Privacy Policy

Triumph Higher Education Group, LLC (“Company”, “we”, “our”, “us”, or “Triumph”) respects your privacy. This policy describes how we collect, process, retain, and disclose personal data about you through our corporate website located at triumpheducation.com and other online services that link to this policy (our “Website” or “Services”), and our practices for using, maintaining, protecting, and disclosing that information. This policy applies only to our corporate Website and does not govern the separate educational platforms, student-facing portals, or products and services offered by Triumph or its schools or other businesses, which are covered by their own privacy notices.

This policy may change from time to time. When we make material changes, we will provide notice as required by applicable law and update the “last updated” date above, so please check the policy periodically for updates. Where applicable law requires your consent for a particular processing activity, we will obtain that consent as required.

Children’s and Minors’ Data

Our Services are not intended for, and we do not knowingly collect any personal data from, children under the age of 18. If we learn we have collected or received personal data from a child under 18 years old without verification of parental consent, we will delete that information.

The Personal Data That We Collect or Process

“Personal Data” means information that uniquely identifies, relates to, describes, or is reasonably capable of being associated with or linked to you. The types and categories of personal data we collect or process include:

• Contact Information – If you submit an inquiry, register for an account, or provide information on or through our Website, we may collect your contact information including your name, mailing address, email address, and phone number.
• Commercial Information – If you submit an inquiry, or provide information on our Website, we may collect commercial information including information about your business and any purchases, products, subscriptions, and services you have shown interest in.
• Usage Information – When you use our Website, we may automatically record information, including your Internet Protocol address (IP Address), geolocation of your device, browser type, referring URLs (e.g., the website you visited before coming to our Site), domain names associated with your internet service provider, and any other information regarding your interaction with our Website.
• Employment Information – If you apply for employment with us, we will collect Personal Data related to your potential employment, including your education and employment history, address and contact information, demographic information, and any other information included in your resume or application.
• Communication Information – We may collect Personal Data contained within your communications with us via email, social media, telephone, or otherwise, and in certain cases we may use third-party service providers to do so. Where permitted by applicable law, we may collect and maintain records of calls and chats with our agents, representatives, or employees via message, chat, post, or similar functionality.

Some of the information identified above may be considered sensitive data under certain laws. If required under applicable law, we will collect and process sensitive personal data only with your consent. If you choose not to provide or allow us to collect some information, we may not be able to provide you with requested features, services, or information.

We may also collect:

• Statistics or aggregated information – Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from personal data. For example, we may aggregate personal data to calculate the percentage of users accessing a specific Services feature.
• Technical information – Technical information includes information about your internet connection and usage details about your interactions with the Services, such as clickstream information to, through, and from our Website (including date and time), products that you view or search for; page response times, download errors, length of your visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), or methods used to browse away from a page.

If we combine or connect non-personal statistical or technical data with Personal Data so that it directly or indirectly identifies an individual, we treat the combined information as personal information.

How We Use Your Personal Data

To the extent permitted by applicable law, we use Personal Data:

• To provide, operate, and personalize our Website, such as responding to your inquiries and requests, providing information about our organization and offerings, verifying the information you provide, creating and maintaining business records, and undertaking similar activities.
• To optimize, improve, and maintain our Website, including understanding how users interact with our Website, gauging user interest in certain content or functionality, and troubleshooting problems.
• For internal research and development, such as testing, verifying, and improving the quality of our Services or developing new ones.
• For communicating with you, such as responding to your questions and comments or notifying you of changes to our Website or any services we offer or provide that may be of interest.
• For legal, security, or safety reasons, such as protecting our and our users’ safety, property, or rights; complying with legal requirements; enforcing our terms, conditions, and policies; detecting, preventing, and responding to security incidents; and protecting against malicious, deceptive, fraudulent, or illegal activity.
• As part of a corporate transaction, such as in connection with the sale of part or all of our assets or business, the acquisition of part or all of another business or another business’ assets, or another corporate transaction, including bankruptcy.
• To fulfill any other purpose for which you provide it, including purposes described when you provide the information or give your consent.
• If you are applying for employment with us, we also use Personal Data to process your job application, to verify the information you have provided in your application, conduct interviews, perform background and reference checks, to communicate with you and answer your questions, to confirm your eligibility for employment, and improve our recruiting processes. We may also save your Personal Data for future employment opportunities with us.

Large Language Model Training Disclosure

We do not collect, use, or sell personal data for the purpose of training large language models.

Who We Disclose Your Information To

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We do not sell your personal information to any third party. We may disclose Personal Data that we collect or you provide as described in this privacy policy:

• To our subsidiaries and affiliates.
• To contractors, service providers, and other third parties we use to support our organization, including but not limited to, data analytics providers, website hosting providers, and other technology providers. If you are applying for a job with us, this may include service providers such as background check providers and human resource providers.
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal data held by us is among the assets transferred.
• We may disclose Personal Data to a third party when we have a good faith belief that such disclosure of Personal Data is reasonably necessary to (a) satisfy or comply with any requirement of law, regulation, legal process, or enforceable governmental request, (b) enforce or investigate a potential violation of any agreement you have with us, (c) detect, prevent, or otherwise respond to fraud, security or technical concerns, (d) support auditing and compliance functions, or (e) protect the rights, property, or safety of Triumph, its employees and clients, or the public against harm.
• We may disclose Personal Data to third parties as necessary if we are involved in a merger, acquisition, or any other transaction involving our business, including but not limited to, a bankruptcy or similar proceeding.
• To fulfill the purpose for which you provide it.

Cookies and Other Website Technologies

As you navigate through and interact with our Website or Services, we and our service providers may use automatic data collection technologies to collect information that may include personal data. Information collected automatically may include usage details, IP addresses, operating system, and browser type, and information collected through cookies and other technologies. The technologies used for this automatic data collection may include:

• Cookies. A cookie is a small file placed on your device when you interact with the Services. You may refuse to accept or disable cookies by activating the appropriate setting on your browser or device. However, if you select this setting, you may be unable to access certain features of the Services.
• Google Analytics. To learn more about how Google uses data, visit Google’s Privacy Policy and Google’s page on How Google uses data from sites or apps that use our services. You may download the Google Analytics Opt-out Browser Add-on for each web browser you use, but this does not prevent the use of other analytics tools.

To the extent any of these automated technologies are considered a personal data sale, targeted advertising, or profiling, under applicable laws, depending on where you live, you may opt out from use of these automated technologies for such uses by emailing at info@triumpheducation.com.

Your Rights and Choices About Your Information

This section describes mechanisms you can use to control certain uses and disclosures of your information and rights you may have under state law, depending on where you live.

Advertising, marketing, cookies, and other tracking technologies choices:

Cookies and Other Tracking Technologies. You can set your browser to refuse all or some browser cookies or other tracking technology files, or to alert you when these files are being sent. Some browsers include a “Do Not Track” (DNT) setting that can send a signal to the online services you visit indicating you do not wish to be tracked. Because there is not a common understanding of how to interpret the DNT signal, our Services may not respond to all browser DNT signals. Instead, you can use the range of other tools to control data collection and use, including the cookie controls and advertising controls described in this policy.

Your State Privacy Rights

Depending on your state of residency, you may have certain rights related to your personal data, including:

• Access and Data Portability. You may confirm whether we process your personal data and access a copy of the personal data we process. To the extent feasible and required by state law, depending on your state, data will be provided in a portable format. Depending on your state, you may have the right to receive additional information and it will be included in the response to your access request.
• Correction. You may request that we correct inaccuracies in your personal data that we maintain, taking into account the information’s nature and processing purpose.
• Deletion. You may request that we delete personal data about you that we maintain, subject to certain exceptions under applicable law.
• Opt Out of Sale. We do not sell your personal information to any third party.
• Objection/Restriction of Processing. The right to object or restrict us from processing your Personal Information in certain circumstances.
• Withdraw Consent. The right to withdraw your consent where we are relying on your consent to process your Personal Data.
• Automated Decision-Making. The right to know when you are subject to automated decision-making, the Personal Data used to render the decision, the principal factors and parameters involved in the decision, and human review or correction of the decision (or its underlying data, where appropriate). You may also have the right to consent or opt out of this automated decision-making, depending on your location.
• Appeal. If we decline to take action on your request, you may have the right to appeal that decision within a reasonable period. We will respond to appeals as required by applicable law, and if an appeal is denied you may contact your state attorney general to submit a complaint.

Important: The exact scope of these rights varies by state. There are also several exceptions where we may not have an obligation to fulfill your request.

To exercise any of these rights, please email info@triumpheducation.com.

You will not be discriminated against in any way by virtue of your exercise of the rights listed in this Privacy Policy. However, should you withdraw your consent or object to processing of your Personal Data, or if you choose not to provide certain Personal Data, we may be unable to provide some, or all, of our services or Website features to you.

Some browsers and browser extensions support the Global Privacy Control (“GPC”) that can send a signal to process your request to opt out from certain types of data processing, including data “sales” as defined under certain laws. When we detect such a signal, we will make reasonable efforts to respect your choices indicated by a GPC setting as required by applicable law.

Information for California Consumers

If you are a California resident, additional information applies to you. The California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act (“CCPA”) grants a right of privacy certain rights and protections to California residents.

CCPA Rights: The CCPA provides certain rights and protections to California residents including: (a) the right to know and to request that we disclose the categories and specific pieces of personal information we have collected; (b) the right to request that we delete personal information we have collected from you; (c) the right to request that we correct inaccurate personal information; (d) the right to opt out of the “sale” or “sharing” of personal information, including for purposes of cross-context behavioral advertising; (e) the right to limit our use and disclosure of sensitive personal information to the uses permitted under the CCPA; and (f) the right not to receive discriminatory treatment for exercising any of these rights. “Personal information” is defined under the CCPA as “information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.”

California residents who would like to exercise these rights can do so by emailing us at info@triumpheducation.com. We will use your email address to verify your identity. Provided we are able to confirm your identity, we will respond within the time period provided by applicable law.

Limiting Use of Sensitive Personal Information: To the extent we collect sensitive personal information (as defined under the CCPA), you have the right to direct us to limit our use and disclosure of that information to the uses permitted under the CCPA.

Do Not Sell or Share My Personal Information: We do not sell or share your personal information to any third party for purposes of cross-context behavioral advertising.

Verification and Authorized Agents: To protect your information, we will take steps to verify your identity before responding to a request, which may include asking you to provide or confirm information we already maintain about you. You may use an authorized agent to submit a request on your behalf; we may require the authorized agent to provide proof that you gave the agent signed permission to submit the request and may require you to verify your own identity directly with us.

Non-Discrimination: We will not discriminate against you for exercising any of your privacy rights, including by denying you goods or services, charging you different prices, or providing you a different level or quality of goods or services, except as permitted by law.

How We Protect Your Personal Data

We use commercially reasonable administrative, physical, and technical measures designed to protect your personal data from accidental loss or destruction and from unauthorized access, use, alteration, and disclosure. However, no website, mobile application, system, electronic storage, or online service is completely secure, and we cannot guarantee the security of your personal data transmitted to, through, using, or in connection with the Services. In particular, email, texts, and chats sent to or from the Services may not be secure, and you should carefully decide what information you send to us via such communications channels. Any transmission of personal data is at your own risk.

The safety and security of your information also depends on you. You are responsible for taking steps to protect your personal data against unauthorized use, disclosure, and access.

How We Retain Your Personal Data

We keep the categories of personal data described in this policy for as long as reasonably necessary to fulfill the purposes described or for as otherwise legally permitted or required, such as maintaining the Services, operating our organization, complying with our legal obligations, resolving disputes, and for safety, security, and fraud prevention. This means that we consider our legal and business obligations, potential risks of harm, and nature of the information when deciding how long to retain personal data. At the end of the retention period, personal data will be deleted, destroyed, or deidentified.

International Use and Cross-Border Data Transfers

If you are visiting our Site from outside of the United States, please note that our Website is hosted in the United States and intended specifically for U.S. users. Where permitted by applicable law, we may transfer the Personal Data we collect about you to the United States and other jurisdictions that may not be deemed to provide the same level of data protection as your home country, as necessary for the purposes set out in this Privacy Policy.

Changes to Our Privacy Policy

We may update this policy from time to time, and we will provide notice of any such changes to the policy as required by law. The date the privacy policy was last updated is identified at the top of the page. We will notify you of changes to this policy by updating the “last updated” date and posting the updated policy on the Services. We may email or otherwise communicate reminders about this policy, but you should check our Services periodically to see the current policy and any changes we have made to it.

Contact Information

To exercise your rights or ask questions or comment about this privacy policy or our privacy practices, contact us at: info@triumpheducation.com.