Terms of Use

PLEASE READ THESE TERMS OF USE CAREFULLY BEFORE ACCESSING THESE STUDER EDUCATION-HOSTED SUBSCRIPTION SERVICES. BY USING, ACCESSING, OR VIEWING THE SUBSCRIPTION SERVICES, WHETHER AS AN INDIVIDUAL SUBSCRIBER OR AN AUTHORIZED USER OF AN ORGANIZATIONAL SUBSCRIBER, YOU ACCEPT AND AGREE TO BE BOUND BY THE FOLLOWING TERMS AND CONDITIONS (“TERMS OF USE”). IF YOU DO NOT AGREE TO THESE TERMS OF USE, DO NOT CONTINUE YOUR USE OF THE SUBSCRIPTION SERVICES.

STUDER EDUCATION

SUBSCRIPTION SERVICES

Terms of Use

These Terms of Use, together with Client’s subscription order, govern your access to and use of the applicable online-hosted subscription offering, such as the 9P Online Learning Platform or the Nine Principles^TM Academy, which is reflected on your subscription order and owned and provided by Huron Consulting Services LLC d/b/a Studer Education, as successor-in-interest to The Studer Group, L.L.C. (“Studer Education,” “we” or “our”), and comprise the complete understanding of the parties on the subject matter (the “Agreement”). For purposes of this Agreement, “subscription order” will refer to: (i) for individual subscribers, if applicable, Client’s completed online registration submission, and (ii) for organizational subscribers, the fully executed letter of engagement or other services agreement between the Client and Studer Education that includes access to the Subscription Services (as defined below) (the “Engagement Letter”). In the event of any direct conflict between the Engagement Letter and these Terms of Use with respect to the Subscription Services, then the Engagement Letter shall control.

Subscription Services. Client, and with respect to organizational subscribers only, its Authorized Users, may access, view, and use the hosted offering outlined in Client’s subscription order (the “Subscription Services”), subject to the terms of this Agreement. Subject to Client’s timely payment of the Access Fee, Studer Education hereby grants Client a non-exclusive, non-transferable, right and license to access and use the Subscription Services throughout the subscription access period outlined in the subscription order and each agreed-upon renewal thereof (each, a “License Term”) for your personal educational use and with respect to organizational subscribers only, for the internal business purpose of educating and training Client’s Authorized Users.

Client will pay all fees for the Subscription Services in accordance with Client’s subscription order (the “Access Fee”). For individual subscriptions, which require regular payment by credit card, Studer Education will charge Client’s designated credit card upon receipt of the credit card information for the initial subscription order and each subsequent Access Fee due thereafter under the terms of this Agreement. As a general matter, the Access Fee is only refundable and subscriptions are only cancelable pursuant to the terms outlined in Paragraph 3 of these Terms of Use, unless otherwise provided in the Engagement Letter.

License Term; Termination. For individual subscribers, Client’s initial License Term will automatically renew for successive subscription periods equivalent in length to the initial License Term, based on Studer Education’s then-applicable rates; provided, that at any time either party may terminate the subscription order and any subsequent renewals hereunder by providing the other party with written notice its desire to terminate this Agreement, in which event the termination will be deemed effective as of the first day of the next month and any prepaid amounts attributable to Client’s access to the Subscription Services following the effective date of termination will be refunded by Studer Education within a reasonable period following termination. For organizational subscribers, the applicable License Term and corresponding termination rights will be governed by the terms of Client’s Engagement Letter.

Upon termination of the License Term under this Paragraph 3, (a) Studer Education will have no further obligation to provide Client with access to the Subscription Services; and (b) Client and if applicable, its Authorized Users will immediately cease use of the Subscription Services; provided, however, that you may retain copies of and continue to use any Downloadable Content in accordance with the Use Restrictions set forth in Paragraph 6 of these Terms of Use, which survive termination of the License Term and continue to apply for so long as such Downloadable Content is retained.

Client will also pay, or reimburse Studer Education for, all applicable sales, use, excise, value added, services, consumption and other taxes and duties associated with your use and receipt of the Subscription Services, excluding taxes on Studer Education’s income generally. Client will provide Studer Education with a copy of Client’s certificate of tax exemption, if applicable. If Client is required by the laws of any foreign tax jurisdiction to withhold income or profits taxes from the Access Fee, then the amount payable by Client upon which the withholding is based shall be paid to Studer Education net of such withholding. Client shall pay any such withholding to the applicable tax authority. However, if after 120 days of the withholding, Client does not provide us with official tax certificates documenting remittance of the taxes, Client shall pay to Studer Education an amount equal to such withholding. The tax certificates shall be in a form sufficient to document qualification of the taxes for the foreign tax credit allowable against our corporation income tax.

Equipment and Technical Support. The Subscription Services are hosted online, and Client will be responsible for obtaining any equipment and Internet access needed for Client and its Authorized Users, if any, to use the included services. Studer Education will provide commercially reasonable maintenance and technical support for the Subscription Services during normal business hours.

Use Restrictions.Client and if applicable, its Authorized Users will not: (a) access or use the Subscription Services, particularly including the hosted offering and all content available on, comprising, or incorporated within the Subscription Services (the “Content”), in order to design, create or build a service or product that is competitive with the Subscription Services, or which uses ideas, features or functions that are similar to the Subscription Services; (b) license, sublicense, sell, resell, resyndicate, transfer, assign, distribute or otherwise commercially exploit, make available to, or share the Subscription Services or included Content with any third party, who is not the Client or a permitted Authorized User under these Terms of Use; or (c) modify or make derivative works based upon the Subscription Services, or directly or indirectly disassemble, decompile, reverse engineer, or otherwise work around the technical limitations in the Subscription Services or any portion thereof. For avoidance of doubt, the parties agree that unless any Content is specifically marked within the Subscription Services as available for downloading and printing (“Downloadable Content”), Client and any permitted Authorized Users, as applicable, will not attempt to download, record, reproduce, or otherwise access such Content outside of the Subscription Services.

Client will be responsible for controlling the access and use of the Subscription Services in accordance with these Terms of Use and with respect to organizational subscribers, for notifying Client’s Authorized Users of the rights and restrictions set forth in these Terms of Use. Anyone authorized to access the Subscription Services under these Terms of Use will be required to create an account with a unique username and password and to login into that account each time he or she wishes to access the Subscription Services. Such user account information should be treated as confidential. Client will immediately notify Studer Education if any unauthorized use is discovered.

Client acknowledges that any unauthorized use or disclosure of the Subscription Services and included Content would cause Studer Education irreparable harm, and therefore, in addition to any other remedy available in law, Studer Education would be entitled to immediate injunctive relief, without showing any actual damages sustained, to prevent such disclosure or unauthorized use. Studer Education will have no obligation to post a bond or other security in connection with obtaining an injunction, specific performance, or other relief.

Intellectual Property. The Subscription Services, including without limitation the hosted offering, Content, Studer Education Data, and any modifications, configurations, enhancements, or derivative works to any of the foregoing (including all intellectual property rights in or to any of the foregoing), are and shall remain the exclusive property of Studer Education and its licensors. No licenses or rights are granted to Client except for the limited rights expressly granted in these Terms of Use.

All Content is protected by United States and international laws regarding copyrights, trademarks, trade secrets and other proprietary rights. Client and its Authorized Users will not remove any notices or legends that appear in the Subscription Services, or any Content, that either serve to identify Studer Education or its licensors as the owner, or that provide notice of the confidential and/or proprietary nature of such materials, and/or their contents, including without limitation copyright notices, trademark symbols and notices, and notices that such materials are “confidential” or “proprietary.” The obligation of Client and its Authorized Users not to remove such notices shall apply in all circumstances, including without limitation when Client copies or distributes materials as permitted by these Terms of Use. Studer Education may, in its sole discretion, change, limit, or discontinue any particular Content that is part of the Subscription Services.

User Contributions. The Subscription Services contains message boards, forums, networking opportunities, and other community-focused features which allow users to post, publish, or share messages and specific Content with other users of the Subscription Services. For purposes of this Paragraph 8, “User Contributions” means any messages or other content shared by Client or any Authorized Users other than Studer Education’s proprietary Content. Client is fully responsible for any User Contributions that Client or if applicable, its Authorized Users may share through the Subscription Services or otherwise send to other Subscription Services users, including the legality, reliability, accuracy and appropriateness of such User Contributions.

Based on the design of the Subscription Services, Client and any Authorized Users may share messages and internally circulate Studer Education’s Content using the included community-focused features but may not share or provide access to any external content or materials. Client and its Authorized Users, if any, shall not post, submit, or link to any User Contributions that infringe, misappropriate, or violate the rights of any third party or any applicable law, or that is defamatory, obscene, indecent, harassing, threatening, abusive, inflammatory, or fraudulent, purposely false or misleading, or otherwise harmful.

Studer Education does not approve, control, or endorse Client’s or anyone else’s User Contributions, and has no obligation to do so. However, Studer Education reserves the right (but assumes no obligation) to remove or modify User Contributions for any reason or no reason, at Studer Education’s sole discretion, including User Contributions that, in Studer Education’s sole discretion, violates these Terms of Use.

In using the Subscription Services, Client and its Authorized Users will be subject to Studer Education’s Privacy Policy, located at: www.huronconsultinggroup.com/legal/privacy-policy, as well as the Huron Virtual Events Privacy Terms, located at: https://www.huronconsultinggroup.com/legal/virtual-events.

Suspension of Services. Studer Education may suspend your access to the Subscription Services at any time (a) in order to prevent damage to, or degradation of, our network integrity; (b) if you fail to pay any amounts that are more than thirty (30) days past due and such failure continues without a cure for ten (10) days after notice from us; or (c) you breach these Terms of Use. If suspended and the License Term has not been terminated, Studer Education may restore use of the Subscription Services to the Client after the event giving rise to the suspension has been resolved to our reasonable satisfaction. Any accounts that are restored after suspension due to your failure to pay or other breach of these Terms of Use may be subject to any then-current reactivation fees. This Paragraph 10 does not limit any of our other rights or remedies, whether at law, in equity or under this Agreement.

Disclaimer of Warranties.THE SUBSCRIPTION SERVICES AND INCLUDED CONTENT ARE PROVIDED “AS IS” WITHOUT WARRANTY OF ANY KIND. STUDER EDUCATION EXPRESSLY DISCLAIMS (TO THE GREATEST EXTENT PERMISSIBLE UNDER APPLICABLE LAW) ALL WARRANTIES, EXPRESS, IMPLIED, STATUTORY, OR OTHERWISE, RELATING TO THE SUBJECT MATTER OF THESE TERMS OF USE, INCLUDING BUT NOT LIMITED TO ANY WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, TITLE AND NON-INFRINGEMENT AND WARRANTIES ARISING FROM COURSE OF DEALING OR USAGE OF TRADE. STUDER EDUCATION DOES NOT WARRANT THAT THE OPERATION OF THE SUBSCRIPTION SERVICES WILL BE COMPLETELY SECURE, ERROR-FREE OR UNINTERRUPTED, OR THAT ALL ERRORS WILL BE CORRECTED.

Limited Liability. CLIENT’S SOLE AND EXCLUSIVE REMEDY FOR ANY AND ALL CLAIMS, INCLUDING STUDER EDUCATION’S BREACH OF THESE TERMS OF USE, IS TERMINATION OF THIS AGREEMENT AND REFUND OF ANY PREPAID AMOUNTS ATTRIBUTABLE TO YOUR ACCESS TO THE SUBSCRIPTION SERVICES FOLLOWING THE EFFECTIVE DATE OF TERMINATION. In no event shall we be liable for any damages caused by your inability to access to the SUBSCRIPTION SERVICES as a result of network or server downtime, transmission problems or otherwise. STUDER EDUCATION SHALL NOT BE LIABLE FOR ANY PUNITIVE OR EXEMPLARY DAMAGES OR LOSS, NOR ANY LOST PROFITS, SAVINGS OR BUSINESS OPPORTUNITY, SPECIAL, CONSEQUENTIAL, INCIDENTAL, OR INDIRECT DAMAGES, EVEN IF NOTIFIED OF THE POSSIBLITY OF SUCH DAMAGES.

Governing Law, Arbitration. These Terms of Use shall be governed by and construed in accordance with the laws of the State of Illinois without giving effect to conflict of law rules. Any controversy or claim arising out of or relating to these Terms of Use or any breach thereof will be settled by binding arbitration administered by the American Arbitration Association in accordance with its Commercial Arbitration Rules. Any arbitration will be conducted in Chicago, Illinois. Any arbitration award may be entered in and enforced by any court having jurisdiction thereof, and each party consents and commits itself to the jurisdiction of the courts of the State of Illinois for purposes of enforcement of any arbitration award. Except as may be required by law, neither party nor an arbitrator may disclose the existence, content, or results of any arbitration hereunder without the prior written consent of both parties. The United Nations Convention on Contracts for the International Sale of Goods does not apply to these Terms of Use.

Force Majeure. Neither party shall be liable hereunder by reason of any failure or delay in the performance of its obligations hereunder (except for payment obligations) on account of strikes, shortages, riots, insurrection, fires, flood, storm, explosions, acts of God, war, terrorism, governmental action, labor conditions, earthquakes, material shortages, outages of electrical or Internet services, or any other cause that is beyond the reasonable control of such party (“Force Majeure Event”). Upon the occurrence of a Force Majeure Event, the non-performing party shall promptly notify the other party of occurrence of that Force Majeure Event, its effect on performance, and how long that party expects it to last. During a Force Majeure Event, the nonperforming party will use reasonable efforts to limit damages to the performing party and to resume its performance under these Terms of Use.

Studer Education shall have the right to assign these Terms of Use to any successor to its business or assets to which these Terms of Use relate, whether by merger, sale of assets, sale of stock, reorganization or otherwise. Client may not assign its rights or responsibilities under these Terms of Use in whole or in part without the prior written consent of Studer Education, and any purported assignment in violation of this provision shall be null and void. Subject to the foregoing limitation, these Terms of Use shall be binding upon and inure to the benefit of the parties hereto, their respective heirs, personal representatives, successors, and assigns.

If any provision of these Terms of Use shall be held by a court of competent jurisdiction to be illegal, invalid, or unenforceable, the remaining provisions shall remain in full force and effect.

All notices or demands required hereunder shall be in writing and shall be delivered personally or sent by certified or registered mail, return receipt requested, or by overnight express service, to the appropriate party at the address stated in the Client’s submitted subscription order, his or her successor, or other designee or officer of the party with a copy to Studer Education at: Legal Department, Huron Consulting Group Inc., 550 West Van Buren Street, Chicago, IL 60607.

No waiver of any breach of any provision of these Terms of Use shall constitute a waiver of any prior, concurrent or subsequent breach of the same or any other provisions hereof, and no waiver shall be effective unless made in writing and signed by an authorized representative of the waiving party.

No Relationship. Nothing in these Terms of Use creates any special relationship between the parties, such as a partnership, joint venture, agency, franchise, advisory, fiduciary, professional or employee/employer relationship. Neither the Subscription Services nor any Content on or accessed through the Subscription Services shall be considered a substitute for your independent investigation and sound technical and business judgment and you should consult with a professional advisor familiar with your particular factual situation for advice or service concerning specific matters.

Entire Agreement. These Terms of Use, together with the Client’s subscription order, the above-referenced privacy terms, and any other linked website terms of use, constitute the entire understanding between the parties and is intended as the complete and exclusive statement of the agreement between the parties with respect to the Subscription Services provided hereunder, superseding all prior agreements and negotiations between the parties and/or affiliates of Studer Education relating to the Subscription Services contemplated hereunder. In no event shall any purchase order, acknowledgment form or similar document issued by either Party serve to modify, supplement, or supersede, directly or indirectly, any provision of these Terms of Use, even if accepted or countersigned by the other Party for administrative convenience only.

Changes to Terms of Use. Studer Education reserves the right to change the terms of these Terms of Use at any time by notifying Client of the change in writing or electronically, including without limitation, by e-mail or posting a notice on the Subscription Services that the terms have been “updated” or a similar message. The changes will also appear in this document, which Client can access at any time by going to the Terms of Use link available via the Subscription Services. By continuing to use the Subscription Services after changes are made, Client and its Authorized Users signify their agreement to the updated Terms of Use.

***END OF TERMS OF USE***

Additional Information for Residents of California

This supplemental section of Huron’s Privacy Statement is directed at and applies to a limited subset of individuals who interact with Huron, who are verifiable residents of the state of California, and who are not otherwise exempted from the California Consumer Privacy Act (CCPA). Huron is largely not subject to the requirements of the CCPA given the nature of our business (i.e., primarily business-to-business transactions as described below).

Your California Consumer Privacy Rights

If you are a resident of California, who is neither (a) an employee, owner, director, officer, or contractor of an organization (i.e., company, sole proprietorship, non-profit, or government agency) whose communications or transactions with us occur solely within the context of us conducting due diligence regarding, or providing or receiving a product or service to or from your organization), or (b) a job applicant, you have the following specific additional privacy rights under the law:

Right to request access to personal information. California residents have the right to request that we disclose to them the categories and specific pieces of personal information we have collected about them. Upon submission and our receipt of a verifiable consumer request, and not more than twice in a 12-month period, we are required to provide such information directly to California consumers (if it is not already provided here or in another notice).
Right to request deletion of personal information. California residents have the right to request that we delete any personal information about them which we collected from them. Our obligation to delete personal information is limited by the law, and we are not required or able to comply with requests in all instances; for example, if it is necessary for us to maintain personal information in order to complete a transaction with the consumer, detect or protect against security incidents or other illegal or deceptive activity, exercise our free speech or other rights provided by law or protect the lawful rights of another consumer, comply with other legal obligations, or enable internal uses of the personal information in a lawful manner compatible with the context in which the consumer provided the information or would expect it to be used based on their relationship with us. For the full list of exceptions, see Cal. Civ. Code § 1798.105.
Right to request disclosure of what personal information we process, the source of it, the business or commercial purpose for processing it, and with whom (e.g., service providers) we share it. California residents have a right to request that we disclose to them (if we have not already in this or another notice): the categories of personal information collected about them, the categories of sources from which it was collected, the business or commercial purpose for collecting it, the categories of third parties (e.g., service providers) with whom we share it, and the specific pieces of personal information collected about them. A large portion of that information is provided here in this Privacy Statement, and we may direct you back here to make note of that information. It should also be noted that the disclosure right related to specific pieces of personal information is not absolute, and it is our responsibility to protect that sort of information from unauthorized Please refer to the sections below on How to Submit and What to Expect for more information about the process.
Right to know that we do not “sell” personal information. We have not sold (neither under the ordinary meaning of the term “sale,” nor under the CCPA’s definition of “sale”) consumers’ personal information in the preceding 12 months.

How to Submit a Request to Exercise your CCPA Rights

If you are a consumer and resident of California who is not a job applicant or individual involved in business-to-business communications and transactions with Huron (as described in the Your California Consumer Privacy Rights section above), and you wish to exercise one of your CCPA rights, please send an email to privacy@huronconsultinggroup.com and include your name, your specific request, and a preferred contact method (e.g., email or mail) for us to follow up with you.

You may call 1-866-229-8700 (toll-free) and ask to be connected with Christopher Hoff, Huron’s Chief Privacy Officer. Ultimately though, we will instruct and require you to submit your request in writing, for us to keep appropriate records, and because the law requires us to respond to you in writing. Please start by contacting us at privacy@huronconsultinggroup.com to expedite the process.

Please see the section below for what to expect once you contact us.

What to Expect When you Submit a Request to Us

We are a professional services firm, dealing almost exclusively with other companies, as opposed to directly with consumers as that term is usually understood, in business-to-business transactions; and the protection of our clients’ information (past, present, and future) is paramount to our corporate values and our privacy program.

We take data security, in addition to privacy, very seriously, and California law is clear on the need for businesses to protect all consumers from fraudulent requests made by someone other than the actual individual.

We mention this to prepare you for the fact that if you request from us specific pieces of personal information collected about you, we will do whatever is reasonably necessary (as the law allows and requires) to verify that you are who you say you are; and as such, you should expect a thorough and personalized vetting process from us to ensure that we do not provide one individual’s personal information to an imposter. The process may take 45 days (or longer when reasonably necessary) depending on the request, and consistent with our obligations under the law.

Personal Information We Collect About Consumers

We have collected the below categories of personal information about consumers in the past 12 months.

In the table below, we have used the CCPA categories of Personal Information and provided basic explanations in plain English for each of those categories. Our responses are divided below into the three broad categories of individuals (or “consumers”) with whom we work every day, and to whom this Privacy Statement applies: (1) leads (a/k/a potential clients/customers), (2) clients/customers, and (3) job applicants.

Not everything below will apply to you, because we have different relationships with different individuals. Our Privacy Statement should be read and understood in the reasonable context of your particular relationship with Huron.

CCPA Categories of Personal Information	Does Huron Collect that for Leads?	Does Huron Collect that for Clients/Customers?	Does Huron Collect that for Job Applicants?
A. Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.	Yes. We collect identifying information about leads who interact with us online, for example, (a) online or IP identifiers or email addresses for potential clients and customers who interact with us online, and (b) names and addresses for organization contacts at potential client organizations.	Yes. We know the identities of our clients and customers and maintain interest and transactional records that would be expected of a professional services firm with business clients and customers. We also receive and process personal information from or on behalf of our clients and customers (about their own customers, clients, employees, market research participants, etc.) when we perform services for them and otherwise act as a service provider to them.	Yes. We know the identities of those who apply for employment with Huron. This is the only group that we are likely to collect some of the more sensitive categories of identifiers from (in order to screen and properly identify them in accordance with employment law), such as social security number, driver’s license number, or similar identifiers.
B. Any categories of personal information described in subdivision (e) of Section 1798.80 (i.e., any information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information)	Yes. Same as above. We collect what you would expect us to collect in the context of your relationship with Huron, even though we do not collect all of the information listed in this category for everyone.	Yes. Same as above. We collect what you would expect us to collect in the context of your relationship with Huron, even though we do not collect all of the information listed in this category for everyone.	Yes. Same as above. We collect what you would expect us to collect in the context of your relationship with Huron, even though we do not collect all of the information listed in this category for everyone.
C. Characteristics of protected classifications under California or federal law (subject to change under the law, but for example: race, color, sex, gender identity and expression, sexual orientation, age, religion, national origin, disability, citizenship status, and genetic information).	No.	No.	Maybe. This information may be passively collected if for example a job applicant discloses it in an employment application (e.g., a Huron job applicant states or implies their race, sex, sexual orientation, religion, or other protected characteristic by listing an affiliation that implies inclusion in a protected classification on their resume or application). Huron does not actively collect this information, unless and until it is part of the equal employment opportunity data recordkeeping process.
D. Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	Yes. We may collect this information about leads in order to develop new business with organizations and individuals who may be interested in or have expressed an interest in Huron. We are primarily a business-to-business organization, and as such we are concerned with organizational habits and needs, far more than individual consumer habits and needs.	Yes. We collect and retain this information about organizational clients and customers because it helps us provide tailored goods and services.	No.
E. Biometric information.	No.	Probably not. However, it is possible within the reasonable context of our relationship with clients that as a professional services firm, Huron may be providing consulting or other services that relate to the client’s own biometric information systems, and may result in Huron having tertiary access to such information that belongs to the client.	No.
F. Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an Internet website, application, or advertisement.	Yes. Huron may have information regarding a lead’s interaction with an Internet website (e.g., Huron’s or other websites), application (e.g., Huron’s SaaS offerings), or advertisement (e.g., Huron’s advertisements). We may collect information related to internet activity attributable to other organizations (i.e., activity attributable to another organization’s known IP addresses for example, rather than individual or household activity) to inform our marketing strategies.	Yes. Huron may have information regarding a client or customer’s interaction with an Internet website (e.g., Huron’s or other websites), application (e.g., Huron’s SaaS offerings), or advertisement (e.g., Huron’s advertisements). We may collect information related to internet activity attributable to other organizations (i.e., activity attributable to another organization’s known IP addresses for example, rather than individual or household activity) to inform our marketing strategies.	Yes. Huron may have information regarding an individual job applicant’s interaction with an Internet website (e.g., Huron’s recruiting website), application (e.g., Huron’s recruitment portal), or advertisement (e.g., Huron’s job postings).
G. Geolocation data.	Maybe. Huron may know the location from where your computer or device is accessing our website in order to provide local content and offerings and to prevent fraud or misuse of our electronic properties.	Maybe. Huron may know the location from where your computer or device is accessing our website in order to provide local content and offerings and to prevent fraud or misuse of our electronic properties.	Maybe. Huron may know the location from where your computer or device is accessing our website in order to provide local content and offerings and to prevent fraud or misuse of our electronic properties.
H. Audio, electronic, visual, thermal, olfactory, or similar information.	Not much, and only what you would expect. For example, physical security, including CCTV at physical Huron office locations may collect audio, electronic, and visual information for a time on security systems, but would be used for security purposes and then overwritten after a set period of time. We electronically monitor the use of our website, but both the technology and our policy prohibit the capturing of personal information in such monitoring and the attribution of website activity to individuals.	Not much, and only what you would expect. For example, physical security, including CCTV at physical Huron office locations may collect audio, electronic, and visual information for a time on security systems, but would be used for security purposes and then overwritten after a set period of time. We electronically monitor the use of our website, but both the technology and our policy prohibit the capturing of personal information in such monitoring and the attribution of website activity to individuals.	Not much, and only what you would expect. For example, physical security, including CCTV at physical Huron office locations may collect audio, electronic, and visual information for a time on security systems, but would be used for security purposes and then overwritten after a set period of time.
I. Professional or employment-related information.	Yes. Because we are a professional services firm serving other business organizations, and some individuals directly, we do collect professional and employment-related information as part of the lead generation or business development process, as you would expect.	Yes. Because we are a professional services firm serving other business organizations, and some individuals directly, we do collect professional and employment-related information as part of the client management process, client service process (e.g., market research and other services provided to or on behalf of other businesses), and additional business development, as you would expect.	Yes. Most job applicants provide this information on their application or we otherwise receive it (e.g., from recruiters or public professional networking and job sites) during the recruiting process.
J. Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99).	No.	Usually not. However, in the context of our TeacherReady Online Certification program we may process education information. And as with certain other categories, it is possible within the reasonable context of our relationship with clients that as a professional services firm, Huron may be providing consulting or other services that relate to the client’s own education information systems, and may result in Huron having tertiary access to such information that belongs to the client.	Yes. As part of the ordinary job applicant background check process, we may collect education information, such as degree confirmations or degree transcripts.
K. Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	Not really at the consumer level, as much as the organization-level. Huron’s marketing efforts are principally focused on figuring out what organizations need and then providing relevant professional services to those organizations (as opposed to targeting and profiling consumers individually to influence their consumer purchases). That means that we are profiling potential client organizations. However, a necessary part of marketing and business development usually includes reaching out to individuals who represent their organizations. In order to do that we have marketing and business development operations and Customer Resource Management systems with information contained therein that you would expect from a B2B professional services firm.	Not really at the consumer level, as much as the organization-level. Huron’s marketing efforts are principally focused on figuring out what organizations need and then providing relevant professional services to those organizations (as opposed to targeting and profiling consumers individually to influence their consumer purchases). That means that we are profiling potential client organizations. However, a necessary part of marketing and business development usually includes reaching out to individuals who represent their organizations. In order to do that we have marketing and business development operations and Customer Resource Management systems with information contained therein that you would expect from a B2B professional services firm.	Not really. We don’t collect inferences to create a profile, but, as is the case with every organization, we do have a recruitment file for job applicants, and we are trying to determine whether any particular applicant is a good fit for Huron.

Regarding any of the above categories of personal information that we process, Huron may disclose that information for a business purpose. Huron uses service providers, like all organizations. And those service providers may process Personal Information for operational purposes – such as detecting or protecting against security incidents, auditing, and performing services on behalf of Huron. For personal information that belongs to our clients, if the clients allow us to use “subcontractors,” then we may be disclosing personal information to those subcontractors which are acting as service providers, as part of our contractual performance on behalf of clients.

California Do Not Track Disclosures

When you visit a website (such as Huron’s website), your browser automatically shares certain information with that website, such as your IP address and other device information, which may also be considered Personal Data under applicable laws. Some of this data may also be sent to service providers (for example: advertisers, website analytic companies, etc.) that provide content on the website. Such sharing may allow the website and/or content providers to track you over time and across multiple websites. At this time, Huron’s website does not respond to Do Not Track beacons sent by browser plugins as there is not yet a common agreement about how to interpret Do Not Track signals from browsers. Please visit our Cookie Policy to learn even more about cookies and similar technologies.

Additional Information for Individuals Located in Europe

This supplemental section of Huron’s Privacy Statement is directed at and applies to individuals located in the European Union (“EU”), United Kingdom (“UK”), Switzerland, or where applicable EU data protection laws (e.g., the General Data Protection Regulation (“GDPR”)) applies.

International Transfers of Your Personal Data

By using the website or providing Personal Data to Huron, your Personal Data may be transferred to the United States, where Huron is headquartered, or to other Huron locations where we carry out our support activities. Your country’s laws governing data collection and use may differ from those in the United States or other Huron locations. For example, the data protection laws of the United States, India, and most other countries have not been found by the European Commission to provide the same level of protection as EU data protection law. Some of the entities with whom we share your Personal Data are also located in countries whose laws have not been deemed by the European Commission to provide the same level of protection to your Personal Data. Only a small number of countries have been officially recognized by the European Commission as providing an adequate level of protection (list available here). Transfers to Huron entities and others located in countries outside the European Economic Area (“EEA”), UK, or Switzerland take place on the basis of an adequacy finding by the relevant authority (i.e., European Commission, Swiss Federal Data Protection and Information Commissioner (“FDPIC”), UK Information Commissioner’s Office (“ICO”) or other competent supervisory authority), EU Standard Contractual Clauses (or other standard contractual clauses approved by a competent supervisory authority), or other appropriate GDPR or applicable law derogations. Please contact privacy@huronconsultinggroup.com if you want to receive further information.

EU-U.S. and Swiss-U.S. Privacy Shield

Special 2020 Privacy Shield Notice: Please note that with respect to Personal Data received from the EEA, UK, and Switzerland in reliance on Huron’s Privacy Shield certification prior to July 2020, and received from Switzerland prior to September 2020, Huron continues to process such Personal Data (previously transferred) in accordance with the Privacy Shield Principles, as the Privacy Shield framework requires. However, the European Commission’s EU-U.S. Privacy Shield adequacy decision was invalidated by the Court of Justice of the European Union in July 2020, and the Swiss-U.S. adequacy decision was revoked by the Swiss FDPIC in September 2020; and as such, Huron no longer relies on its Privacy Shield certification for current and future transfers of Personal Data from the EEA, UK, and Switzerland to the U.S. As noted above, we rely on other appropriate GDPR Art. 46 and 49, UK Data Protection Act Ch. 5, or Swiss Federal Data Protection Act Art. 6 provisions to validate transfers of Personal Data from the EEA, UK, and Switzerland to third countries.

Huron complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Data transferred from the EEA, UK, and Switzerland to the United States prior to July 2020 with regard to the EEA and UK, and September 2020 with regard to Switzerland . Huron has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. Our Privacy Shield certification applies to all U.S. entities and subsidiaries covered in our Privacy Shield certification record, accessible here. Huron and its controlled U.S. subsidiaries subject to the Privacy Shield Principles hold and process all Personal Data previously received from the EEA, UK, and Switzerland, in reliance on our Privacy Shield certification, to the Privacy Shield Principles. If there is any conflict between the terms in this Privacy Statement and the Privacy Shield Principles related to Personal Data transferred in reliance on our Privacy Shield certification, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/. Huron is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.

When we receive written complaints submitted as instructed herein, we will follow up with the person who made the claim. If you have a complaint or concern, please contact us and we will attempt to resolve it. If we are unable to do so, we have designated JAMS, a worldwide provider of alternative dispute resolution services, as our independent recourse mechanism to address complaints and provide appropriate recourse free of charge to individuals covered by the Privacy Shield. The website for submitting complaints which have not been resolved directly by Huron can be found here. Individuals covered by the Privacy Shield may seek binding arbitration for limited types of claims. For additional information about the Privacy Shield arbitration process, please visit the Privacy Shield website at Privacy Shield Arbitration. If a service provider providing services to Huron processes Personal Data from the EEA, UK, or Switzerland that is subject to the Privacy Shield in a manner inconsistent with the Privacy Shield Principles, Huron will be liable unless we can prove we are not responsible for the event giving rise to the damages.

Your European Privacy Rights

Access. You have the right to obtain from us confirmation if your Personal Data is being processed and certain information in this regard.

Rectification. You have the right to request the rectification of inaccurate Personal Data and to have incomplete data completed.

Objection. You have the right, when we process Personal Data on the grounds of legitimate interests, to object to the processing of your Personal Data for compelling and legitimate reasons relating to your particular situation, except in cases where legal provisions expressly provide for that processing. In addition, you have the right to object at any time where your Personal Data is processed for direct marketing purposes.

Portability. You may receive your Personal Data that you have provided to us in a structured, commonly used and machine-readable format and have the right to transmit them to other data controllers without hindrance. This right only exists if the processing is based on your consent or a contract and the processing is carried out by automated means.

Restriction. You may request to restrict processing of your Personal Data (i) while we verify your request – if you have contested the accuracy of the Personal Data about you which we hold; (ii) if the processing is unlawful and you oppose the erasure of it and request restriction instead; (iii) if we no longer need it, but you tell us you need it to establish, exercise or defend a legal claim; or (iv) while we verify your request if you have objected to processing based on public or legitimate interest.

Erasure. You may request to erase your Personal Data if it is no longer necessary for the purposes for which we have collected it, you have withdrawn your consent and no other legal grounds for the processing exists, you objected and no overriding legitimate grounds for the processing exist, the processing is unlawful, or erasure is required to comply with a legal obligation.

Right to lodge a complaint. You also have the right to lodge a complaint with a supervisory authority, in particular in the jurisdiction of your residence, or the location where the issue that is the subject of the complaint occurred.

Right to refuse or withdraw consent. Please note that in case we ask for your consent to certain processing, you are free to refuse to give consent and you can withdraw your consent at any time without any adverse negative consequences. The lawfulness of any processing of your Personal Data that occurred prior to the withdrawal of your consent will not be affected.

If you have questions about exercising any of those rights or their applicability to any of our particular processing activities or have questions about any data transfer mechanism or want a copy thereof, you may contact us at privacy@huronconsultinggroup.com or at the address provided below.

EU Representative

VeraSafe has been appointed as Huron’s representative in the European Union for data protection matters, pursuant to Article 27 of the General Data Protection Regulation of the European Union. If you are in the European Economic Area, VeraSafe can be contacted in addition to Huron’s Chief Privacy Officer (available at privacy@huronconsultinggroup.com), only on matters related to the processing of personal data. To make such an inquiry, please contact VeraSafe using this contact form: https://verasafe.com/public-resources/contact-data-protection-representative or via telephone at: +420 228 881 031.

Alternatively, VeraSafe can be contacted at:

VeraSafe Ireland Ltd.
Unit 3D North Point House
North Point Business Park
New Mallow Road
Cork T23AT2P
Ireland

Contact Us

We have taken great measures to ensure that your visit to our website and your interactions with Huron are satisfying and that your privacy is respected. Unless otherwise stated, Huron is a business and data controller for Personal Data processed subject to this Statement. Because Huron is a professional services firm focused primarily on serving other businesses, Huron is a service provider and data processor to our clients for Personal Data that belongs to the data subjects and consumers who are associated with those clients. If you have any questions, comments or concerns about our privacy practices, please contact us by e-mail at privacy@huronconsultinggroup.com.

Effective October 2020