Athena is solely and independently responsible for its own privacy practices. No Member is responsible for Athena’s privacy practices.
Each Member is solely and independently responsible for its own privacy practices. No Member is responsible for another Member’s privacy practices. Also, Athena is not responsible for any Member’s privacy practices.
- Information that Athena collects from you (including Personal Information)
- Cookies and Tracking Technologies on the Athena Platform
- How your information is used
- How your information is shared
- How to manage your Personal Information
- Storage & Security
- Contact information
INFORMATION THAT ATHENA COLLECTS FROM YOU (INCLUDING PERSONAL INFORMATION)
Athena directly collects information when you:
- sign up for an Athena user account and create an Athena user profile;
- enroll and participate in online courses;
- purchase a product or service (for example, Verified Certificates);
- send email messages to Athena (including messages to learner support);
- participate in user surveys; and
- participate in public forums, webinars, and other interactive experiences on the Athena Platform.
Athena also indirectly collects usage information about your visit to the Athena Platform, as explained in the section below titled Cookies and Tracking Technologies.
Athena does not itself collect or store financial account numbers or identification issued by a governmental entity, employer, or other authority. Instead, if you choose to make a purchase on the Athena Platform, for example a Verified Certificate, you will be directed to Athena’s third-party payment processor and Athena’s third-party ID verification service provider. If you do not wish to submit the required authentication or payment information, then you will not be able to obtain a certificate via the Athena Platform.
Athena requires your Personal Information only in limited circumstances when you:
- sign up for an Athena user account (name, username, email address);
- purchase a Verified Certificate (so that Athena’s third-party vendor can authenticate your identity) or other product or service (so that Athena’s third-party vendor can process payment);
- participate in remote proctoring or other course facilitation processes (so that Athena’s third-party vendor can monitor and assess the integrity of your course activity); or
- earn a Verified Certificate (the certificate will have your name on it).
To the extent that Athena associates the information that Athena collects directly or indirectly with an individual (for example, you), the association is based on Personal Information in your account profile.
You may voluntarily choose to share additional Personal Information on the Athena Platform, for example:
- in your Athena account profile (and you may display a limited or full profile to other Athena Platform users);
- in applying for financial assistance; or
- when participating in a course, forum, webinar, or other interactive experience on the Athena Platform (noting that in some cases, this information is shared with a third party that provides tools or other assistance for the Athena Platform or a course).
Athena encourages you to use discretion before voluntarily sharing additional Personal Information on the Athena Platform. (If you later choose to delete your Athena account, deletion of your Personal Information will be subject to the process and limits outlined below.)
Members do not receive your Personal Information unless and until you enroll in a course. If you enroll in a course, the Member that offers the course will receive Personal Information from your Athena account profile plus the information that Athena collects about your activity and performance in the course in which you enrolled.
COOKIES AND TRACKING TECHNOLOGIES ON THE ATHENA PLATFORM
- based on your cookie settings, Athena tracks information indicating, among other things, which pages of the Athena Platform were visited, the order in which they were visited, when they were visited, and which hyperlinks and other user interface controls were used;
- Athena may log the IP address, operating system, and browser software (including mobile use and device type when you use Athena native mobile apps) you used when accessing the Athena Platform, and Athena may be able to determine from an IP address your Internet Service Provider and the geographic location of your point of connectivity; and
- Athena may track and collect information from emails that Athena sends to you, for example whether you opened the email or clicked on any links from the email.
Athena also partners with third parties to help us track and understand your activity on the Athena Platform, how you interact with Athena’s social media, and how you find or may be referred to the Athena Platform. Individual Members may separately use Tracking Technologies within their courses and email communications to understand your activity within a course and how you find or may be referred to a course on the Athena Platform.
- when necessary for system administration, security, and integrity to ensure the Athena Platform works properly for you. Without these technologies, the Athena Platform may not function correctly;
- to enable analytics, performance and functionality, to help Athena and Members gather information about how visitors use the Athena Platform and monitor Athena Platform performance, and to enhance your experience by recognizing and remembering whether you have visited the Athena Platform before and may have any personal preferences; and
- to support marketing by enabling Athena and Members to deliver content relevant to your interests on the Athena Platform and third-party sites based on how you interact with Athena or Member advertisements or content. Athena and Members use “first-party” cookies, which means cookies served by Athena or an individual Member, and also “third-party” cookies, which means cookies served by third parties that help Athena and Members track this information.
You have some options for managing Cookies and other Tracking Technologies. These include:
- Modifying your browser settings: You should be able to control how and whether your web browser accepts Cookies by adjusting its privacy and security settings. The “help” feature of the menu bar on most browsers will tell you how to stop accepting new Cookies, how to receive notification of new Cookies, and how to disable existing Cookies. If you reject Athena’s Cookies, many functions and conveniences of the Athena Site may not work properly.
- Opting-out of certain third-party tracking and advertising: Some of the third parties used by Athena or a Member for Cookies and Tracking Technologies offer the ability to opt-out from their tracking by following processes described on their websites. A list of some such third parties is maintained and available at the Athena learner Help Center and includes, for some, links to applicable opt-out processes. Neither Athena nor any Member is responsible for the effectiveness of any third-party opt-out options.
HOW YOUR INFORMATION IS USED
Athena and Members use information, including Personal Information, to carry out the following purposes:
- Operate and improve the Athena Platform – This includes creating and improving features that support the Athena community and enable Athena Platform usage at scale. This also includes personalizing the Athena Platform, so your learning experience is tailored to your interests and needs.
- Create, administer, provide, and teach courses – This includes creating and improving the delivery of massive open online courses and programs on Athena. This also includes personalizing courses, so your learning experience is tailored to your interests and needs, and assessing your performance and awarding certificates.
- Offer and improve products and services – This includes enabling you to navigate the Athena Platform, to enroll and participate in courses and programs on the Athena Platform, to learn effectively in such courses and programs, and to purchase or obtain products and services on the Athena Platform such as Verified Certificates.
- Develop and maintain the security and performance of the Athena Platform – This includes tracking Athena Platform outages and creating software solutions, detecting violations of the Honor Code and Terms of Service, and monitoring uses, misuses, and potential misuses of the Athena Platform.
- Communicate with you – This includes answering your course and platform questions, notifying you of course and Athena Platform maintenance and updates, marketing to you about course offerings, programs, news, and related products and services of Athena or Athena affiliates, and as permitted under applicable law, sending you communications about products or services of selected business partners that may be of interest to you.
- Support scientific research including, for example, in the areas of cognitive science and education – This includes collaborating to enable and conduct research about how learners access and master course materials online, with the goal of improving course outcomes.
- Track Athena Platform usage against goals and mission – This includes performing analytics to evaluate access to and performance in courses and course-related products and services and to report aggregate usage information (not Personal Information) to business partners and external audiences.
- Exercise, enforce, and comply with legal rights and obligations – This includes responding to subpoenas, court orders, or other legal process; and investigating, preventing, or taking action regarding illegal activities, suspected fraud, security or technical issues, or to protect the rights, property, or safety of Athena, Members, or others, and as otherwise required by applicable law.
Athena or a Member may also seek your consent for additional uses of information, including Personal Information, and will use it only for the purpose described to you. All use of Personal Information is subject to applicable law.
HOW YOUR INFORMATION IS SHARED
Athena and Members share information, including Personal Information, with third parties for the following purposes:
- With other learners in courses that you take and with other visitors to the Athena Platform, to create an interactive learning environment, support class participation, and share course information – This includes sharing comments, coursework, or other information or content that you submit to a portion of the Athena Platform designed for viewing by other class members or for public communication. This also includes providing opportunities for you to communicate with other users who may have similar interests or educational goals, for instance, recommending specific study partners or connecting potential student mentees and mentors. In such cases, Athena and each Member that offers a course in which you enrolled may use all information collected about you to determine who might be interested in communicating with you, but will only provide others your username (for clarity, no disclosure of your real name or email address).
- With employers, government programs, institutions, or other enterprises that sponsor your enrollment in a course for training or other educational purposes – If an entity pays for or otherwise sponsors your Verified Certificate or course participation, Athena will share information with the entity as needed to confirm your enrollment, participation, progress, and completion status in that course.
Athena or a Member may also seek your consent for additional disclosures of information, including Personal Information, and will share it only as described to you. In addition, Athena or a Member may share with the public and with third parties, including but not limited to researchers and business partners, information and Personal Information that is de-identified or aggregated in a manner that does not personally identify you.
HOW TO MANAGE YOUR PERSONAL INFORMATION
You can manage your Personal Information through learner features on the Athena Platform and requests to the Athena learner support team. If your request involves information controlled by a Member, Athena learner support will notify and coordinate with the appropriate Member to address your request. Athena will provide support to the extent required by applicable law (for example, learners in the European Union) and more broadly when possible, as a courtesy in our sole discretion. Athena will notify you in the event that Athena is unable to meet a request that is not legally required. Similarly, Members will only be obligated to comply with requests to the extent legally required, but may choose to comply with other requests in their sole discretion.
Access and correct your Personal Information
Much of your Personal Information is available in your Athena account. Your name, email address, and other identifiable profile information is editable through the profile settings in your Athena account except as noted below. Your account dashboard lists all current and archived courses in which you have enrolled and includes links to any Verified Certificates you may have earned. The dashboard also contains copies of your answers and other participation and performance in courses. Please contact Athena learner support to access and update this or other information. If your request involves information controlled by a Member, Athena learner support will notify the appropriate Member of your request.
- Usernames cannot ever be changed. This is an Athena system restriction. Because usernames identify you in courses and elsewhere on the Athena Platform, Athena encourages you to use discretion in choosing your username.
- Athena does not track or index every time or every place on the Athena Platform when or where a learner may volunteer Personal Information, so neither Athena nor Members will be able to help you locate or manage all such instances. Athena encourages you to use discretion before volunteering Personal Information on the Athena Platform.
Restrict or object to the processing of Personal Information
If you want to manage emails and other communications to you, you may update your preferences in your Athena account dashboard, follow the steps described in links at the bottom of email messages, or contact Athena learner support. You may object to, or request that Athena or a Member stop, its use of your Personal Information for other purposes by contacting the Athena learner support team. If your request involves information controlled by a Member, Athena learner support will notify the appropriate Member of your request. Please note that if you choose to restrict Athena’s or a Member’s ability to process Personal Information, and the processing is otherwise required to provide you with various services and products offered on the Athena Platform, you may not be able to establish an Athena user account or enroll for a course, and Athena or a Member may not be able to provide you with those services or products.
Delete account and Personal Information
To request deletion of your Athena account and Personal Information, you should click the button labeled “Delete my account” in your Athena account settings. Because deletion on the Athena system is a permanent action and cannot be reversed, Athena may ask you to complete a process that aims to confirm your authority to manage the Athena account affected by your request.
With respect to your Athena account, Athena will permanently:
- deactivate your Athena account,
- remove the active profile,
- retire your username, and
- remove you from Athena email lists.
With respect to your Personal Information, Athena will permanently delete your Athena account profile Personal Information from the Athena Platform.
As noted above, to the extent that Athena associates the information that Athena collects directly or indirectly with an individual (for example, you), the association is based on Personal Information in your Athena account profile. By erasing the Personal Information in your Athena account profile, the remaining information about your activity on the Athena Platform will no longer be associated with you, except as noted below.
These changes will be applied to data stores that are used for operation of the Athena Platform including course administration by Members. If you enrolled in any courses on the Athena Platform, the Athena learner support team will share your request with the Members that offered those courses.
- Deletion will not apply to historical activity logs or archives unless and until these logs and data naturally “age-off” the Athena system.
- Athena does not track or index every time or every place on the Athena Platform when or where a learner may volunteer Personal Information, so neither Athena nor Members will be able to help you locate or manage all such instances. Athena encourages you to use discretion before voluntarily sharing your Personal Information on the Athena Platform.
- Athena will archive course data (in a manner and to the extent permitted under applicable law) to serve its mission to enable scientific research on cognitive science and education. These archives are used to produce encrypted research data packages for Members, and Personal Information may not be deleted from research data packages retained by Members.
- Athena and each applicable Member cannot always delete records of past interactions and transactions. For example, records relating to previous purchases on the Athena Platform must be retained for financial reporting, audit, and compliance reasons.
- Athena and each Member will retain and use Personal Information as necessary to comply with its legal obligations, resolve disputes, enforce its agreements, and as otherwise permitted by applicable law.
Athena will retain your Personal Information for as long as your account is active or as needed to provide you with services; to maintain a record of your transactions for financial reporting, audit, and compliance purposes; and to comply with Athena’s legal obligations, resolve disputes, enforce its agreements, and as otherwise permitted by applicable law. If you enroll in a Member’s course, such Member will also retain your Personal Information for as long as needed to provide you with services; to maintain a record of your transactions for financial reporting, audit, and compliance purposes; and to comply with its legal obligations, resolve disputes, enforce its agreements, and as otherwise permitted by applicable law. Upon your request that Athena deactivate your account and delete your information, Athena will follow the process described above, including without limitation archiving your course data (in a manner and to the extent permitted under applicable law) to serve its mission to enable scientific research on cognitive science and education. These archives will be used to produce encrypted research data packages for Members, and each such Member may also keep and use course data for scientific research.
STORAGE & SECURITY
Athena stores information, including Personal Information, on its own servers and also on servers of companies that Athena hires to provide services. Each Member also stores information, including Personal Information, on its own servers and/or on servers of companies that the Member hires to provide services. In each case, information may be stored in Germany and in other countries where Athena or a Member operates, and in countries where Athena and each Member’s respective service providers operate. If you are in the European Union, Switzerland, or other regions with laws governing data collection and use, you acknowledge that Athena and each Member may transfer, process and store your personal information in Germany and other countries, the privacy laws of which may be considered less strict than those of your region.
Athena controls its own copy of information collected through the Athena Platform and has an information security program designed to protect information in its possession or control. This is done through a variety of privacy and security policies, processes, and procedures. Athena uses administrative, physical, and technical safeguards that reasonably and appropriately protect the confidentiality, integrity, and availability of the information that it collects, receives, stores, or transmits. Nonetheless, no method of transmission over the Internet, or method of electronic storage, is 100% secure; and therefore, Athena cannot guarantee its absolute security. While Athena works hard to ensure the integrity and security of its network and systems, Athena cannot guarantee that its security measures will prevent “hackers” or other unauthorized persons from illegally accessing or obtaining information.
If Athena learns of a security breach involving its copy of your Personal Information, Athena may attempt to notify you electronically so that you may take appropriate protective steps. By using the Athena Platform or providing Personal Information to Athena, you agree that Athena can communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Athena Platform. If a security systems breach occurs, Athena may post a notice on the Athena homepage (www.athena.ied.eu ) or elsewhere on the Athena Platform and may send an email to you at the email address associated with your Athena account. Depending on where you are located, you may have a legal right to receive notice of a security breach, involving your Personal Information, in writing.
If a Member learns of a security breach involving that Member’s copy of your Personal Information, the Member may attempt to notify you electronically so that you may take appropriate protective steps. By enrolling in a Member’s course on the Athena Platform or providing Personal Information to the Member, you agree that the Member can communicate with you electronically regarding security, privacy, and administrative issues relating to your course enrollment and participation. If a security systems breach occurs, the affected Member may post a notice on the Athena Platform and/or send an email to you at the email address associated with your enrollment in the Member’s course on the Athena Platform. Depending on where you are located, you may have a legal right to receive notice of a security breach, involving your Personal Information, in writing.
If you have privacy concerns, have disclosed data you would prefer to keep private, or would like to access the Personal Information that Athena maintains about you, please contact us at firstname.lastname@example.org.
Data Protection Officer:
You may also write to us at: ATTN: PRIVACY, Institute of Entrepreneurship Development, Valtetsiou and Tripoleos, Larisa 41336, GREECE. If your request involves a Member, Athena will notify the appropriate Member of your request.
Cookies are unique identifiers usually in the form of small data files placed on your device that send certain information about your activity on the Athena Platform or in an email communication back to Athena or the authorized third party that served the cookie. Athena or third parties may also use Flash cookies.
Athena Platform consists of all content and pages located within the athena.ied.eu web domain and all Athena mobile applications.
Member is each educational institution or other leading global institution or entity that provides courses through the Athena Platform.
Personal Information is information that specifically identifies you or that, when combined with other information, could be used to identify you.
Tracking Technologies are web beacons, clear gifs, pixels, and similar technologies that are also unique identifiers used to track your online activity but are not stored on your device.
Verified Certificate is a virtual certificate that shows that you have successfully completed your Athena course or program and verified your identity using your webcam and your acceptable form of photo ID.
May 7, 2020