Peregrine Global Services adheres to the highest ethical standards in business practice and higher education. We treat all correspondence confidentially and do not sell or otherwise distribute client or participant information without the express written permission of the client or participant.
We are committed to respecting online privacy and recognize the need for appropriate protection and management of any personally identifiable information (“personal information”) shared with us. Personal information means anything that may be used to identify an individual, including but not limited to, a first and last name, a home or other physical address, and an email address or other contact information. A person can visit our web pages without telling us who they are or revealing any personal information about themselves.
If an individual chooses to provide us with personal information on the web in order to obtain materials or take an online test or course, we will only use that information for its intended purpose of processing the request and meeting those academic needs.
Peregrine Global Services takes reasonable and appropriate steps to protect personal information from unauthorized access or disclosure. If there are questions regarding personal privacy, contact us for more information.
Data Processing
Methods of Processing – Peregrine Global Services, as the data controller, processes user information securely following stringent procedures to prevent unauthorized access, modification, or destruction of data. Processing activities are carried out using IT-enabled tools and systems, with access limited to authorized personnel or external parties under contractual agreements.
Data Zone – All Peregrine data shall remain within the U.S. data zone and must comply with all applicable U.S. laws. If compliance with local data zone laws outside of the U.S. is required, data instances will be established in those zones.
Retention Time – Data is kept for at a minimum the time necessary to provide the service requested by the user.
Personal Information Collected
Personal information may be provided by the user or collected automatically during the use of Peregrine services. This includes system logs, cookies, and other tracking mechanisms used for operational, maintenance, and analytical purposes. Personal data will be classified and handled according to its sensitivity, with appropriate access controls applied.
Utilizing User Information
Peregrine Global Services utilizes user information, including personal information, for several key purposes:
Service Provision – To communicate with clients, respond to inquiries, fulfill orders, and provide services.
Marketing and Promotions – For example, Peregrine may use client information, such as an email address, to send news, special offers, and promotions, or to contact clients about products or information that may be of interest. All marketing efforts comply with the CAN-SPAM Act, ensuring that recipients have the ability to stop receiving communications from us.
Enhancement and Analysis – To understand how users access and use Peregrine sites and services, and to improve these services based on user preferences and aggregated data.
Sharing User Information
Peregrine Global Services may share user information, including personal data, only under specific circumstances:
- Aggregate and Anonymized Information – Peregrine may share non-personally identifiable information for marketing, research, or similar purposes.
- Educational Institutions and Sponsoring Organizations – User registration data, progress data, test results, and other relevant information may be shared with the institution or organization sponsoring the user’s course for administrative purposes.
- Affiliates and Subsidiaries – Peregrine Global Services may share user information with company affiliates or subsidiaries solely for service provision, ensuring compliance with this policy.
- Service Providers – Third-party vendors, service providers, contractors, or agents performing functions on Peregrine’s behalf may access user information under strict contractual agreements that ensure data protection.
- Business Transfers – In the event of a merger, acquisition, or asset transfer, user information may be transferred as part of the transaction.
- Legal Process – Peregrine Global Services may disclose user information to comply with legal requirements or court orders.
- Protection of Rights – Information may be disclosed to protect the safety of individuals,
investigate fraud, or enforce the terms of service.
User Rights Regarding Personal Information
Users have the right to access, modify, delete, or oppose the processing of their personal data. Requests for access or modification will be processed in a timely manner, and all such requests will be logged to ensure accountability. Users may also request that their personal information be anonymized or deleted if it is no longer required for service provision or legal compliance.
Children’s Online Privacy Protection Act (COPPA) Compliance
Peregrine adheres to COPPA regulations and does not knowingly collect personal information from individuals under the age of 13. If such information is inadvertently collected, it will be promptly deleted. The COPPA compliance process will be reviewed regularly to ensure that Peregrine continues to meet its obligations under the act.
Family Educational Rights and Privacy Act (FERPA) Compliance
Peregrine Global Services complies with the Family Educational Rights and Privacy Act (FERPA), processing student data solely on behalf of educational institutions. We only use the personally identifiable information (PII) necessary to perform contracted services, and all record changes must be authorized by the institution.
General Data Protection Regulation (GDPR) Compliance
Peregrine Global Services is dedicated to safeguarding the personal information of our subscribers residing in the European Union, in strict compliance with the General Data Protection Regulation (GDPR). Users of Peregrine systems can request the suspension or removal of their personal information in compliance with the General Data Protection Regulation (GDPR). The process is as follows:
- Documented Request: Users must submit a documented request for access, review, modification, or deletion of their personal data.
- Identity Verification: We confirm the identity of the data subject before granting access, ensuring that personal information is securely handled.
- Timely Response: All requests are addressed within three business days, in line with GDPR requirements.
- Communication of Decisions: Should a request be denied, users will be informed of the reasons, maintaining transparency and accountability
Additional Components of Data Privacy
Additional components of data security include the following:
- Academic Data Access: Only authorized account holders at a student’s institution can access that institution’s student data. Cross-institution, shared data is only in aggregate form and cannot be attributed to any specific school or individual student.
- Account Confidentiality: Student client accounts have unique credentials that must be entered each time a user logs on. Each student utilizes a unique registration code or access key to access Peregrine Global Services systems. All personal information is stored in an encrypted format. Peregrine Global Services does not store credit card data.
- Data Breach Response: In the event of a data breach, our policy mandates immediate notification of affected users. This includes sending individual email notices and posting a statement on our websites to ensure transparency and prompt communication.
Third-Party Links
Peregrine Global Services sites and services may contain links to third-party websites. Except as noted for Peregrine above, any access to and use of such linked websites is not governed by this policy but instead is governed by the privacy policies of those third-party websites. Peregrine Global Services is not responsible for the information practices of such third-party websites.
Notice of Consent Required
When using Peregrine Global Services that require personal information for login purposes, clients must provide their consent by checking an acknowledgment box. This box confirms their understanding of our privacy practices as outlined in this policy. Prior to obtaining consent, Peregrine will provide clients with an electronic version of the key elements of this policy to ensure they are fully informed.
Changes to Data Privacy Policy
Peregrine Global Services reserves the right to amend this privacy policy at any time. Changes must be announced on our website so users may be informed of our privacy practices. Users who do not agree with any changes must discontinue using our services. In such cases, users may also request the removal of their personal information. Unless specified otherwise, the most recent privacy policy applies to all personal information held by Peregrine Global Services.
Contact Us
If you have questions about the privacy aspects of our services or would like to make a complaint, please contact Peregrine Global Services at info@peregrineglobal.com.
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This document was last modified January 1, 2025.
