Privacy Policy for GIU LMS Mobile Application

Effective Date: 21/8/2025
Last Updated: 21/8/2025

1. Introduction

Graham International University (“GIU,” “we,” “us,” or “our”) is committed to protecting the privacy and security of users of our GIU LMS mobile application (the “App”). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile learning management system application.

This Privacy Policy applies to all users of the GIU LMS mobile application, including students, faculty, administrators, and other authorized users. By downloading, installing, accessing, or using the App, you agree to the collection and use of information in accordance with this Privacy Policy.

2. Information We Collect

2.1 Personal Information

We may collect personally identifiable information that you provide directly to us, including but not limited to:

  • Account Information: Full name, email address, username, and encrypted password
  • Educational Information: Program enrollments, academic records, grades, assignments, quiz responses, discussion forum posts, academic progress, and learning analytics
  • Contact Information: Phone number.
  • Profile Information: Profile picture, bio, and other profile customizations
  • Communication Data: Messages sent through the App’s notification system, forum discussions, comments, and support communications

2.2 Technical Information

When you use our App, we automatically collect certain technical information:

  • Device Information: Device type, operating system version, unique device identifiers, mobile network information, hardware model
  • App Usage Data: Features accessed, time spent in the App, frequency of use, interaction patterns, navigation paths
  • Log Information: IP addresses, access times, App crashes, error logs, performance data
  • Location Information: General location data (if location services are enabled) for campus-specific features
  • Network Information: Internet service provider, connection type, network performance metrics

2.3 Educational Content and Submissions

  • Program materials accessed and downloaded
  • Assignment submissions and file uploads
  • Quiz and exam responses
  • Video lecture viewing progress and engagement metrics
  • Research data and academic work submitted through the App
  • Participation in online discussions and collaborative activities

2.4 Cookies and Tracking Technologies

The App may use cookies, web beacons, pixel tags, and similar tracking technologies to:

  • Remember user preferences and settings
  • Analyze App performance and user behavior
  • Provide personalized content and recommendations
  • Maintain security and prevent fraud

3. How We Use Your Information

3.1 Educational Purposes

  • Providing access to program content, materials, and learning resources
  • Facilitating online learning activities, assignments, and assessments
  • Tracking academic progress and generating performance reports
  • Enabling communication between students, faculty, and administrators
  • Supporting collaborative learning and group projects
  • Customizing learning experiences based on individual needs and preferences

3.2 Administrative Purposes

  • Managing user accounts and authentication
  • Maintaining academic records and transcripts
  • Processing enrollments and program registrations
  • Generating academic reports and analytics
  • Facilitating degree audits and graduation requirements
  • Supporting academic advising and student services

3.3 Technical and Operational Purposes

  • Ensuring App functionality and performance optimization
  • Providing technical support and troubleshooting
  • Conducting security monitoring and fraud prevention
  • Analyzing usage patterns to improve user experience
  • Developing new features and services
  • Maintaining system backups and disaster recovery

3.4 Communication Purposes

  • Sending program-related notifications and announcements
  • Providing important academic and administrative updates
  • Facilitating student-faculty communication
  • Delivering technical support and customer service
  • Sending surveys and feedback requests (with your consent)

3.5 Legal and Compliance Purposes

  • Complying with educational regulations and accreditation requirements
  • Meeting legal obligations and responding to lawful requests
  • Protecting the rights and safety of users and the institution
  • Enforcing our Terms of Service and other policies
  • Conducting investigations into violations of academic integrity

4. Information Sharing and Disclosure

4.1 Within the Educational Institution

We may share your information with:

  • Faculty and Instructors: For educational purposes, grading, and academic support
  • Academic Administrators: For enrollment management, academic planning, and student services
  • IT Support Staff: For technical assistance and system maintenance
  • Student Services Personnel: For advising, counseling, and support services
  • Authorized Researchers: For educational research purposes (with appropriate anonymization)

4.2 Third-Party Service Providers

We may share information with trusted third-party service providers who assist us in:

  • Cloud hosting and data storage services
  • App development and maintenance
  • Analytics and performance monitoring
  • Communication and notification services
  • Backup and security services

All third-party service providers are contractually required to maintain the confidentiality and security of your information and are prohibited from using it for any purpose other than providing services to us.

4.3 Legal Requirements

We may disclose your information when required by law or when we believe disclosure is necessary to:

  • Comply with legal process, court orders, or government requests
  • Protect the rights, property, or safety of GIU, our users, or others
  • Enforce our Terms of Service or other agreements
  • Investigate potential violations of academic integrity or institutional policies
  • Respond to claims of illegal activity or infringement

4.4 Business Transfers

In the event of a merger, acquisition, or sale of assets, user information may be transferred as part of the transaction, subject to appropriate confidentiality protections.

4.5 Consent-Based Sharing

We may share your information with your explicit consent for purposes such as:

  • Sharing academic achievements with external organizations
  • Participating in inter-institutional programs or research
  • Connecting with alumni networks or professional organizations

5. Data Security

5.1 Security Measures

We implement comprehensive security measures to protect your information:

  • Encryption: Data is encrypted in transit using industry-standard TLS encryption and at rest using strong encryption algorithms
  • Access Controls: Role-based access controls ensure only authorized personnel can access your information
  • Authentication: Multi-factor authentication and strong password requirements for administrative access
  • Network Security: Firewalls, intrusion detection systems, and regular security monitoring
  • Regular Audits: Periodic security assessments and vulnerability testing
  • Staff Training: Regular security training for all personnel with access to user data

5.2 Data Centers and Infrastructure

Our data is stored in secure, professionally managed data centers with:

  • 24/7 physical security and monitoring
  • Redundant power and network connectivity
  • Environmental controls and disaster recovery capabilities
  • Regular security certifications and compliance audits

5.3 Incident Response

We maintain an incident response plan to address potential security breaches, including:

  • Immediate containment and investigation procedures
  • User notification protocols as required by applicable laws
  • Remediation steps to prevent future incidents
  • Cooperation with law enforcement when necessary

6. Your Rights and Choices

6.1 Access and Correction

You have the right to:

  • Access your personal information stored in the App
  • Request corrections to inaccurate or incomplete information
  • Update your profile and contact information
  • Review your academic records and submissions

6.2 Data Portability

You may request a copy of your personal information in a portable format, subject to technical limitations and applicable laws.

6.3 Deletion Rights

You may request deletion of your personal information, subject to:

  • Legal and regulatory requirements for record retention
  • Academic record-keeping obligations
  • Ongoing educational relationships and requirements

6.4 Communication Preferences

You can control certain communications by:

  • Adjusting notification settings within the App
  • Opting out of non-essential communications
  • Managing email preferences through your account settings

6.5 Location Services

You can control location data collection by:

  • Disabling location services in your device settings
  • Adjusting location permissions for the App
  • Opting out of location-based features

7. Children’s Privacy

7.1 Age Restrictions

The GIU LMS App is designed primarily for higher education students and is not intended for children under 13 years of age. We do not knowingly collect personal information from children under 13.

7.2 Parental Consent

If we become aware that we have collected personal information from a child under 13 without parental consent, we will take steps to delete such information promptly.

7.3 Educational Exception

In cases where minors are enrolled in university programs, we collect and use information solely for educational purposes under the supervision of the educational institution and with appropriate parental awareness.

8. International Data Transfers

8.1 Cross-Border Transfers

Your information may be transferred to and processed in countries other than your country of residence. We ensure appropriate safeguards are in place for such transfers, including:

  • Standard contractual clauses approved by regulatory authorities
  • Adequacy decisions by relevant data protection authorities
  • Other legally recognized transfer mechanisms

8.2 Data Protection Standards

We maintain consistent data protection standards across all jurisdictions where we operate, ensuring your information receives appropriate protection regardless of location.

9. Data Retention

9.1 Retention Periods

We retain your information for different periods based on the type of data and purpose:

  • Account Information: Retained while your account is active and for a reasonable period thereafter
  • Academic Records: Retained in accordance with educational record-keeping requirements and accreditation standards
  • Communication Data: Retained for the duration of your academic relationship and as required by institutional policies
  • Technical Logs: Typically retained for 12-24 months for security and troubleshooting purposes

9.2 Retention Criteria

Retention periods are determined based on:

  • Legal and regulatory requirements
  • Academic and institutional policies
  • Legitimate business interests
  • User preferences and requests

9.3 Secure Disposal

When information is no longer needed, we securely dispose of it using industry-standard methods to prevent unauthorized access or recovery.

10. Third-Party Links and Services

10.1 External Links

The App may contain links to external websites, services, or resources not operated by GIU. We are not responsible for the privacy practices of these third-party services and encourage you to review their privacy policies.

10.2 Third-Party Integrations

The App may integrate with third-party educational tools and services. Such integrations are subject to the privacy policies of the respective third parties, and we encourage you to review these policies.

10.3 Social Media Features

If the App includes social media features or widgets, these features may collect information about your interactions and are governed by the privacy policies of the respective social media platforms.

11. Updates to This Privacy Policy

11.1 Policy Changes

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of material changes through:

  • In-app notifications
  • Email communications to your registered address
  • Updates posted on our website at https://university.fgjf.org/

11.2 Effective Date

Changes to this Privacy Policy will become effective on the date specified in the updated policy. Your continued use of the App after the effective date constitutes acceptance of the updated policy.

11.3 Version Control

We maintain version control of our Privacy Policy to ensure transparency about changes and enable users to review previous versions if needed.

12. Regional Privacy Rights

12.1 European Union (GDPR)

If you are located in the European Union, you have additional rights under the General Data Protection Regulation, including:

  • Right to be informed about data processing
  • Right of access to your personal data
  • Right to rectification of inaccurate data
  • Right to erasure (“right to be forgotten”)
  • Right to restrict processing
  • Right to data portability
  • Right to object to processing
  • Rights related to automated decision-making

12.2 California (CCPA)

If you are a California resident, you have rights under the California Consumer Privacy Act, including:

  • Right to know what personal information is collected
  • Right to delete personal information
  • Right to opt-out of the sale of personal information
  • Right to non-discrimination for exercising privacy rights

12.3 Other Jurisdictions

We comply with applicable privacy laws in all jurisdictions where we operate and will extend similar rights to users as required by local regulations.

13. Contact Information

13.1 Privacy Questions

If you have questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us:

Graham International University
U.S.A. Office – Sacramento, California
Email:frankiegrahamjr@fgjf.org

Website: https://university.fgjf.org/

14. Definitions

“App” refers to the GIU LMS mobile application available for download on mobile devices.

“Personal Information” means information that identifies, relates to, describes, or is capable of being associated with a particular individual.

“Processing” means any operation performed on personal information, including collection, use, storage, disclosure, and deletion.

“Third Party” means any individual or entity other than GIU and you.

“User” means any individual who downloads, installs, accesses, or uses the App.

Acknowledgment: By using the GIU LMS mobile application, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy.

Last Updated: 21/8/2025
Version: 1.0

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