1. Overview
This Web Privacy Policy sets forth the data privacy standards of Quantum Pathways Institute (“Quantum Pathways Institute”, “we”, “us”, or “our”) and provides information about the collection, maintenance, use, disclosure, and protection of personal information or personal data provided to, collected by, or processed by Quantum Pathways Institute in connection with our websites, web applications, and online services (collectively, the “Quantum Web”).
2. Purpose
The purpose of this Policy is to establish an organization-wide standard for transparent, lawful, and secure handling of personal information across the Quantum Web. Where applicable, this Policy is intended to align with recognized international privacy frameworks, including the EU General Data Protection Regulation (GDPR), and applicable national and state privacy laws. This Policy describes how we collect, use, retain, share, and protect personal data and explains the rights available to data subjects.
3. Scope
This Policy applies to all domains, subdomains, microsites, web applications, APIs, and third-party services operated, controlled, or maintained by Quantum Pathways Institute (collectively “Quantum Web”) and to any processing of personal information performed as part of Quantum Pathways Institute’ academic, research, administrative, or commercial activities. It applies regardless of the format, location, or the technology used to collect or store personal information (electronic, paper, or otherwise).
Local units, departments, projects, or partner programs that maintain specialized or additional privacy practices must document those practices and obtain prior approval from the Data Protection Officer (DPO) or Privacy Office before public publication.
The Quantum Web may include links to external third-party websites and services over which Quantum Pathways Institute has no control; this Policy does not govern those third-party sites.
4. Required Link
Every Quantum Web page, application, and public-facing web property must include a prominent link to this Web Privacy Policy and to any applicable Cookie Notice or Data Subject Rights page.
5. Definitions — What is Personal Information / Personal Data?
“Personal Information” or “Personal Data” means any information that identifies, relates to, describes, or can reasonably be linked to an identifiable natural person, including direct identifiers (name, email, national ID) and indirect identifiers (IP address, device identifiers, behavioral profiles).
“Processing” means any operation performed on personal data — collection, recording, organization, storage, retrieval, consultation, use, disclosure, dissemination, alignment, combination, erasure, or destruction.
“Data Subject” means the identified or identifiable natural person to whom the personal data relates.
6. How Personal Information Is Collected and Processed
- Information you voluntarily provide via online forms, applications, surveys, registrations, job applications, support tickets, and contact forms (e.g., name, email, phone, address, application materials, transcripts, resumes).
- Authentication data for access-controlled services (usernames, hashed passwords, unique identifiers).
- Payment and billing information processed through third-party payment processors when you purchase products or services.
- Information collected automatically when you visit the Quantum Web, such as IP address, browser type, device identifiers, referrers, and clickstream data.
- Cookies, web beacons, local storage, and similar technologies for session management, personalization, analytics, and advertising.
- Personal data received from authorized third parties and publicly available sources when permitted by law.
Processing activities are limited to purposes described at the point of collection or in this Policy and are carried out under appropriate legal bases.
7. Log Data and Aggregated Usage Information
Quantum Web servers and third-party service providers may generate logs that record technical information such as IP addresses, request URLs, referrers, browser user agents, timestamps, and error codes. These logs are used for performance monitoring, security, troubleshooting, and aggregate usage reporting.
8. Cookies and Similar Technologies
- Strictly necessary: session management, secure login, load balancing, and essential functionality.
- Preferences/Functional: language preferences and UI customization.
- Performance/Analytics: site usage analytics to improve the Quantum Web.
- Targeting/Advertising: with explicit consent where required.
Users may manage cookie preferences via the cookie banner or browser settings.
9. Third-Party Content and Embedded Services
Quantum Web may embed third-party content such as videos, social widgets, and fonts. When such content loads, technical details like your IP address may be transmitted to those third parties.
10. Legal Grounds for Processing and How We Use Data
- Providing and administering services, applications, and instruction
- Managing admissions, employment, and contractual relationships
- Processing payments and financial transactions
- Communicating about events and services
- Ensuring network security and preventing fraud
- Research, analytics, institutional planning
- Compliance with legal and regulatory obligations
Where required, lawful bases (e.g., consent, legitimate interests) are documented.
11. Research and Further Processing
Personal data may be used for research, historical, statistical, or archival purposes with safeguards such as anonymization, minimization, and access controls.
12. Google Analytics and Other Analytics Services
Quantum Web may use analytics tools like Google Analytics to collect aggregated usage statistics. Consent will be obtained where required by law.
13. Security and Data Accuracy
Quantum Pathways Institute implements administrative, technical, and physical safeguards against unauthorized access, disclosure, or destruction of data.
14. Data Breach Response Plan
Incident response procedures are in place to detect, contain, and remediate data security incidents. Users will be notified where required by law.
15. E-commerce and Online Payments
Quantum Web uses secure, PCI-compliant payment processors. Payment information is used only to complete transactions.
16. Open Records, Legal Requests, and Disclosure
Information may be disclosed to comply with legal requests where permitted by law. We notify individuals where required.
17. Public Forums, Discussion Boards, and User-Generated Content
Information posted publicly may become accessible to others. Users should use caution when sharing personal details.
18. Online Surveys and Research Data Collection
Survey purposes, data usage, and confidentiality practices will be disclosed before participation.
19. Data Processors and Third-Party Service Providers
Contracts with vendors include data protection requirements and restrict unauthorized transfers.
20. Types of Personal Information Processed
Examples include: identity information, contact details, student/staff IDs, academic and job records, financial info, authentication data, and device metadata.
21. Data Subject Rights and How to Exercise Them
Depending on the law, rights may include access, correction, deletion, restriction, objection, and portability of personal data. Requests may require identity verification.
22. Special Legal Regimes (FERPA, HIPAA, GDPR, etc.)
- FERPA: Protects educational records.
- HIPAA: Separate Notices of Privacy Practices are issued for covered health units.
- GDPR: Safeguards for international transfers may include SCCs.
23. Data Retention and Records Schedule
Personal data is retained only as long as necessary to fulfill intended purposes and comply with legal retention rules.
24. Changes to This Web Privacy Policy
Policy is reviewed periodically and updates will be posted with revised dates. Significant changes may be communicated to users.
25. Publication Frequency and Revision History
Reviewed at least annually or when necessary. Revision history available on request.
26. Additional Resources and Related Policies
Related policies include: Acceptable Use Policy, Information Security Policy, Records Retention Schedule, Data Breach Response Plan, and Cookie Notice.