INTRODUCTION

Aspen OpCo, LLC d/b/a Aspen Publishing ("we" or "us") wants to inform you about the ways we process your personal information. In this Privacy & Cookie Notice we explain what personal information we collect, use and disclose. 

Personal information means any data relating to an individual who can be identified, directly or indirectly, based on that information. This may include information such as names, contact details, (online) identification data, online identifiers, or other characteristics specific to that individual.

This Privacy & Cookie Notice applies when you visit our websites, solutions and other services, including events, that refer or display a link to this notice (“Services”). This Privacy & Cookie Notice may be supplemented or replaced by additional privacy statements or terms provided to you.

  WHO WE ARE

Aspen Publishing is a leading provider of educational content and digital learning solutions to law schools in the U.S. and around the world. Aspen Publishing controls the personal information provided to or collected by it. We are committed to safeguarding the personal information of our customers, users, employees and other stakeholders.

If you wish to contact us in relation to questions about your personal information, refer to the ‘HOW YOU CAN CONTACT US’ section below.

WHAT PERSONAL INFORMATION DO WE COLLECT?

The type of personal information we collect depends on your relationship with us and the Services we deliver to you. To that end, we may collect the following personal information about you:

• Name and contact details, such as, first and last name, email address, postal address, telephone number
• Work or education related information related information, such as, job title and other employment or education information
• Account Credentials, such as, passwords and other security information for authentication and access
• Financial Information, such as, bank account, credit and debit card numbers for processing of payments
• Usage information, such as, behavioral information about how you navigate within our Services; which elements of our Services you use the most; information regarding the goods and/or services you wish to order; wish lists; preferences; interests; other information shared by you through our websites, apps, web store, and other products, etc.
• Computer, device and connection information, such as, IP address, browser type and version and location

If you are under 13 years of age, please do not use or access the Services. Aspen Publishing does not knowingly collect or maintain personal information (as defined by the United States Children’s Online Privacy Protection Act) from persons under 13 years of age. If Aspen Publishing learns that personal information of persons under 13 has been collected on or through the Services, we will take appropriate steps to delete this information.

Recording Use of the Website. We may partner with trusted third-party vendors to analyze performance and traffic of our websites.   This may include things like buttons you click, mouse movements and other behavior on our websites, date and time of access, pages visited, web beacons, and cookie or pixel tag information. Please see “THE USE OF COOKIES” section below to learn more about cookies, pixels tags, and analytic technologies.

Free-Text Boxes. The information that you provide in each case will vary. In some cases, you may be able to provide personal information via email or free text boxes, such as contacting the Company to request further information.  When providing your personal information, please provide only relevant information and do not provide unnecessary sensitive information, such as Social Security numbers, credit card information or other sensitive personal data, unless required for our Services.   

HOW WE COLLECT PERSONAL INFORMATION

We and our third-party service providers may collect personal information from the following sources:

• Direct Interactions, such as, when you register for our Services or make a purchase
• Data from Third Parties, such as, information on third-party websites or other information you may have made publicly available or information provided by third party sources, including but not limited to government entities and data resellers
• Automated Tracking Technologies, such as, information automatically collected about your interaction with our Services and websites using various technologies such as cookies, web logs and beacons and internet tags
  

HOW WE USE YOUR PERSONAL INFORMATION

Personal information collected is used for the purposes for which you have provided it and might be further used for statutory or other legitimate purposes only. As an example, if you make use of our service contact form on our website, we will use the information you provided in the first place to respond to your service request. We might further use that information to improve the quality of our customer service process.

Lawfulness of the processing is one of the main principles relating to processing of your personal information. We apply the following legal processing grounds:

• processing is necessary for the performance of a contract or in order to take steps prior to entering into a contract;
• processing is necessary for the purposes of our legitimate interests — for example, to improve the quality of our products and services;
• processing is necessary for compliance with a legal obligation to which we are subject or that is otherwise lawful under applicable data protection laws;
• with your given consent.

Depending on how you interact with us and the Service, we may use your personal information for the following purposes:

• Administering our relationship with you and our business, such as providing and managing your access to and use of our Services. This processing is necessary for the performance of a contract;
• Improving our Services and developing new products, such as inviting you to participate in surveys or to personalize your experience with our Services. This processing is necessary for the purposes of our legitimate interests; 
• Marketing, such as providing you with marketing or advertising communications that we think you may be interested in. This processing is with your given consent or for our legitimate interests;
• Recruiting, such as assessing job applicants. This processing is in order to take steps prior to entering into a contract or with your given consent;
• Providing online communities, such as making chat rooms, forums, message boards, or news groups available to you.  This processing is necessary for the performance of a contract or our legitimate interests.  Please remember that any information disclosed in these forums is public.  We encourage you to exercise caution when disclosing personal information in these forums, as this information is made available to other users.  Do not disclose information in these public forums that might be considered confidential or proprietary or that you do not wish to be publicly available or that you are prohibited from disclosing.
• Other general business support purposes, including but not limited to, procurement, financial and fiscal management, risk and compliance management, and external reporting. This processing is necessary for compliance with a legal obligation to which we are subject or that is otherwise lawful under applicable data protection laws or for our legitimate interests.

SHARING YOUR PERSONAL INFORMATION

To be able to provide you the best possible Services and further our business operations, we may share certain information internally or with selected third parties. There might also be a certain statutory or legal obligation that we believe in good faith requires us to disclose your personal information externally. Parties we might share data with include:

• our service providers, e.g. for managing or hosting services and/or underpinning technology for the Services we are providing;
• our business partners, to the extent you have purchased or expressed interest in, a product or service of such business partner, interacted with them or otherwise authorized the sharing of your personal information with such business partner;
• subscribing, accrediting or professional organizations, e.g. for providing utilization information to organizations that provide you with access to our Services and/or sharing tracking and redeeming credits for professional accreditation;
• organizations involved in business transfers, e.g. to a purchaser or successor entity in the event of a sale or any other corporate transaction involving some or all of our business;
• other parties, e.g. as needed for external audit, compliance, risk management, corporate development and/or corporate governance related matters; or
• governmental authorities and regulators, as required under applicable law.

Whenever we share personal information internally or with third parties in other countries, we have appropriate safeguards in place in accordance with applicable data protection laws including as applicable the EU Model clauses. As required under applicable law, third parties are required to use appropriate safeguards to protect personal information and they can only access personal information that is necessary for performing their specific tasks.

HOW LONG WE KEEP YOUR PERSONAL INFORMATION

Your personal information will be processed to the extent necessary for the performance of our obligations, and for the time necessary to achieve the purposes for which the information is collected, in accordance with our data retention policies and applicable data protection laws. When we no longer need your personal information, upon your request, we will take all reasonable steps to remove it from our systems and records or take steps to properly anonymize it so that you can no longer be identified from it.

HOW WE PROTECT YOUR PERSONAL INFORMATION

We have put in place an internal framework of policies and minimum standards across our business to keep your data safe. In addition, we limit access to personal information by our employees, business partners, service providers and third-party service providers to a ‘need-to-know’ basis. More specifically and in accordance with the law, we take appropriate technical and organizational measures (policies and procedures, IT security, and others) to ensure the confidentiality and integrity of your personal information and the way it is processed.

ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS; YOUR RIGHTS UNDER STATE LAW

California Residents. In addition to the information provided in this privacy policy, if you are a California consumer, as that term is defined under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (the “CCPA”), you may have additional rights to your personal information.  Additional information for California residents can be found here.

Colorado and Virginia Residents. In addition to the CCPA for California consumers, some additional state laws in the United States provide consumers with rights with respect to their personal information (also known as “personal data”), as those terms are defined under those applicable state laws. Such state laws may include, but are not limited to, the Colorado Privacy Act (“CPA”) and the Virginia Consumer Data Protection Act (“VCDPA”).  Any personal information we collect is collected for the commercial purpose of effectively providing our services to you, as well as enabling you to learn more about, and benefit from, our services. If you reside in a state that provides additional rights with respect to your personal information, you may exercise each of your rights as identified below, subject to our verification of your identity.

1. Access.  You have the right to request that we disclose certain information to you about our collection, use and disclosure of your personal information over the past twelve (12) months. Any disclosures we provide will only cover the 12-month period preceding the receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable.
2. Correction.  You can correct what personal data our Services database currently contains by accessing your account directly, or by contacting us to request that we correct or rectify any personal data that you have provided to us.
3. Limit Use and Disclosure of Sensitive Personal Information. If we collect any sensitive personal information, you have the right to request that we limit the use of the sensitive personal information to that use which is necessary to perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services.
4. Portability.  Upon request and when possible, we can provide you with copies of your personal information.  When such a request cannot be honored, we will advise you accordingly.  You can then choose to exercise any other rights under this Privacy & Cookie Notice
5. Deletion.  You have the right to request that we delete any of your personal information, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.  Where applicable, we will ensure such changes are shared with trusted third parties.
6. Opt-out of Processing. You have the right to request that we do not sell your personal information, use your personal information for Targeted Advertising, or use your personal information for profiling. Where applicable, we will ensure such changes are shared with trusted third parties.
7. Non-Discrimination. If a data subject exercises his or her rights under applicable state law, including but not limited to the CPA and VCDPA, we shall not discriminate against that data subject by denying our goods or services, charging different prices or rates to similarly situated consumers, providing a different level or quality of our goods or services, or taking any other adverse action.
8. Exercising your rights. If you are a data subject that has rights under applicable state law, including but not limited to the CPA and VCDPA, who chooses to exercise the rights listed above, you can:

1. Submit a request via email at support@aspenpublishing.com; or
2. Call us at 1-800-317-3113 to submit your request.

Only you, or someone legally authorized to act on your behalf, may make a request related to your personal information. 

Responding to Your Request. Upon receiving your request, we will confirm receipt of your request by sending you an email confirming receipt. To help protect your privacy and maintain security, we may take steps to verify your identity before granting you access to the personal information. In some instances, such as a request to delete personal information, we may first separately confirm that you would like for us to in fact delete your personal information before acting on your request.

We will respond to your request within forty-five (45) days. If we require more time, we will inform you of the reason and extension period in writing.

In some cases our ability to uphold these rights for you may depend upon our obligations to process personal information for security, safety, fraud prevention reasons, compliance with regulatory or legal requirements, or because processing is necessary to deliver the services you have requested. Where this is the case, we will inform you of specific details in response to your request.

DATA SUBJECT RIGHTS FOR INDIVIDUALS OUTSIDE THE UNITED STATES

Under the (i) General Data Protection Regulation (Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, or “GDPR”), (ii) Data Protection Act 2018, (iii) the GDPR as it forms part of the law of England and Wales, Scotland and Northern Ireland (i.e., “UK GDPR”) as provided in the Data Protection Act 2018, and (iv) any other applicable data protection legislation of any country or other jurisdiction (collectively “International Data Protection Laws”) individuals have specific rights with respect to their personal information, or “personal data” as defined under the International Data Protection Laws.  For the purposes of this Privacy & Cookie Notice , the Company operates as a data controller.  Any personal data we collect from you is processed in the United States and under the terms of this Privacy & Cookie Notice.

Any personal data we collect from you is processed in the legitimate interest of our business and providing our services to you as the lawful means of such processing.  You may always withdraw your consent to our use of your personal data as described below.  We will only retain your personal data for the time necessary to provide you the information and services to which you have consented, to comply with the law and in accordance with your rights below.

• Right of access (‘an overview of your personal information’): the right to get an overview of your personal information that we process.
• Right to rectification (‘correct your personal information’): if your personal information is inaccurate or incomplete, the right to ask us to rectify or complete your personal information.
• Right to erasure (‘right to be forgotten’): the right to request that we delete your personal information to the extent permitted by applicable law. In certain circumstances, it may not be possible for us to accept your request, for example, when the processing is necessary to comply with a legal obligation, or if processing is necessary for the performance of a contract. In some cases, your personal information is necessary in order to provide the Services and if you do not provide such information to us then you may be precluded from accessing and using the Services or using certain Services features. 
• Right to data portability (‘transfer your personal information’): the right to ask us to transfer your personal information directly to you. This applies to certain personal information if processed by automated means and with your consent or based on a contract you have with us. On your request, and where technically feasible, we will transfer your personal information to another party of your choice.
• Right to restrict processing: the right to request that we restrict or stop the processing of your personal information held by us for a certain period of time, or for an indefinite period. In certain circumstances, it may not be possible for us to accept your request, for example, when the processing is necessary to comply with a legal obligation, or if we can demonstrate compelling legitimate grounds otherwise.  
• Right to object: the right to object to the processing of your personal information. The reasons for objection should relate to your particular situation, and be related to a processing based on the legitimate interest condition. We will then no longer process the personal information, unless we can demonstrate compelling reasons otherwise. In certain circumstances you have the unconditional right to object; for instance, in the context of direct marketing activities. 
• Withdrawal of Consent: the right to withdraw your consent to the processing of your personal information at any time; for instance, after you consented to keeping you informed about our Services, you have the right to withdraw this consent at any time.

To exercise your rights and/or for any other questions about the handling of your personal information, we refer you to the 'HOW YOU CAN CONTACT US' section below.

If you feel we are unresponsive or disagree with our data privacy practices, you can also file a complaint with your national or supervisory Data Protection Authority.

THE USE OF COOKIES

We use cookies to optimize our websites and analyze website traffic. On occasion, we may use third party cookies, notably social media plugins, to enable you to share ideas and information related to us instantly and for own marketing purposes.

Cookies or similar techniques (referred to collectively as “Cookies”) are small text files or pixels, which might be stored on your computer or mobile device. Cookies may be necessary to facilitate website browsing and making it more user-friendly. Third party Cookies may collect information to analyze personal browsing behavior. Cookies are usually defined in one of two ways, and we may use either (or both) of them: 

1. session cookies, which do not stay on your device after you close your browser, and
2. persistent cookies, which remain on your device until you delete them or they expire. 

We may use Cookies belonging to one of the three categories listed below.

• Necessary Cookies - these mandatory Cookies are needed for our websites to function properly.
• Functional Cookies - these Cookies add additional functionality to our websites.
• Performance Cookies - these Cookies support analytic services that help us to improve our website’s functionality and user experience.

Of course, if you do not wish to have cookies on your devices, you may turn them off at any time by modifying your internet browser’s settings.  However, by disabling cookies on your device, you may be prohibited from full use of our Service’s features or lose access to some functionality.

1. Google Analytics.  Our websites may send aggregated non-personal information to Google Analytics for the purpose of providing us with the ability to conduct technical and statistical analysis on the Website’s performance.  For more information on how Google Analytics supports our websites and uses information sent from our websites, please review Google’s privacy policy available at https://policies.google.com/technologies/partner-sites.
2. Web Beacons.  A Web Beacon is an electronic image.  Web Beacons can track certain things from your computer and can report activity back to a web server allowing us to understand some of your behavior.  If you choose to receive emails from us, we may use Web Beacons to track your reaction to our emails.  We may also use them to track if you click on the links and at what time and date you do so.  Some of the third-party marketers we engage with may use Web Beacons to track your interaction with online advertising banners on our websites.  This information is only collected in aggregate form and will not be linked to your personal information.  Please note that any image file on a webpage can act as a Web Beacon.
3. Embedded Web Links.  Links provided in our emails and, in some cases, on third-party websites may include tracking technology embedded in the link.  The tracking is accomplished through a redirection system.  The redirection system allows us to understand how the link is being used by email recipients.  Some of these links will enable us to identify that you have personally clicked on the link and this may be attached to the personal information that we hold about you.  This data is used to improve our service to you and to help us understand the performance of our marketing campaigns.
4. Third-party Websites and Services.  We work with a number of service providers of marketing communications technology.  These service providers may use various data collection methods to improve the performance of the marketing campaigns we are contracting them to provide.  The information collected can be gathered on our websites and also on the websites where our marketing communications are appearing.  For example, we may collect data where our banner advertisements are displayed on third-party websites.

LINKS TO OTHER WEBSITES

Our websites may contain links to other Aspen Publishing or third-party websites, which may have privacy notices that differ from ours. We are not responsible for the collection, processing or disclosure of personal information collected through other websites.

We are also not responsible for any information or content contained on such websites. Links to other websites are provided solely for convenience. Your usage and browsing on any such website is subject to that website’s own policies. Please review the privacy notices posted on other websites that you may access through our website.

Aspen Publishing may provide you with additional or different privacy notices in specific instances on how your personal information is collected and used for a specific Service.

HOW YOU CAN CONTACT US

If you have any questions about how we process your personal information or if you want to exercise one of your rights, you can contact us at:

By Phone: 1-800-317-3113

By Email: support@aspenpublishing.com  

If you feel we are unresponsive or disagree with our data privacy practices, you can also file a complaint with your national Data Protection Authority.

In response to a request, we might ask you to verify your identity if needed, and to provide information that helps us to understand your request better. If we do not grant your request, whether in whole or in part, we will explain why.

From time to time we may update this Privacy & Cookie Notice or any other specific privacy statement. When making changes to this Privacy & Cookie Notice, we will add a new date to this Privacy Statement. This version is effective per September 21, 2023.