Our Privacy Policy

Privacy Notice

The Milken Center for Advancing the American Dream (“MCAAD,” “we,” “us,” or “our”), a wholly-owned subsidiary of the Milken Institute, respects and is committed to protecting your privacy. This Privacy Notice is intended to inform you of our privacy policy and practices and applies to all personal information that we collect, process, or share when you use the sites and services owned, hosted, or operated by MCAAD, both online and offline, on any platform, including MCAAD.org, TheAmericanDreamAcademy.org, and any other site that we have owned or operated, do own and operate, or may own and operate in the future (collectively, the “Sites and Services”).

This Privacy Notice explains the types of personal information we collect, how we may use and share that information, and the privacy choices that you have with respect to our handling of your personal information.

Information We Collect

For purposes of this Privacy Notice, “personal information” means any information from or about a person that either identifies that person directly or makes that person identifiable when that information is combined with other information from or about that person from any source. Personal information does not include data that has been aggregated or de-identified such that a person can no longer be identified using means reasonably available to us.

We may collect the following categories of personal information:

Contact Information, such as your name, mailing or postal address, phone number, or e-mail address when you register for events or sign up to receive regular news and information from us.

Account/Registration Information, such as your username and password, date of birth, and any other registration information when you sign up for an MCAAD account, as well as information about your enrollment, participation, progress, and completion status with respect to courses or other engagements that we offer.

Demographic information, such as gender and age range.

Location Information, including general location information derived from your IP address (when you visit our website(s)).

Payment Information, such as your debit or credit card details (cardholder name, card number, expiration date, and other information necessary to process payment) or other forms of payment to fulfill orders or to make donations.

Online Identifiers, such as your IP address, unique device ID, and other information about your device.

Internet Activity Information, such as your IP address, user agent string (i.e., operating system and browser type/version), and the pages you clicked on while on our website, unique URLs visited within our website, and details regarding your activity on the website such as time spent on the website and other performance and usage data.

Inferences, which we may have derived or drawn based on the other personal information we collect about you. For example, based on the services you receive through our website, we may infer your interests or how you rank with regard to certain attributes as compared to others in your group. 

Other Information You May Choose to Provide, including any content you submit or make available when you make information requests or use our products and services, including during any workshops that we host.

We also collect employment-related information if you apply to work with us. When you apply for a job, we collect information you submit as part of your application and resume, which may include your work experience and previous employment, your education, and/or salary expectations. We collect payroll, benefits, and financial information (such as your bank account details, payroll records, tax information) from employees.

Where/How Do We Collect Personal Information?

We collect personal information about you from the following sources:

You. We receive information directly from individuals who register with MCAAD to gain access to our products and services, e.g., those who may enroll in an online course or who correspond with us in person or online.

Service Providers. We work with service providers who collect information on our behalf in order to provide services to us. We only allow our service providers to use your personal information in connection with the services they provide to us.

Data Partners. We work with data partners, such as analytics providers and other third parties, who provide us with insights and information about consumer behaviors, which we use to evaluate and improve our products, services, marketing and customer experience. We may also receive email addresses from third parties to allow us to offer courses and workshops more broadly.

Cookies & Other Technologies on our website.

What are Cookies & Other Technologies?

A “cookie” is a small data file transferred by a website to your computer’s hard drive. We send cookies when you surf our site, make purchases, request information, or register yourself for certain events and programs. Accepting the cookies used on our site does not give us access to information that directly identifies you, such as your name, address, or social security number, but we may use the cookies to identify your computer. For example, although you may not log in when you visit our website, we can use cookies to recognize that you have visited our website in the past. We use this information to analyze our website traffic and make decisions about the information presented on our website.

Web Beacons, Pixel Tags and Other Tracking Technologies. Web beacons, pixel tags, and other “tracking technologies” are small strings of code placed on a web page or in an email or advertisement. These technologies allow your browser to recognize and store certain types of information such as cookies previously set, and the time and date that you viewed the page with the beacon and a description of that page.

Can You Opt Out? Visit our section below entitled “Opting Out of Cookies and Other Technologies” for more information on how to opt-out from tracking technologies.

How We Use Your Information

We collect, use, share, and/or disclose your personal information for the following purposes: to establish and maintain contractual relationships; to comply with our legal obligations; to provide services and information that you request and consent to receive, and to fulfill our other legitimate interests as described in this Privacy Notice.

Specifically, MCAAD uses your information:

To help us understand your needs and interests and provide you with an improved user experience.

To help you complete a transaction or order related to MCAAD charitable contributions, publications, events, or content;

To communicate with you;

To provide service and support;

To update you on publications and programs (sometimes co-hosted with partner or third-party organizations);

To monitor, audit and analyze trends, usage, and activities in connection with the MCAAD website; to conduct internal research and development; and

To personalize your user experience. Credit card information is used only for payment processing and fraud prevention and is not used for other purposes;

To comply with any legal obligations and enforce our legal rights. For example, we may use personal information to exercise contractual rights, or to comply with financial reporting obligations, court orders, warrants, or subpoenas in accordance with applicable law.

Data collected online may also be combined with information you provide through other sources, such as conferences or personal contacts with members of MCAAD or its affiliates. We may also use personal information as otherwise disclosed or permitted by law, or as we may notify you from time to time.

We use aggregate and de-identified information to improve the customer experience, usability, and site content.

Sharing and Disclosure of Your Information 

In addition, we disclose personal information as we believe to be necessary or appropriate with the following categories of third parties:

Affiliates.  We may share your personal information with affiliates, subject to the terms of this Privacy Notice or otherwise as we disclose to you at the time your information is collected.

Service providers.  We may share each category of personal information with companies and individuals that provide services on our behalf or help us operate our website or our business (such as order fulfillment, shipping, payment processing, customer support, hosting, analytics, email delivery, marketing, database management services, returns processing, and risk and fraud mitigation). 

Advertising and Marketing Partners.  We may share the above categories of personal information with companies that help us with our marketing efforts, including third-party advertising partners and social media platforms.

Other Partners. Where applicable, for those taking courses offered by or through us, we may share personal information, including information about your course enrollment and completion status, with higher education institutions and other partner organizations to support you at the community level (e.g., to verify eligibility for college course credit transfer, or to connect you to local job opportunities). We may also share de-identified or aggregate information with these partners for purposes of understanding learner outcomes.

Law enforcement, government authorities, and private parties. We may share the above categories of personal information as we believe in good faith to be necessary or appropriate to comply with law or for the compliance, fraud prevention, and safety purposes described above.

Organizations in connection with a business transfer.  We will share your personal information if we are acquired by or enter into a merger with another company, or otherwise reorganize our business.

Your Choices

You have certain choices about how we use your personal information.

Marketing Communications. If you would like to unsubscribe to our newsletters or other correspondence, please use the link provided at the bottom of each of your electronic correspondence to manage your e-mail relationship.

Opting Out of Cookies and Other Technologies. We use the following types of cookies:

Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website. This category of cookies cannot be disabled.

Analytical cookies. These cookies allow us to recognize and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily. Information collected by Google Analytics cookies will be transmitted to and stored by Google on servers in the United States of America in accordance with its privacy practices. To see and overview of privacy at Google and how this applies to Google Analytics, visit https://www.google.com/intl/en/policies/privacy/. You may opt out of tracking by Google Analytics by visiting https://tools.google.com/dlpage/gaoptout.

Advertising or targeting cookies. When present, these cookies are used to make advertising more relevant to you and your interests. They perform functions such as preventing the same ad from continuously reappearing, ensuring that ads are properly displayed, and in some cases selecting advertisements that are based on your interests. To the extent we have them, our third-party advertising partners may use the cookies to build a profile of your interests and deliver relevant advertising on other websites.

You can opt-out of tracking on our website or others for online behavioral advertising by visiting the DAA’s Consumer Choice page at http://www.aboutads.info/choices/ and the NAI’s Opt Out page at https://optout.networkadvertising.org

You may also disable cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to disable all cookies (including strictly necessary cookies) you may not be able to access all or parts of the website.

Disabling a cookie or category of cookie does not delete the cookie from your browser. You will need to do this separately within your browser. If you have disabled one or more analytical cookies, we may still use information collected from cookies prior to your disabled preference being set.

How We Respond to “Do Not Track” Signals. Please also note that at this time our website does not recognize automated browser signals regarding tracking mechanisms, which may include “Do Not Track” instructions.

Data Rights and Choices

MCAAD strives to keep your personal information updated and in keeping with your preferences. In relation to your personal information, you have certain rights, where provided under applicable law (each of which is subject to various exceptions and limitations).  A summary of these rights and how they can be exercised is set forth below.  If you would like to exercise any of these rights, please send your request to [email protected].

Right to access and/or correct your personal information and data portability: You have the right to access the personal information that we have about you.  You also have the right to request a copy of the information, in most circumstances.  You also have the right to request correction of any personal information that may be incorrect.

Right to restrict use of your personal information: You have the right to request that we delete your personal information. Please note that in certain circumstances there may be legal or compliance reasons that will prevent us from removing all of your data.

Right to object to processing your personal information: You have the right to request that we cease processing, or using, your personal information. 

Right to lodge a complaint with a supervisory authority: You have the right to complain to the data protection authority in the country in which you reside or work if you believe an infringement of data protection laws has taken place.

We may deny certain requests, or fulfill a request only in part, based on our legal rights and obligations. For example, we may retain personal information as permitted by law, such as for tax or other record keeping purposes, to maintain an active account, and to process transactions and facilitate customer requests. Employment-related information will not be included in fulfillment of your requests.

Your California Privacy Rights.  California Civil Code Section 1798.83 permits Users who are California residents to request certain information, once a year, regarding disclosure of personal information to third parties for their direct marketing purposes. However, we do not share personal information with third parties for their direct marketing purposes.

To protect your privacy and security, we will take reasonable steps to verify your identity before fulfilling your request. 

Location of Your Data

Since MCAAD is based in the United States, your personal information will be collected and processed in the United States regardless of where you are located.  The laws of the United States and other countries governing data protection may not be as comprehensive or as protective as the laws in the country where you live.  

Security

The security of your personal information is important to us.  Please be aware that despite our best efforts, no data security measures can guarantee 100% security. While we strive to protect information transmitted on or through our website, we cannot and do not guarantee the security of any information you transmit on or through this website.  

No website or electronic data can ever be completely secure, but we are always working to maintain up-to-date and appropriate security mechanisms.

Links to Other Websites

If you click on a link to a third-party site, you will be taken to a website we do not control. This Policy does not apply to the privacy practices of that website, which may collect information from you. Read the privacy policy of other websites carefully. We are not responsible for these third-party websites or their policies.

 Children’s Privacy

MCAAD does not knowingly collect information from children under the age of 13 and our products and services do not target information to children under 13.   We reserve the right to delete any information identified as having been provided by such persons at our discretion.

Contacting Us

We value your comments and opinions. If you have comments or questions about our privacy policy, contact us by email at [email protected].

Conditions of Use, Notices, and Revisions

We work in an evolving environment in which change is inevitable. This Privacy Notice will also change, and use of information that we gather now is subject to the Privacy Notice in effect at the time of use. We may e-mail periodic reminders of our notices and conditions, unless you have instructed us not to, and you should check our website frequently to see recent changes. This Privacy Notice was last updated as of the date shown above.