Emeritus Privacy Notice

This website is owned and operated by EMERITUS Institute of Management Pte. Ltd. (Singapore Company Registration Number: 201510637C).

This privacy policy (the “Privacy Policy” or “Policy”) explains how EMERITUS Institute of Management Pte. Ltd. and all of its affiliates and subsidiaries (collectively, “Emeritus”) use, share, and protect personal information that we collect, including on Eruditus.com and each of their respective subdomains (the “Site(s)”), information provided during telephone communications, information we collect from websites of our University partners, and information we collect from our referral partners. This Policy does not apply to information that we may collect from you in other ways (for example, this Policy does not apply to information that you may provide to us by fax or through conventional mail). The Privacy Policy is incorporated into our Terms of Service.

EU Residents: The Site is intended for global users. If, however, you are a resident of the EU then you have additional privacy rights, which are explained here.

California Residents: If you are a resident of the State of California you have additional privacy rights, which are explained here.

These rights are additional to those described in this Privacy Policy.

For purposes of this Policy, “Personal Data” means your personal data and any third party’s personal data such as the personal data of your parents.

We may log the IP address, operating system, and browser software used by each user of the Site, and we may be able to determine from an IP address a user’s Internet Service Provider and the geographic location of his or her point of connectivity. Various web analytics tools are used to collect this information. Some of the information is collected through cookies. If you reject our cookies, many functions and conveniences of this Site may not work properly. Although user sessions are tracked, a user remains anonymous.

As a responsible private educational institution, EMERITUS is committed to maintaining a high standard of confidentiality with respect to the Personal Data of our students, alumni, university partners, vendors, employees, faculty, and other third parties in accordance with the requirements of the Personal Data Protection Act 2012 (the “PDPA”), Singapore. For more information about the PDPA, please visit the Personal Data Protection Commission’s website at https://www.pdpc.gov.sg

Our courses are delivered to students from many different countries – in recognition of this, we endeavor to process all data in accordance with principles of internationally accepted best practices. We regularly review our compliance with this Policy and whenever we receive a formal complaint, we will contact the person who made the complaint to attempt to resolve his or her concerns.

To safeguard your Personal Data, all electronic storage and transmission of Personal Data are secured with appropriate security technologies.

By reading this Policy and submitting any application or applying for any of our products or services, you hereby agree to this Policy and consent to our collection, use, and disclosure of your Personal Data.

“Personal Data” is defined in the PDPA to mean personal information, whether true or not and whether in electronic or other form, about an individual who can be identified:

  1. from that data; or
  2. from that data and other information to which we have access to or are likely to have access to.

Examples of personal data are your name, address, NRIC/FIN/Passport number, photograph or video image, telephone numbers and email addresses.

Personal Data excludes Business Contact Information which means an individual’s name, position name or title, business telephone number, business address, business electronic mail address or business fax number and any other similar information about the individual, not provided by the individual solely for his personal purposes.

To find out more about PDPA, you may visit the Singapore Personal Data Protection Commission’s website at https://www.pdpc.gov.sg.

Emeritus and its partners, including its University partners and referral partners (collectively “Emeritus Partners”, “we” or “us”) collect personal data and other data from the Site.

Personal Data We Collect.

We collect Personal Data that you provide us directly, as well as Personal Data that you provided to our University and referral partners that you consented may be shared. In addition, where permitted by applicable law, we collect or receive information about you from companies to whom you indicate that you would like to learn more about an Emeritus program (collectively “Other Sources”) in order to update or supplement the information that you provide or that we collect automatically, as described herein. We use this information to help us maintain the accuracy of the information we collect, to target our communications so that we can inform you of products, services or other offers that may be of interest to you, and for internal business analysis or other business purposes. We may also collect information about you when you respond to advertisements through social media such as Facebook Leads Ads

The Personal Data we collect may include:

  1. your name
  2. your e-mail address
  3. your identification number
  4. your contact particulars
  5. your image
  6. your country of residence
  7. your residential address
  8. your work history
  9. your educational details
  10. your date of birth
  11. the content of any communication that we exchange

Information we collect apart from your Personal Data may include the following:

  1. Cookies and Usage Data. Please see Cookies and Pixel Tag Policy herein.

How We Use Your Personal Data

We collect, use and disclose your Personal Data for the following purposes in connection with the products or services for which you have applied, to the extent applicable:

  1. To fulfill a contract or take steps relating to a contract, with one of our University Partners. This includes:
    • General administration of your application and/or registration and/or enquiry for any program offered by us or our University partners;
    • Performing EMERITUS’ obligations arising from any contracts entered into between you and us;
    • Enabling EMERITUS’ subcontractors, third-party agents and service providers to fulfill obligations/services as stipulated in your contract with EMERITUS;
    • Administering and updating your records in our databases, and monitoring and maintaining a record of previous transactions;
    • Improving our offerings, both individually (e.g., by course staff when working with a student) and in aggregate, and individualizing the experience and evaluating the access and use of the Site;
    • Responding to the inquiry made, for example, responding to a specific inquiry or providing you with access to the specific course content and/or services you select; and
    • Tracking both individual and aggregate attendance, progress and completion of a course, and analyzing statistics on student performance and the manner in which students learn.
  2. For administrative purposes in connection with operating its business.
    • Monitoring and detecting violations, misuses or potential misuses of the Site;
    • Sending you email messages about Site maintenance or updates;
    • Authenticating your identity, when needed;
    • Processing payments and refunds, as applicable;
    • Improving the Site, our products and services;
    • For training purposes;
    • For government, audit and other regulatory purposes, including but not limited to, EMERITUS re-certification and accreditation purposes;
    • Conducting checks with the DO NOT CALL Registry;
    • Internal reporting and/or accounting purposes; and
    • Complying with internal policies and procedures and any applicable laws, rules, regulations, codes of practice or guidelines, orders or requests issued by any court, legal or regulatory bodies (including but not limited to disclosures to regulatory bodies, conducting audit checks, surveillance and investigation and US embargo laws or any regulations or laws promulgated by the United Nations).
  3. To conduct the regular business of Emeritus and pursue all legitimate business interests in marketing our programs, services and products, including:
    • Conducting direct marketing; we may process your Personal Data to contact you via email, telephone, direct mail, SMS or other methods of communication to provide you with information regarding the products or services that may be of interest to you. We may send information to you regarding the products or services, upcoming promotions and other information that may be of interest to you, using the contact details that you have provided to us;.
    • We may use your email address or other contact information to identify groups of individuals with similar interests or characteristics on social media, which we would target for advertisement. Your data would not be used for any other purpose by the social media. This would be based on our legitimate interest to increase the audience of persons likely to be interested in our services. You have a right to object to this use of your information that can be exercised by informing us through email at privacy@emeritus.org
    • We may be targeting advertising on social media through services offered by third-party Service Providers, such as Facebook Custom Audiences or other similar business tools to groups of individuals identified by such social media as having similar interests or characteristics than our existing contacts. This processing activity is based on our legitimate interest to increase the audience of person likely to be interested in our services. In such case, we will be acting as joint controller with the social media (which contact details can be found on the social media’s platform). Such targeted audience will be provided with the possibility to object to the display of targeted advertising by the social media. We will not have any personal data on this audience, except to the extent it decides to click on the advertisement and/or access our website;
    • Facilitating data analysis and business planning purposes, marketing, advertising, and sales efforts.
  4. For purposes which are required by law, including:
    • In response to requests by government or law enforcement authorities conducting an investigation; and
    • Using personal information in connection with legal claims, compliance, regulatory and investigative purposes as necessary, including disclosure of such information in connection with legal process or litigation.
  5. For purposes described elsewhere in this Policy (for example in the section entitled “Use and Disclosure to Third Parties”); and
  6. For any other purpose as disclosed to you at the point of collection or pursuant to your consent.

We may also contact you by any means of communication for which EMERITUS has been given contact details, including but not limited to via email, telephone numbers, and post, for the purpose of getting your feedback or for providing you with information which we believe could be of interest to you or your organization.

By your submission of your personal data to us and our Emeritus Partners, you consent to the onward disclosure of your Personal Data to these service providers (as set out in “How we use your personal data”) and the processing of your Personal Data by these service providers.

By providing us and/or our Emeritus Partners with your Personal Data regardless of the manner in which you have provided such Personal Data, you represent and warrant to us that consent, including that of the third party, has been obtained for collection, use and disclosure of the Personal Data for the above-mentioned purposes. Because we are collecting the third party’s data from you, you undertake to make the third party aware of all matters listed in this Policy.

EMERITUS ensures that the Personal Data held by us shall be kept confidential. When transferring Personal Data to our third-party service providers and/or our affiliates or related corporations whether in Singapore or elsewhere in order to carry out one or more of the purposes listed above, we will require them to ensure that Personal Data disclosed to them is kept confidential and secure.

You consent to the collection, use and disclosure of your Personal Data for the above- mentioned purposes and agree to be bound by the obligations it imposes on you when you accept this Policy. You accept this Policy when you continue to browse on EMERITUS’ website or continue to engage with EMERITUS.

In this regard, please note that it is your responsibility and obligation to ensure that all Personal Data submitted to us and our Emeritus Partners is complete, accurate, true and correct at the time of submission. Failure on your part to do so may result in our inability to provide you with products and services you have requested.

Please note that if you do not consent to any of the above business purposes, EMERITUS may also be unable to meet the purposes for which the information was collected.

We engage other companies and individuals in addition to our Emeritus Partners to perform functions on our behalf (each, a “Third Party” and collective, the “Third Parties”). They will require access to the Personal Data needed to perform certain limited functions for EMERITUS; however, they may not use the Personal Data they receive generally. We will share Personal Data we collect with the following Third Parties or for the following purposes:

  1. With service providers or contractors that perform certain functions on our Site, including managing our learning management system, hosting our videos and course ware, processing information that is provided to us, processing purchases via third party providers, and other transactions through the Site, operating the Site or portions of it, providing or administering courses, or in connection with other aspects of EMERITUS services.
  2. With other visitors to the Site, course platform or our mobile learning app, to the extent that you submit comments, course work, or other information or content (collectively, “Postings”) to a portion of the Site, course platform or mobile learning app designed for public communications; and with other members of an EMERITUS class of which you are a member, to the extent you submit Postings to a portion of the Site, course platform or mobile learning app designed for viewing by those class members. We may provide your Postings to students who later enroll in the same classes as you, within the context of the forums, the courseware, or otherwise. If we do re-post your Postings originally made to non-public portions of the Site, course platform or mobile learning application or learning management system we will post them without your real name and e-mail (except with your express permission), but we may use your username without your consent.
  3. To provide opportunities for you to communicate with other users of the Site who may have similar interests or educational goals. For instance, we may recommend specific study groups or connect potential student and coaches. In such cases, we may use all information collected about you to determine who might be interested in communicating with you.
  4. To collaborate with a University on a course for which you are enrolled, in which event, the University may use your Personal Data in accordance with their own privacy policies.
  5. To third parties whose practices are not covered by this Policy (e.g., third party providers of goods and services, marketing and advertising companies and agencies, content publishers and retailers).
  6. To respond to subpoenas, court orders, or other legal process; to investigate, or prevent, or take action regarding illegal activities, suspected fraud, or security or technical issues, or to enforce our terms and conditions, or this Policy; as otherwise may be required by applicable law; or to protect our rights, property, or safety or those of others.
  7. For government, audit and other regulatory purposes, including but not limited to, EMERITUS re-certification and accreditation purposes.
  8. With the parent company or affiliates of EMERITUS or with successors in the event of a merger, acquisition or reorganization, for their use consistent with this Policy.
  9. With our accountants, bankers, auditors, investors, attorneys, and advisors in connection with providing business-related advice to us consistent with this Policy.
  10. As otherwise described to you at the point of collection of Personal Data or pursuant to your consent.
  11. For integration with Third Party services.

In addition, we may share aggregated information that does not personally identify you with the public and with third parties, including but not limited to researchers and business partners.

Please keep in mind that whenever you voluntarily disclose Personal Data online – for example on message boards, through e-mails, or in chat areas – that information can be collected and used by others. By posting Personal Data online that is publicly accessible, you may receive unsolicited messages from other parties in return.

The Site contains links to websites published by third parties, including other content providers as well as certain service providers, such as those who process payments on behalf of EMERITUS. Some of these third-party websites may have our logo or trademark acknowledged on their website. These other websites are not under our control, and you acknowledge and agree that we are not responsible for the collection and use of your information by such websites, unless we have otherwise indicated in this Policy. We encourage you to be aware when you are be redirected to a third-party website and review the privacy policies of each website you visit and use.

This Privacy Policy governs collection and use of Personal Data by Emeritus. This Privacy Policy does not apply to Third Parties or to third party websites and Emeritus makes no representation about their data practices or policies.

The Personal Data that we hold about you may be stored on servers hosted in Singapore, Japan, US, China, India and on several cloud servers used by our service providers and vendors. EMERITUS implements a variety of security measures to maintain the safety of your submitted information. All electronic storage and transmission of Personal Data is secured and stored on managed servers with controlled access and appropriate security technologies.

We have implemented appropriate technical and organizational security measures designed to protect your Personal Data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, unauthorized access, and other unlawful or unauthorized forms of processing, in accordance with applicable law. In certain instances, we may use Secure Sockets Layer encryption and/or transfer certain Personal Data in a non-human readable format to provide protection.

Although every reasonable effort has been made to ensure that all Personal Data will be so protected, EMERITUS cannot be responsible for any unauthorized use or misuse of such information and from risks which are inherent in all internet communications. We cannot guarantee there will not be a breach, and we are not responsible for any breach of security or for the actions of any third parties.

Your Personal Data will only be disclosed for the express purpose of delivering the product or service requested and shall not be sold or disclosed to any other company for any other reason whatsoever without your consent.

We take every reasonable step to ensure that Personal Data that we process is accurate and, where necessary, kept up to date, and any of your user information that we process that you inform us is inaccurate (having regard to the purposes for which they are processed) is erased or rectified.

Please contact us via privacy@emeritus.org should you wish to have access to or seek to update, correct or withdraw the consent to collect and use your Personal Data. Your email should identify yourself and state which Personal Data and information about its use and/or disclosure is requested.

We will retain Personal Data only for as long as is necessary for the purposes set out in this Policy. In addition, we will retain and use Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain certain data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies. You have full rights to stop processing and/or remove of your data by emailing us at privacy@emeritus.org (by stating “Retention of Data” as the subject matter of the enquiry in the subject matter line.)

You are also entitled to learn about the legal basis of data transfers to a country outside Singapore or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by us and our third-party applications to safeguard Personal Data.

If any such transfer takes place, you can find out more by checking the relevant sections of this document or enquire by writing to us at privacy@emeritus.org (by stating “Data Transfer” as the subject matter of the enquiry in the subject line).

EMERITUS will not transfer Personal Data within or outside Singapore unless it is ensured that the Personal Data will be accorded a level of protection which is comparable to the protection under the PDPA.

Your Newsletter and Email Subscriptions.
You can opt out or unsubscribe to a newsletter or other email list at any time by following the instructions at the end of the newsletters or emails you receive. Please allow five to ten business days for changes to take effect. For some services, member service-related communications are an integral part of such services to which you subscribe and you may continue to receive emails as part of that particular portion of the services unless you cancel your account, even if you opt out of the newsletters or email list. If you have provided more than one email address to us, you may continue to be contacted unless you request to unsubscribe each email address you have provided.

Telephone Communications.
Our telephone communications with you may be recorded in accordance with this Policy. By choosing to continue any telephone conversation, you acknowledge, agree and consent to the terms of this Policy and the recording of any telephone conversation with us. If you do not agree, terminate the telephone conversation immediately and avoid any further telephone

Cookies and Pixel Tags.
When you visit the Site or interact with e-mails that we send to you, we passively collect information from you, including your internet protocol address (“IP address”), browser type, operating system, device identifier, device model, software version, or mobile or ISP carrier information. We and our Third Party partners use cookies and other technologies to collect information about your visit to the Site, such as the date and time of your visit, the information you searched to find the Site, your activities on the Site, and your clicks on our ads. “Cookies” are small files which may be stored on your computer during your use of the Site and contain data about your use of the Site. We use session cookies (which exists only in temporary memory while you navigate the Site and delete when you close the browser.) and persistent cookies (which data file is capable of providing Sites with user preferences, settings and information for future visits) to understand more about your activity on the Site.

You may stop or restrict cookies and pixel tags on your computer or purge cookies from your browser by adjusting your web browser preferences. However, if you “turn off,” purge, or disable cookies or pixel tags, although you may still use the services, you may not be able to use all of the features, functions, or services available on the Site. We have also provided another measure of disabling the cookies, you will see a pop up on our website that can enable you to control the cookies tracking.

Our website uses Facebook Pixel service. This tool allows us to follow your activities on the Site after you are redirected to the Site by clicking on a Facebook advertisement. This will enable us to understand the efficacy of Facebook advertisements for analytical purposes, and in the process improve our advertising campaigns for a better users’ experience. We may use the analysis to retarget you with further advertising on Facebook and the use of Custom Audiences. Facebook website provides information about Custom Audiences and how to opt-out from being targeted.

You can find more information about our Cookies Policy here.

This Privacy Policy Addendum supplements the Privacy Policy at emeritus.org and describes additional rights of residents of the EU under the General Data Protection Regulation 2016/679 (the “GDPR”).

Capitalized terms not defined in this section shall be as defined in GDPR or in the Privacy Policy, as applicable.

GDPR provides certain rights for EU residents.

Storage and Retention of your Personal Data. We will only retain your Personal Data for as long as necessary to fulfil the purposes for which we collected such data, including for legal, accounting or reporting requirements. To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements. If you would like more information on this process, please do not hesitate to reach out to us at privacy@emeritus.org.

It is important that the Personal Data we hold about you is accurate and current. Please keep us informed if your Personal Data changes during your partnership with us.

In some circumstances we may anonymize your Personal Data so that it can no longer be associated with you, in which case we may use such information without further notice to you.

Your Rights as a Data Subject.

By law, in certain circumstances, you have the right to:

  • Request access to your Personal Data (commonly known as a “data subject access request”) to check that we are lawfully processing it.
  • Request correction of the Personal Data that we hold about you to ensure its accuracy and completeness.
  • Request erasure of your Personal Data where there is no good reason for us continuing to process it and ask for deletion or removal of your Personal Data where you have exercised your right to object to processing (see below).
  • Object to processing of your Personal Data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground.
  • Object where we are processing your Personal Data for direct marketing purposes.
  • Request the restriction of processing of your Personal Data.
  • Request the transfer of your Personal Data to another party.

If you want to review, verify, correct, or request erasure of your Personal Data, object to the processing of your Personal Data, or request that we transfer a copy of your Personal Data to another party, please contact us at privacy@emeritus.org.

What We May Need From You
We may ask for additional information to confirm your identity to ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it.

No Fee Usually Required
You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights) unless your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

Your Right to Withdraw Consent
In circumstances where you may have provided your consent to the collection, processing and transfer of your Personal Data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. You have the right to withdraw consent to marketing by following the opt-out links on any marketing message. To withdraw your consent for another circumstance, please contact us at privacy@emeritus.org. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

You may decline to share certain information with us, in which case we may not be able to provide some of the features and functionality of the Site or the Services. These rights include, in accordance with applicable law, the right to object to or request the restriction of processing of your information, and to request access to, rectification, erasure and portability of your own information. Where we process your information on the basis of your consent, you have the right to withdraw that consent (noting that such withdrawal does not affect the lawfulness of any processing performed prior to the date on which we receive notice of such withdrawal and does not prevent the processing of Personal Data in reliance upon any other available legal bases). Requests should be submitted by contacting us by writing to privacy@emeritus.org (and you must state “Privacy Policy” as the subject matter of the enquiry in the subject line).

While you have the right to make a complaint at any time to the EU Supervisory Authority for data protection issues (www.ico.org.uk), we would, however, welcome the opportunity to address discuss and resolve concerns before you reach out to the EU Supervisory Authority so please contact us in the first instance.

General Data Protection Regulation (GDPR)

Pursuant to Article 27 of Europe’s General Data Protection Regulation (GDPR), Emeritus Institute of Management Pte Ltd. has appointed European Data Protection Office (EDPO) as its GDPR representative in the EU. EU residents can contact EDPO regarding matters pertaining to the GDPR as follows:

By email: privacy@edpo.brussels,
By using EDPO’s online request form
By mail to EDPO: Avenue Huart Hamoir 71, 1030 Brussels, Belgium.

This Privacy Policy Addendum supplements the Privacy Policy at emeritus.org and describes additional rights of residents of the State of California under the California Consumer Privacy Act of 2018, as amended (the “CCPA”).

California residents are entitled once a year, free of charge, to request and obtain certain information regarding our disclosure, if any, of certain categories of Personal Information (as defined under CCPA) to third parties for their direct marketing purposes in the preceding calendar year.

Notice to California Residents

This section describes how we handle the Personal Information of California residents (as defined in Section 17014 of Title 18 of the California Code of Regulations), and the rights they have under the CCPA”) to the extent that (1) we collect and process such information in the context of providing services and selling goods (hereinafter, Customer Related Personal Information); and (2) the obligations imposed by the California Consumer Privacy Act of 2018 (“CCPA”) apply to such data. This section also notifies California residents of our collection practices regarding such Personal Information and describes your rights under the CCPA.

Capitalized terms not defined in this section shall be as defined in CCPA or in the Privacy Policy, as applicable.

Notice at Collection

We collect the following categories of Customer Related Personal Information from you:

  1. Identifiers: We collect identifiers such as real name, alias, postal address, unique personal identifiers, online identifier, Internet Protocol address (see “internet activity” below), email address, and account name.
  2. Internet /electronic network activity: When you browse our sites or otherwise interact with us online, we may collect browsing history, search history, and other information regarding your interaction with our sites, application or advertisements.
  3. Customer Records: We collect Personal Information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) such as name, signature, description, address, telephone number, bank account number, or other financial information. Some Personal Information included in this category may overlap with other categories.
  4. Characteristics of protected classifications under California or federal law: In some circumstances, we may collect information that is considered protected under California or federal law such as age but only when that information is relevant for our business purposes. We abide by the legal requirements imposed under applicable law regarding such information.
  5. Sensory data: In some circumstances, we collect audio information (e.g., records of calls made through our systems when call recording is activated), electronic and visual information (e.g. recordings from security cameras), or similar information.
  6. Geolocation data: If you interact with us online, we may gain access to the approximate location of the device or equipment you are using. If you visit our facilities, we may keep record of the fact that you visited, the location visited, and the day/time.
  7. Biometrical data: We do not independently collect biometric data such as DNA data, fingerprints, voice prints, retina scans, or face scans; however, we may collect data from which biometric data could be derived (such as voice recordings and pictures.)
  8. Commercial Information: We collect commercial information, such as records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
  9. Professional or employment related data: Because we collect and handle information related to our services, we may collect from you professional or employment information such as company name, designation, work experience, etc.
  10. Inferences: We may draw inferences from other information we collect about you. For example, if you use our services, we may create a client profile reflecting our understanding of your personal preferences.

We use the Customer Related Personal Information collected for operational purposes or other business purposes as described in this Privacy Policy. Examples of how we may use Customer Related Personal Information include:

  • For our internal efforts to operate and improve our business.
  • For advertising and marketing purposes relating to our services and programs, including marketing on social media sites.
  • For our general administrative purposes.
  • For social-media engagement.
  • For security purposes, as necessary to help us protect against, identify, or investigate fraud or other criminal activity.
  • For other legal purposes, if we have a legal obligation, or need to pursue or defend against legal claims, for which we need to process your information.
  • For communication purposes, to get in touch with you in connection with any of the reasons listed above.

We share Personal Information in the context of marketing and advertising in ways that may be considered selling under CCPA. You can opt-out out of the sharing as described in the California Rights section below. However, we do not authorize third parties to use your Personal Information for their own purposes unless you direct us to do so.

Collection and sharing practices in the last twelve (12) months

In the last twelve (12) months we have collected Customer Related Personal Information for all categories outlined in the Notice at Collection section above.

We collected such information from the sources described in our Privacy Notice. For example, we have collected Customer Related Personal Information:

  • Directly from our customers (for example, information provided through the Site or other communications with us).
  • From our business partners with whom you have consented to the sharing of your information.
  • From consumers’ activity on the Site (for example, Site visit information collected directly or through third-party analytics providers).
  • From a device’s GPS, Wi-Fi, Bluetooth, or IP address.
  • From consumers’ activities on social media.
  • From our interaction through social media.

We have shared Customer Related Personal Information for our operational purposes or other business purposes as described in our Privacy Notice. We also share Personal Information in the context of marketing and advertising in ways that may be considered selling or sharing under CCPA. The types of entities with which we have shared Customer Related Personal information include:

  • Service providers
  • Other members of our corporate group
  • Governmental entities (where we are under a duty to disclose or as required to protect our rights or the rights of others).
  • Business Partners and other third parties as necessary to provide services to our customers

Your rights under California law

If you are a California resident, you have the following rights under CCPA:

  • Right to know/access information: You have the right to request that we disclose to you: (1) the specific pieces of Personal Information we have collected about you over the past 12 months; (2) the categories of Personal Information collected or shared over the past 12 months; (3) the purposes for which we collected or shared such Personal Information; (4) the categories of third parties to whom we have disclosed such Personal Information.
  • Right to delete: You have the right to request in certain circumstances deletion of the Personal Information that we have received about you. As a general rule, we must delete the Personal Information at your request and require our vendors to do so as well. However, the law provides certain exceptions that allow us to retain the information even if you have requested that it be deleted. If we do not erase the information pursuant to one of those exceptions, we must inform you of that fact and of any rights you may have to appeal our decision.
  • Right to Opt Out of Sale of Personal Information to Third Parties. You have the right to opt out of any sale of your Personal Information by Emeritus to Third Parties. We do not sell information to third parties.
  • Right to Information Regarding Participation in Data Sharing for Financial Incentives. You have the right to be free from discrimination based on your exercise of your CCPA rights. We do not discriminate against anyone who chooses to exercise their CCPA rights.

California law also provides that California residents are entitled to know how we respond to “Do Not Track” settings. Like many other websites and online services, we do not currently alter our practices when we receive a “Do Not Track” signal.

How to exercise your Rights

You can make requests related to your California privacy rights by completing our Enquiry Form.

You may also make those requests by writing to us at privacy@emeritus.org

Please be aware that we do not accept or process requests through other means (e.g., via fax, chats, social media etc.).

When you make a request, we may ask you to provide verifying information, such as your name, email, or phone number. We will review the information provided and may request additional information via email or other means to ensure we are interacting with the correct individual. Please also be aware that making any such request does not ensure complete or comprehensive removal or deletion of personal information or content you may have posted, and there may be circumstances in which the law does not require or allow us to fulfill your request.

If we suspect fraudulent or malicious activity on or from the password-protected account, we may decline a request or request that you provide further verifying information.

You may only make a verifiable consumer request twice within a 12-month period. Making a verifiable consumer request does not require you to create an account with us.  We will only use Personal Information provided in a verifiable consumer request to verify your identity or authority to make the request.

Please note that we review and may make changes to this Policy from time to time. When changes are made, the Policy link will include a notation “Revised (date).” indicating that you should review the new terms, which will be effective immediately upon posting on this page, with an updated effective date. The notation will be included in this Policy link for at least seven (7) days after the update has been made. By accessing the Site after any changes have been made, you signify your agreement on a prospective basis to the modified Policy and any changes contained therein. In case you miss the notification referenced above, be sure to return to this page periodically to ensure familiarity with the most current version of this Policy.

Privacy Concerns

If you are concerned about the handling of your Personal Data, or if you have any complaints or queries related to your Personal Data or this Policy, please contact:

The Data Protection Officer

EMERITUS Institute of Management
78 Shenton Way,
#20-02 Singapore-079120

Email: privacy@emeritus.org.

Effective Date: 11 June 2021

View the last versions of our privacy policy here.

February 26, 2021
June 18, 2020
January 15, 2020
June 21, 2019