INSTITUTE OF CULINARY EDUCATION, INC. PRIVACY POLICY

Last Modified February 18, 2020

The Institute of Culinary Education, Inc. (“ICE,” “us,” our” or “we”) is committed to protecting your privacy. “You/your/user(s)” means you as a user of our Website, including any information, tools and services available from the Website. Our privacy policy, which applies to all Users of our Website, is designed to explain the information we collect and how we use it to provide our Services and give Users a better experience (“Privacy Policy”). Capitalized terms not defined in this Privacy Policy have the meanings given in our Terms of Use. This Privacy Policy is part of, and incorporated into, the Terms of Use.

This Privacy Policy describes the Personal Information (as defined below) we collect about you online on the Website, why we collect it, how we use it, and when we share it with third parties. This Privacy Policy also describes the choices you can make about how we collect and use certain of that information. The Personal Information provided by you is not used for any purpose other than as outlined in this Privacy Policy.

By accessing and using the Website you consent to our collection, storage, use and disclosure of your Personal Information and other information as described in this Privacy Policy. If you do not agree with the terms of this Privacy Policy, please do not provide any Personal Information to us. If you choose not to provide any Personal Information that is necessary for us to accept you into ICE programs or to provide you with specific products or services, we may not be able to provide those programs, products or services to you.

Types of Information We Collect
1. Personal Information; Anonymous Information. We collect both Personal Information and Anonymous Information about our users. “Personal Information” is information that can be used to contact or identify you or individuals about whom you enter information as part of your activities on our Website or Services, such as first name, last name, e-mail address, phone number, street address, comments, company name and address, title, work experience and skills, username and/or e-mail address in combination with a password or security questions and answers, account numbers or credit/debit card numbers, even without a security code, access code, or password if the account could be accessed without such information, as well as information that is linked to the forgoing information. “Anonymous Information” or de-identified information is information that cannot reasonably be used to contact or identify you and is not linked to information that can be used to do so. It includes passively collected information about your activities on the Website such as usage data, to the extent that information is not linked to your Personal Information.
2. “Aggregated Anonymous Information” is the combination of your Anonymous Information with the Anonymous Information of other users. Aggregated Anonymous Information does not allow you to be identified or contacted.
3. Non-Personally Identifiable Information. Through your use of the Website, we may also collect certain non-personally identifiable information from you (“NPII”). NPII is not associated with you as an individual. It is measured anonymously and only in the aggregate.
4. Cookies; Pixel Tags. We may also use tools such as cookies and pixel tags to gather information as well. “Cookies” are small pieces of information that a website sends to your device while you are viewing the Website. We use both session Cookies (which expire once you close your web browser), persistent Cookies (which stay on your device until you delete them) and third-party Cookies (which are placed by a website from a domain other than ours) to provide you with a more personal and interactive experience. Persistent Cookies can be removed by following web browser help file directions. "Pixel Tags" (sometimes called "web beacons" or "clear gifs") are a snippet of code that collects information about a visitor’s behavior on a website, and then sends the information back to the originating platform to be processed and reported.
5. Unique Device Identifiers. Users can access and browse a majority of the Website without disclosing Personal Information, although, like most website providers, we passively collect certain information from your devices, such as your IP address, browser information, unique device identifier (“UDID”) and/or your mobile operating system.
6. User-Provided Information. We collect information that you provide directly to us when you engage in the following:
  - When you apply for admission to ICE
  - When you register an online account from ICE or update or change your account information
  - When you enroll, register, or participate in ICE classes, programs or other offerings, whether online or in person (such as through a study abroad offering), including by using ICE’s Website and other information technologies (such as when you turn in assignments and projects online, use online courseware or proctoring services, participate in online discussions and forums, and communicate with ICE faculty and staff)
  - When you communicate with ICE via e-mail, telephone, or other methods
  - When you inquire about, apply for, or initiate employment with ICE
  - When you complete a survey for, submit information to, or request information from, ICE
  - When you are working for ICE
  - When, as a student or prospective student, you submit information to ICE admissions for information about ICE and its programs, tours, visiting our campuses, or interviews.
  - When, as a student or prospective student, you register for or use student services or amenities provided by ICE
  - When you purchase products from ICE (such as through our online shop)
  - When you participate in continuing education programs
  - When you participate in distance programs or other offerings which make use of video communications
    
    We may correlate this information with other Personal Information we have about you. We collect e-mail lists and information related to marketing services. When you use the Website, you may be given the option to subscribe to or to be added to our subscription or e-mail list, to schedule a personal call/meeting and to request certain resource materials. Whether or not you select this/these option(s), your Personal Information may be shared with third parties consistent with this Privacy Policy. You may opt-out or unsubscribe from these e-mail list or call/meeting requests at any time.
7. Hardware; Browser; IP Address. We may collect information from your use of the Website including your hardware model, browser type, operating system, Internet Protocol (IP) address and domain name, through the use of Cookies, web beacons or other technologies. This information may include the following: your browser and mobile device type, operating system and name of your Internet service provider; web pages you visit on the Website; IP address, browser type, profile information, geo-location information; information about your interactions with e-mail messages, such as whether the messages were opened and the links clicked in those e-mails; and standard server log information. If you are using a mobile device, we may also receive your UDID, or another unique identifier, and mobile operating system.
8. Payment Processing Information. Only some payment processing information is collected by us. We may also use a third party(ies) for payment processing. We do not want you to send us your credit card or bank account information by e-mail or other means except where requested as part of the checkout process. Please review the terms of use and privacy policies of the third-party payment processor prior to providing Personal Information to them.
9. Geolocation. If you access the Website through a desktop or mobile device, we may access, collect, monitor and/or remotely store geo-location data.
10. Third-Parties. We may also obtain information from other sources and combine that with information we collect directly. For example, we may collect information about you from third parties, including but not limited to identity verification services, fraud detection service providers, credit bureaus, mailing list providers and publicly available sources. If you create or log into your account through a social media site, we will have access to certain information from that site, such as your name, account information and friends lists, in accordance with the authorization procedures determined by such social media site.
  
  We use third-party services, such as Google Analytics, Google AdWords, Facebook Pixel, DoubleClick and Twitter Conversion Tracking, to track and analyze online behavior of our Users. These services may help inform, optimize, target and serve ads based your visits to our Website. We do this to better understand how you use the Website and Service, with a view to offering improvements for all Users, and to tailor our business and marketing activities accordingly. If you would like to opt out of Google Analytics, please download and install the browser plugin at http://tools.google.com/dlpage/gaoptout?hl=en. Users can also opt out of third party interest based advertising by visiting the Network Advertising Initiative’s deactivation website at www.networkadvertising.org/choices/.
  
  When you interact with ICE through social media networks, such as when you follow us, share content or contact us through Facebook, Twitter, Instagram, YouTube, Snapchat or other sites, we may receive information about you, including your profile information, picture, user ID associated with the social media account, friends list, and any other information you permit the social media network to share with third parties. The data we receive is dependent upon your privacy settings with the social network in question.
How We Use Your Information
1. Personal Information. We may use your Personal Information for the following representative purposes:
  - Process your school application, online tuition payment(s), special event requests (e.g. team building events, personal celebrations, corporate events, etc.), and/or enrollment in a recreational cooking or baking class
  - Review and process your submissions to promotions, scholarship challenges, and contests
  - For disciplinary or academic integrity proceedings;
  - Send communications, including information on career training, professional development programs, alumni development and engagement, special event coordination, and administrative e-mails
  - Communicate with and/or respond to you when you elect to “Chat live” or text with an admissions representative
  - provide you specific courses, products, special events, programs and/or services you select
  - satisfy our contractual obligations to you
  - To meet reporting and/or accreditation requirements and obligations, such as to the state or federal Departments of Education, the Accrediting Commission of Career Schools and Colleges, the Bureau of Proprietary School Supervision, and the Bureau for Private Postsecondary Education
  - Send you promotional/marketing information, newsletters, offers or other information
  - Perform internal operations, processing services, maintain user accounts, resolve disputes, establish, exercise, and defend legal claims, prevent and identify fraud, verify your identity and authenticate users
  - Personalize and tailor the features, performance and support of the Website
  - Analyze, benchmark and conduct research on user data and interactions with the Website and our products and services
  - Provide the materials, goods and/or services we offer and/or that you request
  - Identify your preferences, so we can notify you of new or additional course materials, classes, products, services, contests, and/or promotions that might be of interest to you
  - Improve our services, educational content, programs, events, customer service, and overall Website experience by aggregating and analyzing our customer data
  - Analyze the use of our products and services and information about visitors to the Website to enhance our marketing efforts • Communicate with you by e-mail, text message, app notifications, or other means about our company, our products, or other information that we believe may be of interest to you
  - Provide others with your Personal Information for the limited purposes described in this privacy policy
  - Send you notices of a transactional, administrative or relationship nature, or as required by law
2. Anonymous Information. We may use Anonymous Information for the following representative purposes:
  - Perform internal operations on the Website
  - Improve the Website and customize the user experience
  - Aggregate the information collected via Cookies and Pixels to use in statistical analysis to help us track trends and analyze patterns
3. Both Personal Information and Anonymous Information. We may use a combination of Personal Information and Anonymous Information that we collect to target and measure the performance of advertisements to Users both on and off of the Website on our own and through different ad networks and exchanges, using the following data, whether separately or combined: (i) data from advertising technologies such as Cookies, Pixels, web beacons, ad tags and device identifiers; (ii) User-provided information; (iii) data from your use of the Website; (iv) information from others (e.g., advertising partners, publishers and data aggregators); and (v) social media platforms.
Lawful Processing; Legitimate Interests. Ours Processing of your Personal Information for the purposes set out in this Privacy Policy is necessary for one or more of the following:
- Performing a contract with you, or to take steps at your request prior to contracting with you
- Protecting your vital interests or the interests of another person
- Complying with our legal obligations
- Pursuing our legitimate interests, including without limitation:
  - Providing, improving and customizing our educational offerings;
  - Administration of our operations;
  - Maintaining our accreditation status and complying with all reporting obligations related thereto;
  - Maintaining an ongoing relationship with alumni, donors and prospective donors, and helping to connect them with others;
  - Requesting gifts or donations;
  - Offering attendance to events and opportunities to volunteer and engage in community;
  - Understanding how our Website and services are being used;
  - Exploring ways to develop and grow;
  - Ensuring the safety and security of our students, faculty, employees and others;
  - Cybersecurity;
  - Enhancing protection against fraud, spam, harassment, intellectual property infringement, crime and security risks; and
  - Meeting our obligations and enforcing our legal rights
How We Share and Disclose Personal Information
1. We will not rent, sell or share your Personal Information with third parties except as set forth herein. If you do not want us to use or disclose Personal Information collected about you in the ways identified in this Privacy Policy, you may choose not to use the Website or provide your Personal Information at any time. If you choose not to provide any Personal Information that is necessary for us to accept you into ICE programs or to provide you with specific products or services, we may not be able to provide those programs, products or services to you.
2. We may disclose your Personal Information to outside individuals and/or companies that help us bring you the educational services and products we offer and to create, operate, and maintain our Website. For example, we may work with third-parties to: (a) manage a database of customer information; (b) assist us in distributing e-mails; (c) assist us with direct marketing and data collection; (d) provide data storage and analysis; (e) provide fraud prevention; (f) provide customer service; and (g) provide other services designed to assist us in developing and running our Website and maximizing our business potential. We require that these outside companies agree to keep all information shared with them confidential and to use the information only to perform their obligations to us. In addition, if you submit an entry to a scholarship challenge or contest (collectively, “Contests”), ICE may share your Personal Information with the partners and vendors with whom it is administering, organizing and/or conducting the Contests.
3. Student Records. Certain records of ICE students are protected by the Family Educational Rights and Privacy Act and the Gramm-Leach-Bliley Act, New York law and ICE Policies. Information about student access to their education records and protection of education records is available in our FERPA Notice of Student Rights Policy which can be found in the ICE Career Catalogue and the Career Program Brochure. ICE may disclose confidential information with the consent of the student, under subpoena or court or der, or in other limited circumstances as permitted by FERPA.
4. We may disclose information we have collected about you if required to do so by law or if we, in our sole discretion, believe that disclosure is reasonable to (i) satisfy any applicable law, regulation, legal process or governmental request; (ii) enforce this Privacy Policy and our Terms of Service, including investigation of potential violations hereof; (iii) detect, prevent, or otherwise address fraud, security or technical issues; (iv) respond to user support requests, or (v) protect our rights, property or safety, our users and the public. This includes exchanging information with other companies and organizations for fraud protection and spam/malware prevention.
Use of Non-Personally Identifiable Information.
1. We use NPII to maintain and administer the Website, analyze trends, gather demographic information and comply with applicable law. We may share Aggregated Anonymous Information with third-parties. We may share this information with others without express notice to you or consent from you, and we may exploit, use and disclose your NPII without limitation of any kind. We authorize certain service providers to utilize NPII for their business purposes and in accordance with their privacy policies, such as to report on usage or industry trends to their customer base.
2. The Website may use Cookies. Cookies help us remember you when you return to the Website. Cookies also hold information to personalize and enhance your experience and to gather Website statistical data, such as which pages are visited, the Internet provider's domain name and the addresses of the sites you visited immediately before coming to and immediately after leaving the Website. The information in the cookies lets us trace your "clickstream" activity (i.e., the paths taken by users of the Website as they move from page to page) to enable us to better serve you by revealing which portions of the Website are the most popular. We may also allow our affiliate and service providers and advertisers to serve cookies from the Website to allow them to assist us in various activities such as doing analysis and research on the effectiveness of the Website, its content and advertising. Some third-party advertising companies may be advertising networks that are members of the Network Advertising Initiative, which offer a single location to opt out of ad targeting from member companies. For more information, see: www.networkadvertising.org.
3. We may also use Pixel Tags, which help us analyze users’ online behavior and measure the effectiveness of the Website and our advertising and marketing. Pixel Tags or Clear gif files are tiny graphics with a unique label that work in a similar way to cookies and are used to monitor the user’s online activities. In contrast to cookies that are saved on a user’s computer hard disk, clear gif files are embedded invisibly in websites and are about as big as the full stop at the end of this sentence. Where appropriate, we may combine the information collected by such Pixel Tags with the Personal Information of our customers. We may also use other analytical tools to evaluate site performance through the use of aggregated data, which contain no Personal Information. We work with service providers that help us track, collect, and analyze this information.
4. Cookies, Pixel Tags, and/or other analytical tools that we may use on the Website may collect information about your visit, including the pages you view, the features you use, the links you click, and other actions you take in connection with the Website. This information may include your computer's Internet protocol (IP) address, your browser type, your operating system, date and time information, and other technical information about your computer. We may also track certain information about the identity of the Website you visited immediately before coming to the Website. Cookies, pixel tags, and/or other analytical tools in our e-mails may also be used to track your interactions with those messages, such as when you receive, open, or click a link in an e-mail message from us. We may also work with businesses that use tracking technologies to deliver advertisements on our behalf across the Internet. These companies may collect information about your visits to the Website and your interaction with our advertising and other communications, but no Personal Information is shared with them.
5. We may combine the NPII collected through Cookies, Pixel Tags and other analytical tools with other information we may have collected from you. This information may be used to improve the Website, to personalize your online experience, to help us deliver information to you, to determine the effectiveness of advertising, and for other internal business purposes. We may use and share aggregated and anonymous information to conduct market research and analysis for ourselves and/or for our business partners. Given the anonymous, non-personally identifiable nature of such information, there are no restrictions under this Privacy Policy on how we may use or disclose such information. For example, we may freely share such information with third parties who may use such data for their own marketing, advertising, research, or other business purposes. We may also freely share such information with our service providers in order for them to perform services to or for us.
6. The Website contains links to and/or enables certain third-party functionalities to enhance your experience on the Website, including social plug-ins, tools and APIs. Prior to using any third party functionalities (e.g., Facebook “Like” button) on the Website, you should consult the privacy notices of the third party providers of such functionalities (e.g., Facebook), as we have no control over information that is submitted to, or collected by, such third parties, or how they may use the information. The privacy policies and data practices of such third parties may significantly differ from ours, and we make no representation or warranty whatsoever about their policies and practices. Your communications and interactions with such third parties are solely between you and them and are at your own risk.
Data Retention.
1. We will retain your Personal Information for as long as is necessary for the purposes set out in this Privacy Policy unless a longer period is required under applicable law or is needed to resolve disputes or protect our legal rights or otherwise to comply with legal obligations.
2. Where we are processing Personal Information based on our legitimate interests, we generally will retain the data for a reasonable period of time based on the particular interest, taking into account the fundamental interests and the rights and freedoms of the data subjects.
3. Where we are processing Personal Information based on your consent, we generally will retain the information for the period of time necessary to carry out the processing activities to which you consented, subject to your right, under certain circumstances, to have certain of your Personal Information erased (see Section 8, Deleting, Changing & Updating Your Personal Information).
4. Where we are processing Personal Information based on contract, we generally will retain the information for the duration of the contract plus some additional limited period of time that is necessary to comply with law or that represents the statute of limitations for legal claims that could arise from the contractual relationship.
Opting-Out
1. Unsubscribe. You may opt out of: (a) receiving e-mail communications such as e-mail newsletters and promotional e-mails by following the instructions provided at the bottom of each e-mail, clicking the “unsubscribe” button at the bottom of e-mails we sent you; and/or (b) receiving promotional e-mail communications and newsletters by e-mailing us at privacy@ice.edu and including the word “UNSUBSCRIBE” in the subject text. Opting out of receiving Website communications will not affect your receipt of service-related, education-related, and administrative communications, such as payment confirmations, delivery status updates, updates to our Terms of Use and this Privacy Policy as we must be able to communicate with you regarding your purchases. If you do not receive a response from us to any e-mails you send to us within ten (10) business days, please send us another e-mail as your original e-mail may not have been received.
2. Google Analytics. Our products and services may use Google Analytics Advertising Features and its associated tracking technologies to help display our ads you see on other sites, and to help us manage and optimize our online advertising efforts. To opt out of Google Analytics Advertising Features, visit Google’s Ad Settings page, currently located at https://www.google.com/settings/ads/anonymous?sig=ACi0TChBBUZhbil6jSzh_t9gc_hilJmxPFILo3fzsOJJ6mtq1DpanjQIychv5x00ayD5xiJnE_7py3LRuGOQtj8YQx5_1ZS2FA&hl=en. Website users can also access the Google Analytics Opt Out Browser Add-on, currently located at https://tools.google.com/dlpage/gaoptout or http://tools.google.com/dlpage/gaoptout?hl=en. We may also work with Facebook and Apple to provide analytics in connection with our Website, including our mobile applications. For more information about Facebook’s privacy practices, you may visit https://www.facebook.com/about/privacy, and for Apple’s privacy policy, click here http://www.apple.com/privacy/privacy-policy/.
3. Ad Industry Opt-Outs. You can opt out of Internet-based and mobile advertising on your mobile device by visiting TRUSTe’s Ad Preference Manager, currently available at https://preferences-mgr.truste.com/. You may can opt out of receiving online behavioral or internet based advertising by using the tools located at the Digital Advertising Alliance’s consumer choice page, currently available at http://www.aboutads.info/choices/ or the Network Advertising Initiative (NAI) opt out tool currently available at http://www.networkadvertising.org/choices/. When using the ad industry opt out tools, note that: (a) if you opt-out we may still collect some data about your online activity for operational purposes (such as fraud prevention), but it will not be used by us for the purpose of targeting ads to you; (b) if you use multiple browsers or devices you may need to execute this opt out on each browser or device; and (c) other ad companies’ opt-outs may function differently than our opt-out, and we have no control over the practices of any third parties. We do not make any representations or warranties about such opt-out services. Such services are independent from us, and we have no control over, or responsibility for their performance.
4. Cookies. You can opt out of accepting Cookies or disable them from your browser. The “Help” function on most browsers contains information on how you can set your browser to notify you before accepting Cookies or can disable them entirely. If you opt out of Cookies, you will not be able to take advantage of various features of the Website that are available to other users. For example, we may use Cookies to recognize you by name when you return to this Website so you don’t have to login again and provide your password each time.
5. Text Messages. If after signing up to receive more information about our educational programs, you would like to change or update your contact preferences, you may do so by contacting us by phone at the toll-free phone number (888) 552-8546 or by e-mail at TCPArequests@ice.edu. With regard to automated text communications, if you prefer not to receive text or wireless promotional communications on your mobile device, you can opt out by replying STOP to any text you receive from us.
Deleting, Changing & Updating Your Personal Information
1. You may correct, update or revise your Personal Information that is inaccurate or request that we delete your Personal Information from our system. In certain cases, you may also have a right to: (i) to restrict or limit the ways in which we use your Personal Information; (ii) to object to the processing of your Personal Information; and (iii) to obtain a copy of your Personal Information in an easily accessible format.
2. If you withdraw your consent to the use or sharing of your Personal Information for the purposes set out in this Privacy Policy, you may not have access to the related services, and we might not be able to provide you with certain or any services.
3. To submit a request, please send an e-mail message to privacy@ice.edu. We do not want to take any action regarding your Personal Information at the direction of someone other than you and may therefore ask you for information verifying your identity.
4. BASIS FOR CONTINUED USE OF YOUR PERSONAL INFORMATION. Please note that, in certain cases, we may continue to process your Personal Information after you have withdrawn consent and requested that we delete your Personal Information, if we have a legal basis to do so. For example, we may retain certain data if we need to do so to comply with an independent legal obligation (e.g. with relation to certain legal reporting and/or accreditation requirements of the applicable state or federal Departments of Education, the Accrediting Commission of Career Schools and Colleges, the Bureau of Proprietary School Supervision, and the Bureau for Private Postsecondary Education), if we still need the data for the lawful purposes for which we obtained the data, or if it is necessary to do so to pursue our legitimate interest in keeping our services and operations safe and secure. Furthermore, if we have already disclosed your Personal Information to third-parties pursuant to the terms of this Privacy Policy, we cannot access that Personal Information any longer and cannot compel the deletion or modification of any such information by the parties to whom we have made those disclosures.
European Economic Area (“EEA”) Users
1. Data Transfers. For Users visiting the Website and using our services from within the EEA, we may need to transfer your Personal Information to countries outside the EEA, including to the USA because we are headquartered there. In cases where we do transfer your Personal Information to countries outside the EEA, we will take reasonable steps in accordance with applicable privacy and data protection requirements.
2. Complaints. If you have any complaints regarding our privacy practices, you have the right to make a complaint with your national data protection authority (i.e., supervisory authority), but we hope that you will contact us first at privacy@ice.com to provide us with an opportunity to address your concern, Attn: Privacy Office, The Institute of Culinary Education, Inc. 225 Liberty Street, New York, New York 10281.
California Privacy Rights
1. Shine the Light. Pursuant to California Civil Code Section 1798.83, also known as the "Shine The Light" law, California residents have the right to request in writing from businesses with whom they have an established business relationship: (i) a list of the categories of Personal Information, such as name, address, e-mail address, and the type of services provided to that individual, that a business has disclosed to third-parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties’ direct marketing purposes, and (ii) the names and addresses of all such third-parties. ICE does not share Personal Information with third-parties for those parties’ direct marketing. To request the above information, California residents can e-mail us at CAPrivacy@ice.edu or write to us at The Institute of Culinary Education, Inc., Attn: Privacy Office, 225 Liberty Street, New York, New York 10281. Please note that, under California law, a business is only required to respond to such a request twice in any calendar year.
2. Requesting Access to or Deletion of Personal Information. If you are a California resident, you have the right, subject to certain exceptions defined in the California Consumer Privacy Act (“CCPA”) and other applicable laws and regulations, to request that we disclose certain information to you about our collection and use of your Personal Information over the past twelve (12) months.
  
  In order to verify your request, you will need to provide us with sufficient information to identify you individually so that we can comply with you request, including the name you provided to us when you created your account(s) (i.e. your legal first, last name or variants thereof, e.g. nicknames, aliases, titles (“Mr.”, “Mrs.”, “Dr.”, “Jr.”, etc.), the e-mail address(es) you use to correspond with us and any other e-mail addresses you have used with us in the past, your relationship with us (e.g. student, prospective student, special events customer, etc.), your mailing address, including the state and city you reside in currently.
  
  To make an information access and/or deletion request you may contact us by phone at the toll-free phone number (888) 552-8546 or by e-mail at CAPrivacy@ice.edu.
3. Non-Discrimination. We will not discriminate against you for exercising any of your rights under California law, including:
  - Deny you goods or services
  - Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties
  - Provide you a different level or quality of goods or services
  - Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services
4. Do Not Track. Some web browsers may let you enable a "do not track" feature that sends signals to the websites you visit, indicating that you do not want your online activities tracked. This is different than blocking or deleting cookies, as browsers with a "do not track" feature enabled may still accept cookies. There is currently no industry standard for how companies should respond to "do not track" signals, although one may develop in the future. We do not respond to "do not track" requests or signals at this time.
Children

This Website is not directed to or intended for children under 13 years of age. We do not knowingly solicit, collect or maintain information from those we actually know are under 13, and no part of our Website is targeted to attract anyone under 13. We also do not send e-mail correspondence to anyone who advises that they are under the age of 13. If we later obtain actual knowledge that a User is under 13 years of age we will take steps to remove that User’s Personal Information from our systems. If you are the parent or guardian of a child whom you believe has disclosed Personal Information to us, please contact us at privacy@ice.edu or write to us at The Institute of Culinary Education, Inc., Attn: Privacy Office, 225 Liberty Street, New York, New York 10281 so that we may delete and remove such information from our system.
Security; Legally Required Disclosures
1. Security. We strive to keep your Personal Information private and safe. We take commercially reasonable physical, electronic and administrative steps to maintain the security of Personal Information collected, including limiting the number of people who have physical access to database servers, as well as employing electronic security systems and password protections that guard against unauthorized access. In addition, it is our policy to never send your credit card number via e-mail. Any payment transactions will be encrypted. We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored Personal Information or "Personal Information" (as defined in applicable state statutes on security breach notification) to you via e-mail, text or conspicuous posting on the Website in the most expedient time possible and without unreasonable delay, insofar as it is consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system. Your consent to such purpose remains valid after termination of our relationship with you.
  
  Unfortunately, despite our best efforts, the transmission of data over the Internet cannot be guaranteed to be 100% secure. While we will use reasonable means to ensure the security of information you transmit through the Website, any transmission of Personal Information by you is at your own risk. We cannot guarantee that such information will not be intercepted by third-parties and we shall not be liable for any breach of the security of your Personal Information resulting from causes or events that are beyond our control, including, without limitation, your own act or omission, corruption of storage media, defects in third party data security products or services, power failures, natural phenomena, riots, acts of vandalism, hacking, sabotage, or terrorism, and we are not responsible for circumvention of any privacy settings or security measures contained on the Website.
2. Legally Required Disclosures. We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored "Personal Information" (as defined in applicable state statutes on security breach notification) to you via e-mail and/or conspicuous posting on the Website in the most expedient time possible and without unreasonable delay, insofar as it is consistent with (i) the legitimate needs of law enforcement; or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.
Third-Party Websites

While visiting the Website, you may link to websites operated by third parties or you may have come to the Website using a link found in another website. We do not make any representations or warranties about any third-party website, we have no control over them or the information, services, products they provide or the manner or methods they employ to collect, store, access, or otherwise use your Personal Information. If you provide Personal Information at one of those websites, you are subject to the privacy policy of the operator of that website, not our Privacy Policy. Please make sure you understand any other website's privacy policy before providing Personal Information.
Changes to Our Privacy Policy

We reserve the right to change, modify, add or remove portions of this Privacy Policy at any time and without prior notice, and any changes will become effective immediately upon being posted. However, we will not use your Personal Information in a way that is adverse and materially different from the uses described in this Privacy Policy without giving you an opportunity to opt out. The “Last Modified” date indicates if and as of when changes have been made to this Privacy Policy. Your continued use of the Website after this Privacy Policy has been amended shall be deemed to be your continued acceptance of the terms and conditions of the Privacy Policy, as amended.
Contact Us

If you have any questions regarding our Privacy Policy, or if you wish to issue a request to exercise your rights where applicable by law, you can contact us via e-mail at privacy@ice.edu or write to us at The Institute of Culinary Education, Inc., Attn: Privacy Office, 225 Liberty Street, New York, New York 10281.