you provide on computer servers in a controlled environment that
has implemented protections against unauthorized access, use or disclosure. Paradigm
College has implemented procedures to safeguard the integrity of its
information technology assets, including, but not limited to, authentication,
monitoring, auditing, and encryption. These security procedures have been
integrated into the design, implementation, and day-to-day operations of the
Website as part of College’s continuing commitment to the security of
electronic content as well as the electronic transmission of information.
For website security purposes and
to maintain the availability of the Website for all users, the College employs
software to monitor traffic and identify unauthorized attempts to upload or
change information or otherwise damage the Website. When personally
identifiable information (such as a credit card number) is transmitted to other
websites, it is protected through the use of encryption, such as the Secure
Socket Layer (SSL) protocol.
The College, however, cannot
guarantee that unauthorized third parties will never be able to defeat the
measures described in this section or use your personally identifiable
whether express or implied, regarding the security of your personally identifiable
The Family Educational Rights and
Privacy Act (FERPA) of 1974 was designed to protect the privacy of educational
records, establish the rights of students to inspect and review their
educational records, and provide guidelines for the correction of inaccurate or
misleading information through informal and formal hearings. While FERPA does
not apply to the College, since it is not a federally-funded institution, the College
nonetheless strives to meet FERPA’s provisions to the extent reasonably
The College will not disclose a
student’s educational record without obtaining the student’s prior written
consent, except that a student’s educational record may be disclosed (i) to
other school officials, including teachers with a legitimate educational
interest and contractors, consultants, volunteers, or other parties to whom Paradigm
College has outsourced educational or institutional services or functions; (ii)
to parents of a dependent student, as defined in section 152 of the Internal
Revenue Code of 1986; (iii) to accrediting organizations; (iv) in compliance
with a judicial order or lawfully issued subpoena; or (v) for any other reason
permitted under 34 CFR § 99.31.
The College depends on the
accuracy of the records submitted by its students. False information on an
application, or any other act to intentionally mislead or misinform
instructional personnel or administrators, is grounds for disciplinary action,
including dismissal from the College. Students seeking access or amendment of
their educational records should contact the Office of Admission &
Registrar at email@example.com
CHILDREN’S ONLINE PRIVACY PROTECTION ACT
Although neither this website nor
any of the College’s services are intended for children under 13 years of age,
the College complies with the Children’s Online Privacy Protection Act of 1998
(“COPPA”) and does not knowingly collect any personal information online from
children under the age of 13.
Paradigm College Website may use
“cookies”, subject to your consent if you are a resident of the
European Union or are subject to GDPR, to help you personalize your online
experience. A cookie is a small data file that is placed on your hard disk by a
web page server. The purpose of a cookie is to tell the web server that you
have returned to a specific page. For example, if you personalize Website
pages, or apply for admission to Paradigm College, a cookie helps the College
recall your specific information on subsequent visits. This simplifies the
process of recording your personal information, such as your name and mailing
address. When you return to the Website, the information you previously
provided can be retrieved, so you can more easily use Paradigm College
features. 8 Cookies cannot be used to run programs or deliver viruses to your
computer. Cookies are uniquely assigned to you, and can only be read by a web
server in the domain that issued the cookie to you. By using the Website, its
described herein. Note that most web browsers automatically accept cookies, but
you can usually modify your browser settings to decline cookies if you prefer.
If you choose to decline cookies, you may not be able to fully experience the
interactive features of the Website.
The College uses Google Analytics
to collect information about use of the Website. The College uses the data it
receives from Google Analytics to improve the Website, and does not combine the
IP address collected by Google Analytics with your name or other identifying
information that you may enter on the Website. Paradigm College cannot control
Google’s use of the information it gathers; however, Google’s right to use and
share information collected by Google Analytics about your visits to Paradigm College
visits to this site by deleting its cookie or disabling cookies on your
THE ETHIO TELECOM HOSTING CRM
The College’s Customer Relationship Management (CRM) system is hosted by Ethiotelecom. There is a seamless transition from the College’s main website to the CRM. You enter the
CRM every time you work on your application to the College or otherwise log in
to the Student Portal. The CRM processes and maintains all Paradigm College
applications, student records such as course registration history and grades,
and data related to payment history such as invoices and tracking numbers. Note
that the CRM does not store any of your personal bank account or PayPal
Ethiotelecom is not allowed to
use your personally identifiable information other than for the provision of
services to the College or as otherwise permitted by law. For more information
about the Ethiotelecom Dynamics CRM, you can review the security and privacy
pages at the Microsoft Dynamics CRM Trust Center and the Microsoft Privacy
& Cookies page.
THE MOODLE LEARNING PLATFORM
All of the University’s courses, classroom discussions, assignments, testing, the academic advising messages system, and student and faculty forums are conducted through Moodle, an open
source learning platform. There is a seamless transition from Paradigm College’s
main website to the College’s Moodle platform. No one outside Paradigm College
community is permitted to access Paradigm College Moodle platform. However, Paradigm
College Moodle site administrators have access to nearly everything in the
system and certain private information is also accessible by other Paradigm
College students, faculty and staff:
Paradigm College profile page. Every Paradigm
College student has a profile page in Moodle, which contains their first and
last name, email address (optional), profile picture (optional) and description
(optional). This information is visible to classmates for each course in which
a student is enrolled, and to all students, faculty and staff through the
Academic Advising Virtual Office. Paradigm College profile pages are NOT
available to the general public.
Paradigm College discussion forums. Since Paradigm
College is based on the peer-learning model, the College makes great use of
discussion forums in its courses. Anything posted in a discussion forum is
visible to the instructor and to all students enrolled in that course. For
large classes that are divided into groups, only members of your group can see
your posts. Your posts will include your full name and profile picture if you
have chosen to upload it to the system.
Paradigm College peer-assessed assignments. All
assignments assessed by other students in a particular course are submitted
anonymously. Unless you put your name on your peer assessed assignment, which
is not a requirement, only instructors and administrators will be able to see
who has evaluated your assignment.
4. Private messaging system. Only the sender and receiver can view the content of messages sent through the Moodle privacy
If you withdraw from the University,
your account will be disabled and will no longer visible to students and
instructors. Old and inactive accounts are usually deleted after four years of
non use. Note that if you choose to create a public profile on the moodle.org or
moodle.net sites, which are outside Paradigm College Moodle platform, your
PARADIGM COLLEGE SOCIAL MEDIA NETWORK
Third Party Websites, Cookies and Privacy Policies Certain pages of the Website may contain links to websites that are not controlled by the College. Third-party cookies may be set by websites such as Facebook, Twitter, YouTube, Google Plus and other social media outlets or websites for which Paradigm College may implement plugins.
Third-party Providers In general, the third-party providers used by us will only collect, use and disclose your information to the extent necessary to allow them to perform the services they provide to us. However, certain third-party service providers, such as payment gateways and other payment transaction processors, have their own privacy policies in respect to the information we are required to provide to them for your purchase-related transactions. For these providers,
we recommend that you read their privacy policies so you can understand the
manner in which your personal information will be handled by these providers.
In particular, remember that certain providers may be located in or have
facilities that are located a different jurisdiction than either you or us. So,
if you elect to proceed with a transaction that involves the services of a
third-party service provider, then your information may become subject to the
laws of the jurisdiction(s) in which that service provider or its facilities
are located. For example, if you are located in Canada and your transaction is
processed by a payment gateway located in the United States, then your PII used
in completing that transaction may be subject to disclosure under United States
legislation, including the Patriot Act. Once you leave our Website or are
redirected to a third-party website or application, you are no longer governed
Occasionally, at our discretion, we may include or offer third-party products or Services on our Website. These third-party sites have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites.
AGE OF CONSENT
By using this site, you represent that you are at least the age of majority in your state, province or country of residence, or that you are the age of majority in your state, province or country of residence and you have given us your consent to allow any of your minor dependents to use this site.
RETAINING AND DELETING PII
This Section 4 sets out our data
retention policies and procedures, which are designed to help ensure that we
comply with our legal obligations in relation to the retention and deletion of
We will retain and delete your personal data as follows: PII will be retained for 25 years following the point of first contact with the College at the end of which period it will be deleted from our systems.
CHANGES TO THIS POLICY
COMPLIANCE WITH THIS POLICY