PRIVACY POLICY

Updated: May 24, 2011

Apollo Global, Inc. is committed to protecting your privacy when you visit our Site(s). We want you to know what Information we collect, how we use it, and how you can request that this Information be updated or corrected.

Certain Company Site(s) may be subject to additional privacy policies (collectively "Additional Policies"). In the event of any direct conflict between any Additional Policies and this policy, the Additional Policies shall control. The Company reserves the right to resolve any conflicts between policies in its sole discretion.

The Company reserves the right to amend or otherwise modify this Privacy Policy at any time, so please re-visit this page periodically to check for updates. The date of last revision is shown at the top of this document.

Scope

Our Privacy Policy covers any visitor to our Site(s), including current and prospective students. This policy applies to both online and offline collection, storage, processing, and transfer of Personal Information.

1. Definitions

As used in this Privacy Policy, the following terms have the following meanings:

"Business Associates" means third party service providers which Apollo Group, Inc. or the Company may contract with to provide services on its behalf including those related to the Site(s) or for transactions occurring on the Site(s) including, but not limited to Social Networking, hosting, web analytics, lead generation, academic, business or financial services.

"Company", "we", "us", and "our" refer to Apollo Global, Inc., its controlling shareholder, Apollo Group, Inc., and each of the subsidiaries of Apollo Global, Inc., including educational companies or institutions.

"Educational Partners" means our controlling shareholder, the Apollo Group, Inc., and its subsidiaries including educational companies or institutions that Apollo Group, Inc. or its subsidiaries may be providing educational or other related services to under contract.

"Financial Information" means specific Personal Information of a financial nature such as your credit card number.

"Information" means any Information collected and includes: "Personal Information", "Financial Information", "Web Analytical Information" or any other Information collected from you through our Site(s).

"Marketing Information" means your Web Analytical Information and your Personal Information such as your name, address, e-mail address and telephone number that the Company collects, uses and discloses for the marketing and promotional purposes as disclosed in this Privacy Policy.

"Personal Information" means Information that may be used, alone or in combination, to identify a specific individual and includes Financial Information.

"Site" or "Sites", means the Company's websites located at www.apolloglobal.us and ApolloGlobalStudy.com as well as any other Company-controlled or authorized Sites (including, without limitation, any Business Associate sites), regardless of domain name or IP address.

"Social Network", means various Internet communication technologies provided on Sites that facilitate conversation and interaction between people online and includes, but is not limited to, blogs, discussion forums, wikis, chat sessions, news groups, etc.

"Social Network Content" (or "SNC") means user-generated content you consent to share via a Social Network and includes, but is not limited to, Personal Information, including digital sounds and pictures that you upload to a Social Network. It also includes your Personal Information that may be displayed on other users' Social Network pages.

"Unrelated Entities" means third parties that are not Educational Partners and who are not providing services to Apollo Group, Inc. or the Company as Business Associates.

"Web Analytical Information" means internet generated Information we collect when you visit our Sites. This Information may be linked with marketing and Personal Information. When linked with other Information identifying you personally, either alone or in combination with other Information, then such Information also will be considered Personal Information.

2. Information We Collect

We collect various types of Information from you through our Sites, when we talk to you on the phone and in person with Company representatives. Some of this Information is collected automatically through various web and internet technologies including Social Networking tools used by the Company. Other Information is collected when you provide it in response to an advertisement, a survey, or a request for information; or if you register or order educational or other products and services, set up a Social Network or other Site profile, or if you choose to use one of our learning assessments or other interactive tools.

3. Information Collected Automatically

Each time you visit one of our Sites, Web Analytical Information is automatically gathered. In general, this Information does not identify you personally. Examples of Web Analytical Information include, but are not limited to:

IP address
Collection Date
Publisher Name
Connection Speed
Day of Week Time of Day (hour)
Language settings
Country, State, DMA, City (relating to IP address, if available)
Domain (.com, .net, .mil, .org, .edu, etc.)

Our collection of Web Analytical Information lets us see how users are finding, and navigating our Sites, user preferences regarding Site or Social Networking Content, and it tells us which pages users visited most often so we can make our Sites more useful and relevant. This Information may be linked with personal Information to accomplish the purposes described in this Privacy Policy

4. Information You Provide to Us

In addition to the Web Analytical Information automatically collected when you visit our Sites, the Company also collects, uses and discloses Personal Information that you provide to us voluntarily when you respond to an advertisement, a survey, or a request for information; or if you register or order educational or other products and services, set up a Social Network or other Site profile, or if you choose to use one of our learning assessments or other interactive tools. While the exact nature of the Personal Information may vary depending on the type of response or service requested, the following is a non-exclusive list of the types of Information that may be collected to the extent it is necessary and applicable for the intended purposes:

First, Middle and Last Name, Previous Names
Street Address, City, State, Country, Postal Code
Date of Birth
Place of Birth
Gender
Race
Ethnicity
Country of origin
Employment
Native Language
Address Type
E-mail address
Valid Day or Evening Telephone Number
Cell Phone Number
Confirmation of the age of majority
Campus (based on postal code list)
Company institution interested in
Current degree program of interest
Current modality of interest (online, on-ground or Flexnet)
Publisher Code (SiteID)
Citizenship (Visa Types, Date of Issue – if you want to add this)
# of Previous Credits
Military Affiliation
Credits earned
Prior Education History
High School Diploma
Lead Source
Individual Record Number (IRN) or Social Security Number
Credit Card Number
Other Financial Information and information related to financial aid eligibility
Social Networking Content
Learning Assessment data
Other Information after you become a student at the Company such as course assignments, grades and other educational records relating to your enrollment at the Company and that may be required to be collected in the normal course of your studies.

5. How We Use This Information

Marketing Information

We use marketing Information to help us better plan our Sites and services to meet your needs; to measure and improve our Site(s)' services and features, to communicate with you by e-mail, postal mail, telephone, cellular/mobile phone, PDA devices, and/or on applications for mobile phones such as iPhone or Blackberry about products or services that may be of interest to you, to provide you with customer support, to prevent potentially illegal activities (including illegal downloading of copyrighted materials in accordance with our Copyright Infringement policy), and to enforce our Terms of Use. We also use a variety of technological systems to detect and address anomalous activity and to screen content to prevent certain abuses such as spam. These efforts may on occasion result in permanent suspension or termination of Site functionality for some users.

Personal Information

The Company recognizes that by choosing to provide us with your Personal Information, you are demonstrating your trust in us and we take that trust seriously. We will not sell, rent or lease your Personal Information to others.

We may collect, use and disclose Personal Information for the following purposes:

to determine your admissibility and to register you for your selected educational programs to provide requested products and services
to respond to your inquiries
to administer promotions to which you have indicated an interest
for our internal marketing purposes, which includes, but is not limited to, sending you material about products, services, updates, etc. that we think may be of interest to you
for fostering communication and collaboration among members of the Company community through Social Networks
for sharing with our Educational Partners who may contact you with respect to their educational or marketing services
for sharing with our Educational Partners or Business Associates who are performing services on our behalf
to analyze how Sites and services are being accessed and used
to improve Site and service performance and delivery
to analyze academic and learning outcomes and preferences
to analyze risk and business results
to obtain payment for services that we provide to you
to maintain business records for reasonable periods
to provide to Educational Partners, Business Associates or Unrelated Entities in connection with the contemplated or actual reorganization, merger, acquisition, financing, securitization, insuring, sale or other disposal of all or part of our business or assets, including for the purposes of determining whether to proceed with such transaction or fulfilling any records or other reporting requirements to such parties. In the event of any actual reorganization, merger, or acquisition such Information may be transferred as part of the transaction to the acquirer
and/or as may be required or permitted by legal, regulatory, industry self-regulatory, insurance, audit, or security requirements applicable to the Company, our Educational Partners, or our Business Associates.

Express Consent To Receive Pre-Recorded Voice Messages, Text Messages And Calls Using an Autodialer

In connection with the uses set forth above, we may use an automatic telephone dialing system, artificial or prerecorded voice messages, or text messages to provide you with various communications. Further, when you provide us with a cellular, wireless, or mobile telephone number as your contact number, you agree that you are providing us with your express consent to receive calls using an automated dialing system, prerecorded voice messages or text messages related to your enrollment. If you do not wish to receive these updates on your cellular or mobile phone, please provide us with a LAN-based telephone number.

Financial Information

Your Financial Information will be used to provide requested products and services, to analyze operational and business results, to analyze risk, and for concluding your registration or other transaction you have initiated with us. It will not be sold, rented, or otherwise transferred to an Educational Partner, Business Associate or Unrelated Entity outside of this purpose, except in the case of a reorganization, merger or acquisition of our shares or assets or those of our parent company Apollo Group, Inc.

6. Student Educational Records

If you are or subsequently become a student at the Company, your educational records may be subject to the U.S. federal Family Educational Rights and Privacy Act (FERPA) or other similar laws in other jurisdictions, federal, state or other applicable laws and the Company's policies. In cases where student records are subject to FERPA, the respective students have the right to limit access to FERPA-defined directory Information about them. To obtain a copy of the Company's FERPA policy, click here. You may also contact us via one of the below methods:

Phone: 1.800.866.3919
Email: USSC@phoenix.edu
Mail: University of Phoenix
Attn: Registrar's Office
Mail Stop CF-L201, 4025 S. Riverpoint Parkway
Phoenix, AZ 85040
USA

7. Location of Information Processing

Because we operate in multiple jurisdictions, including the United States, the United Kingdom, Mexico and Chile, some Educational Partners and Business Associates may be located outside of the jurisdiction in which you reside. In such cases, your Personal Information may be collected, used, disclosed, stored and processed in these other jurisdictions for the purposes described in this Privacy Policy. The data protection and other laws of the United States and other countries might differ from your jurisdiction. While we require our Educational Partners and Business Associates to use your Personal Information only to perform the services we have retained them to provide and take reasonable steps to ensure that your privacy is protected in accordance with applicable laws, please be advised that, by using our Sites, your Information may be transferred across borders and will be subject to the laws of those other jurisdictions, including lawful requirements to disclose Personal Information to government authorities.

8. Opt-Out

You may opt-out of our collection, use and disclosure of your Personal Information at any time, subject to contractual, academic, legal or technical restrictions and reasonable notice. Note that if you opt-out of certain uses of your Personal Information, we may no longer be able to provide certain products or services. You may not be permitted to opt-out to certain necessary collection, uses and disclosures, for example, but not limited to, educational announcements, maintaining reasonable academic, business and transaction records and disclosures to government entities as required for us to comply with applicable laws. Click here to opt-out.

You can choose to no longer receive marketing communications from us and you may express your choice where indicated on the applicable email or other communication or click here to opt out. Please note, however, that such a request will only remove you from our list and the list of any Business Associate performing services on our behalf. We are not responsible for the use any other party may make of the Information once it has been transferred in accordance with this Policy and you will need to contact such entity to have your Information removed from their database.

You may change various user settings related to sharing your Personal Information contained in any user profile you set up as part of Social Network activities furnished by us, subject to contractual, academic, legal or technical restrictions and reasonable notice. Note that your withdrawal from Social Network activities might prevent us from providing you with certain products or services.

Students who desire to prevent release of their directory and educational record Information in accordance with FERPA may place a FERPA Hold on their academic file. Click here to review the Company's FERPA Policy.

9. Our Security Measures

We will take commercially reasonable measures to secure and store your Information to protect against the loss, misuse, and alteration of the Information under our control. We utilize industry standard security measures when accepting your credit card Information during the online ordering process, as well as whenever we ask you to login to any of our Site(s).

Unfortunately, no data transmission over the internet can be guaranteed to be completely secure. As a result, although we will utilize such measures, we do not guarantee you against the loss, misuse, or alteration of Information under our control, and you provide Information to us at your own risk. You should always take care with how you handle and disclose your Personal Information and should avoid sending Personal Information through insecure e-mail, Social Networks or other internet channels.

10. Monitoring of Communications

We may monitor and retain all incoming and outgoing communications for training of our representatives and for quality assurance purposes. To the extent such communications are selected, they are only retained as long as necessary to adequately discharge these purposes, unless a specific communication needs to be retained for legal reasons. If you prefer that your communications not be retained for any reason, please advise your representative.

11. Internet Technologies Used

Cookies, web beacons and other relevant internet technologies are used on our Sites to allow us to accomplish the uses set out above as well as to deliver Sites messaging and to keep track of your Information. These small pieces of program code reside in your computer and browser and can be removed. If you desire to remove such technologies you may do so, but this may render our Sites unusable to you. You can opt out of cookies or the other internet technologies used by disabling these features in your browser program. Consult your browser's "Help" menu for assistance in changing cookie settings or removing cookie files.

12. Children's Privacy

We are very sensitive to the issue of children's privacy. Our Sites are neither developed for, nor directed at children under 13. If you believe your child has provided us with Personal Information, or registered at one of our Sites and would like to have this Information removed, click here.

13. Site Hosting and Links from Our Sites to Other Websites

Some of our Sites may be hosted by our Business Associates or contain links to external websites hosted by Educational Partners and Unrelated Entities. When you access these Sites or external websites, the providers of the websites may have access to your Personal Information and may apply their own policies on how your Personal Information is used. Please make sure to read the policies of any Sites you visit on the internet carefully. Please be aware that we are not responsible for the privacy practices or the content of any sites or external websites that we do not control directly and the collection, use and disclosure of Information about you by Educational Partners, Business Associates and Unrelated Entities will be subject to the policies applicable on those other Sites or external websites.

14. Privacy Policy Changes

The Company may update this Privacy Policy or revise it from time to time. If you are concerned about how your Personal Information is used or disclosed you should contact us as described below or check back at this Site periodically to obtain a current copy of this Privacy Policy. We urge you to review this Privacy Policy frequently to obtain the current version. Your continued provision of Personal Information or use of our services following any changes to this Privacy Policy constitutes your acceptance of such changes. If we intend to use Information that personally identifies you in a manner materially different from what we stated at the time it was collected, we will attempt to notify you at least 30 days in advance. You will be given a choice as to whether or not previously provided Information may be used in a new way.

15. How to Access Your Information and Contact Us

If you want access to or wish to update any of your Personal Information or have any questions about our privacy practices, please contact our Chief Ethics and Compliance Officer at Ethics.Compliance@apollogrp.edu or

Apollo Group, Inc.
Attn: Chief Ethics & Compliance Officer
4025 S. Riverpoint Parkway
Phoenix, AZ 85040 USA