Section 1: Unfair or Deceptive Acts or Practices and Marketing Compliance
It is American Diesel Training Center’s (ADTC) policy that all forms of marketing and advertising be approved by senior management prior to use.
REQUESTS FOR APPROVAL OF ADVERTISING
Officers may request approval of advertising and marketing by submitting a copy of the item (if
applicable) together with a completed Advertising Approval Request. One copy of the
request form should be submitted to senior management. The Advertising Approval Request Form should include a complete description of the advertisement or promotion and how or where it will be used. The officer submitting a request is responsible for obtaining the necessary approvals from compliance and senior management on the Advertising Approval Request Form before proceeding with an advertisement, promotion or marketing effort.
UNFAIR OR DECEPTIVE ACTS OR PRACTICES
ADTC shall comply with Section 5 of the Federal Trade Commission Act, 15 U.S.C. § 45(a): "Unfair methods of competition in or affecting commerce, and unfair or deceptive acts or practices in or affecting commerce, are hereby declared unlawful." The officer submitting a request is responsible for obtaining the necessary approvals from compliance and senior management before proceeding with an advertisement, promotion or marketing effort.
Certain regulatory disclosures are required for some ADTC advertising. Some forms of
advertising and marketing, such as lotteries are legally restricted. Proper approval must be
obtained from the compliance department and senior management before running any promotion.
The compliance department will ensure that all regulatory and disclosure requirements have been
met and will maintain copies of all advertising for review by examiners. Senior management will
approve content and cost.
Marketing efforts will be reviewed to ensure that target markets are not selected using a
prohibited basis: race, color, religion, national origin, sex, marital status, age, handicap, familial
status, receipt of public assistance income, or because an applicant has in good faith exercised
any rights under the Consumer Credit Protection Act.
COMMON MEDIUMS USED FOR ADVERTISING AND MARKETING
As defined by various regulations and laws many of the communications ADTC issues to the
public and its’ customers are forms of advertising. The following are common mediums used for advertising and marketing:
1. Social Media platforms;
2. Billboards; signs, and banners
3. Ads in magazines, newspapers, phonebooks, and other printed material
4. Direct mail marketing and form letters;
5. Flyers, handouts and pamphlets;
6. Clothing items, hats, buttons, pens;
7. Information on ADTC’s website;
When in doubt as to whether a promotion is considered advertising officers are directed to
contact the compliance department for assistance. Question regarding this policy should be directed to the Vice President, Marketing Department.
Section 2: Non-Discrimination Policy
ADTC does not and shall not discriminate on the basis of race, color, religion (creed), gender, gender expression, age, national origin (ancestry), disability, marital status, sexual orientation, or military status, in any of its activities or operations. These activities include, but are not limited to, hiring and firing of staff, selection of volunteers and vendors, and provision of services. We are committed to providing an inclusive and welcoming environment for all members of our staff, clients, volunteers, subcontractors, vendors, and clients.
ADTC is an equal opportunity employer. We will not discriminate and will take measures to ensure against discrimination in employment, recruitment, advertisements for employment, compensation, termination, upgrading, promotions, and other conditions of employment against any employee or job applicant on the bases of race, color, gender, national origin, age, religion, creed, disability, veteran's status, sexual orientation, gender identity or gender expression.
Section 3: Tuition Refund Policy
If the student is not accepted into the training program, all monies paid by the student shall be
refunded. Refunds for books, supplies and consumable fees shall be made in accordance with
the following provisions
(1) A student who withdraws before the first class and after the 5-day cancellation period
shall be obligated for the registration fee.
(2) A student who starts class and withdraws before the academic term is 15% completed
will be obligated for 25% of the tuition and refundable fees plus the registration fee.
(3) A student who starts class and withdraws after the academic term is 15% completed but
before the academic term is 25% completed will be obligated for 50% of the tuition and
refundable fees plus the registration fee.
(4) A student who starts class and withdraws after the academic term is 25% completed but
before the academic term is 40% completed will be obligated for 75% of the tuition and
refundable fees plus the registration fee.
(5) A student who starts class and withdraws after the academic term is 40% completed will
not be entitled to a refund of the tuition and fees.
The School shall make the appropriate refund within thirty (30) days of the date the School is
able to determine that a student has withdrawn or has been terminated from a program.
Refunds shall be based upon the last date of a student’s attendance or participation in an
academic School activity.
Section 4: Complaints and Grievances Policy
All student complaints should be first directed to the School personnel involved. If no resolution
is forthcoming, a written complaint shall be submitted to the Administrator of the School.
Students may submit a completed complaint form and supplemental documentation to the
Commission after they have completed the institution’s grievance policy and remain dissatisfied
with the results.
Section 5: Student Privacy and Student Information Security Policy
PERSONAL INFORMATION WE COLLECT
“Personal Information,” means any information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, to any individual or household. It does not include anonymous or aggregated data that cannot be associated with an individual or household.
We may collect, use, store and transfer different kinds of Personal Information about you, which we have grouped together as follows:
Identifiers such as first name, maiden name, last name, alias, username or similar unique personal identifier, student ID, account name, online identifier, social security number, driver’s license number, your state identification card number, military ID or other government identification card, criminal background status, physical characteristics or description, marital status, disability status, date of birth, place of birth, race, ethnicity, religion, gender, or country of origin.
Contact Information such as physical address, mailing address, email address, and telephone numbers.
Educational Information such as educational records that contain information directly related to a student, like your enrollment status, grades, attendance, and high school graduation information and which are maintained by an educational institution or agency or party acting for the institution or agency.
Financial Information such as student financial aid information, payment history, tax information, bank account and routing numbers, credit or debit card information, student account number, tuition totals, and payment details.
Health Information such as height, weight, drug testing, and immunization history.
Commercial Information such as details about payments to and from you, other details of products and services you have purchased from us, or purchasing or consuming tendencies or histories.
Student Housing Information such as residence information, move-in date, and housing costs.
Professional or Employment-Related Information such as your employment status, employer’s information, employment start and end dates, salary, job title and duties, education, training, prior work experience, references, certification, licensure, or other professional information, military affiliation and status, and post-graduation employment and earnings information.
Motor Vehicle Information such as driving history and records, make, model, and year of your vehicle, and license plate number.
Audio, Electronic, and Visual Information such as call and video recordings and photos.
Technical Information includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our Services.
Usage Data includes information about how you use our Services.
Marketing and Communications Information such as marketing campaign data, click throughs, your preferences and consent in receiving marketing from us and our third parties, your communication preferences and other preferences and interests.
We may also collect, use, and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your Personal Information, but is not considered Personal Information as this data does not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your Personal Information so that it can directly or indirectly identify you, we treat the combined data as Personal Information which will be used in accordance with this privacy notice.
Children’s Privacy. The Services are intended for adult use only and is not directed towards children, minors, or anyone under the age of 16. If you are under the age of 13, you are not authorized to provide us with any Personal Information. If the parent or guardian of a child under 13 believes that the child has provided us with any Personal Information, the parent or guardian of that child should contact us at the email address below and ask to have this Personal Information deleted from our files.
HOW WE COLLECT YOUR PERSONAL INFORMATION
We may collect Personal Information from a variety of sources and methods. This includes:
Information You Voluntarily Provide to Us
You may give us your Personal Information by filling in forms, enrolling in one of our educational programs, or by corresponding with us by post, phone, text, email, or otherwise. This includes Personal Information you provide when you:
Submit a request for information form
Submit a contact us form
Use the chat feature on our website
Call, email, or text us
Apply to enroll and/or enroll in one of our educational programs
Request a student ID
Register for classes
Apply for financial aid
Create a student account
Enroll in a training program with one of our partners
Order or purchase educational or other products and services
Attend our courses, programs or other events where we collect information about you
Submit a review or student testimonial
Use one of our career or student resources
Use one of our online learning management, student portal, or other interactive tools
Information We Collect When You Use Our Services:
Automated technologies or interactions. As is true of most websites, we receive and store certain types of Personal Information whenever you interact with us online. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. When you access and use our Services from your mobile devices, we receive data from that mobile device. This may include your device ID, location data, IP address and device type. You may manage how your mobile device and mobile browser share location information with us, as well as how your mobile browser handles cookies and related technologies by adjusting your mobile device privacy and security settings. Please refer to instructions provided by your mobile service provider or the manufacturer of your device to learn how to adjust your settings.
Information We Collect From Third Parties
We collect Personal Information from various third parties, including those listed below. The collection, use, and disclosure of Personal Information received from third parties is governed by the privacy policies listed on the website where the information was submitted by the user. Third parties may send their own cookies and pixel tags to you, and may collect information and use it in a way inconsistent with this Policy. Please carefully review these third-party privacy policies to understand how your information may be collected, used and disclosed by these third parties.
Third Party Service Providers. We collect Personal Information from service providers, including online application submission and management platforms, student information platforms, learning management platforms, background and credit check providers, employment verification providers, housing providers, payment processors, email platforms, call centers, and social media platforms.
Third Party Advertising Partners. We collect Personal Information received from third party advertising partners, including partners who host and manage various advertisements and online forms where you can request additional information.
Google Analytics. We use third-party cookies provided by Google Analytics to assist us in better understanding our website visitors. These cookies collect IP address and usage data, such as the length of time a user spends on a page, the pages a user visits, and the websites a user visits before and after visiting our website. Based on this information, Google Analytics compiles data about website traffic and interactions, which we use to offer better user experiences and tools in the future.
For more information on Google Analytics, visit https://support.google.com/analytics.
Third Party Cookies. We may engage third party service providers, including Google, Facebook, and Instagram, to serve ads to you about our products and services as you browse the Internet. These third party providers may use their own cookies to track your online activities and purchases in order to deliver targeted advertising based on your interests.
You can learn more about Google’s advertising cookies and opt-out options by visiting http://www.google.com/policies/technologies/types/.
You can learn more about Facebook’s advertising cookies and opt-out options by visiting https://www.facebook.com/policy/cookies/.
You can learn about Instagram’s advertising cookies and opt-out options by visiting https://help.instagram.com/1896641480634370?ref=ig.
Your ‘Do Not Track’ Browser Setting. Some web browsers incorporate a “Do Not Track” feature (DNT) that signals to the websites that you visit that you do not want to have your online activity tracked. Many websites and applications, including the Services, do not currently respond to web browser DNT signals because such signals are not yet uniform. For more information about DNT signals, please visit http://allaboutdnt.com. Other third party websites may keep track of your browsing activities when they provide you with content, which enables them to customize what they present to you on their websites.
HOW WE USE YOUR PERSONAL INFORMATION
Our primary purpose for collecting Personal Information is to provide you with products and services you request. We may also use your Personal Information for the following business purposes:
To determine your admissibility for your selected educational program
To process your application and enroll you in an education program
To verify your educational background during the enrollment process
To determine your eligibility for financial aid, scholarships, and grants
To provide career services assistance
To provide you with information, products and/or services you request
To facilitate recruitment efforts
To facilitate the creation of and secure any student accounts
To communicate with individuals in written, electronic, and verbal form
To analyze academic and learning outcomes and preferences
To develop new tools, software applications, products and services
To obtain payment for services that we provide to you, including, but not limited to, financial aid
To conduct background checks where required
For internal marketing purposes, which include, but are not limited to, sending you material about products, services, updates, etc. that we think may be of interest to you
To customize the advertising and content you see
To maintain students records and transcripts
For internal business purposes such as complying with our internal policies, conducting audits, or improving our Services
To analyze how our Services are being accessed and used
To verify information
To protect our interests, including establishing, exercising and defending legal rights and claims
As necessary to comply with legal or accreditation requirements, to enforce the terms of our Enrollment Agreement and Code of Conduct, to prevent fraud, to co-operate with law enforcement and regulatory authorities, and to stop other prohibited, illegal, or harmful activities
For purposes disclosed at the time you provide your information or as otherwise set forth in this Policy
HOW WE SHARE PERSONAL INFORMATION WITH THIRD PARTIES
We endeavor to incorporate safeguards to help protect and secure your Personal Information. However, no data transmission over the Internet, mobile networks, wireless transmission or electronic storage of information can be guaranteed to be 100% secure. Therefore, we cannot guarantee its absolute security. It may be possible for third parties to intercept or access transmissions or private communications unlawfully. Any such transmission is done at your own risk.
CALIFORNIA PRIVACY RIGHTS
California Consumer Privacy Act. The California Consumer Privacy Act of 2018 (“CCPA”) provides California residents with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.
Upon verification of your identity you may:
No more than twice in any 12-month period, request disclosure of the following information:
Categories of Personal Information we collect.
Categories of sources from which Personal Information is collected.
Categories of Personal Information sold or disclosed to third parties.
Categories of third parties with whom such Personal Information is sold or disclosed.
Business or commercial purpose for collecting or selling Personal Information.
Specific pieces of Personal Information we collect.
Request deletion of your Personal Information, subject to the exceptions provided by law.
Opt out from having your Personal Information sold to third parties, if applicable.
Please note that these rights apply only to select California consumers and exclude job applicants, employees, and business contacts. Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child.
The verifiable consumer request must:
Include your full legal name, phone number, and email address, which we will need to contact you in order to verify that you are the person about whom we collected Personal Information or an authorized representative.
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. Making a verifiable consumer request does not require you to create an account with us. If you submit a verifiable consumer request, one of our representatives will contact you with further instructions on how to verify your identity.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
Debug products to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et seq.).
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
Comply with a legal or accreditation obligation.
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.
The CCPA provides the right to be free from discrimination if you choose to exercise your rights under the statute, and ADTC will not discriminate by:
Denying you goods or services.
Charging you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
Providing you a different level or quality of goods or services.
Suggesting that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Other California Privacy Rights. California Civil Code Section 1798.83 permits California residents who have provided personally identifiable information to us or our third-party advertisers and marketing partners, if any, to request certain information regarding our disclosure of personally identifiable information to third parties for direct marketing purposes.
ADTC may modify or update this Policy from time to time. We encourage you to revisit this page often to remain fully informed of our Policy or you can contact us at any time to obtain the latest copy of this Policy.
QUESTIONS ABOUT THIS POLICY
For questions or comments regarding our Policy, please contact us at firstname.lastname@example.org
If you become a student, your educational records are subject to the U.S. federal Family Educational Rights and Privacy Act (FERPA), state laws and your School policies. To obtain a copy of the Students' Rights to Privacy and Access to Educational Records policy, click here.
If you do not wish to receive marketing email communications or direct mail communications from us, you may express your choice where indicated on the applicable email or other communication, or unsubscribe.