Summer Institute for the Gifted Privacy Policy

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Summer Institute for the Gifted a is a program of the American Institute for Foreign Study Foundation, Inc (“SIG”). Our contact details are at the end of this Policy (see HOW TO CONTACT SIG below).

SIG takes your privacy very seriously and is committed to protecting and respecting your privacy. This Policy, together with a) our Website Terms of Use, b) our Cookie Policy, c) our SIG Student Agreement (described in OTHER TERMS WHICH MAY APPLY TO YOU below), applies to personal information that we and/or third party Partners acting on our behalf (“our Partners”) collect about you.

Where we refer to the “Summer Institute for the Gifted Website” in this Policy, we mean the website which can be accessed at https://www.giftedstudy.org website operated by us (including any updates or supplements to them), and where we refer to the “Program”, we mean the Summer Institute for the Gifted program.

Please read this Policy carefully to understand our views and practices regarding your personal information and how we will treat it.

 

TOPICS COVERED:

WHO THIS POLICY APPLIES TO

This Policy applies to:

  • “SIG Students/Parents”, i.e. someone who applies to the Program to become a SIG Student or the parent of someone who applies to the Program to become a SIG Student and/or who takes part in the Program as a SIG Student;
  • “Visitors” to the Summer Institute for the Gifted Website, i.e. someone who visits and/or uses the Summer Institute for the Gifted but who does not register for or apply to the Program.

Unless we say otherwise, the terms of this Policy apply to all SIG Students/Parents and Visitors.

 

OTHER TERMS WHICH MAY APPLY TO YOU

This Policy refers to the following additional terms, which also apply to your use of the Summer Institute for the Gifted Website and, if applicable, your participation in the Program:

WEBSITE TERMS OF USE

Our “Website Terms of Use” govern your use of the Summer Institute for the Gifted Website.

COOKIE POLICY

Our “Cookie Policy” sets out information about the cookies we use on the Summer Institute for the Gifted Website.

SIG STUDENT AGREEMENT

If you are a SIG Student/Parent, as part of your application to the Program, we will ask you to read, acknowledge and sign our terms and conditions for SIG Students/Parents (the “SIG Student Agreement”).

 

INFORMATION WE COLLECT (INCLUDING WHEN AND HOW WE COLLECT IT)

We collect the following personal information from and about you:

  1. Information you give us
  2. Information we collect when you visit the Summer Institute for the Gifted Website
  3. Information provided by third parties

Information you give us.You may give us information about you:

  • when you register your interest in or apply to take part in the Program;
  • when you take part in the Program;
  • when you use the Summer Institute for the Gifted Website, for example, if you upload any documents or files that contain personal information;
  • if you complete a survey or provide feedback on the Summer Institute for the Gifted Website;
  • when you report a problem with the Summer Institute for the Gifted Website; and
  • if you contact or correspond with us (for example, by phone, e-mail or otherwise) for any other reason.

Information we collect when you visit the Summer Institute for the Gifted Website. Each time you visit the Summer Institute for the Gifted Website, we will automatically collect the following:

  • certain technical information, for example, the type of device (and its unique device identifier) you use to access the Summer Institute for the Gifted Website, the internet protocol (IP) address used to connect your device to the internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system, mobile network information and platform;
  • information about your visit to the Summer Institute for the Gifted Website, including the full Uniform Resource Locators (URL), clickstream to, through and from the Summer Institute for the Gifted Website (including date and time), pages you viewed, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page; and
  • certain cookies that are capable of identifying your device (see our Cookie Policy to understand which cookies the Summer Institute for the Gifted Website uses).

Information provided by third parties.

If you are a SIG Student/Parent:
when taking part or after taking part in the Program:

  • we may obtain feedback, comments or complaints about you and/or others taking part in the Program.

 

HOW WE USE YOUR INFORMATION AND OUR LEGAL BASIS FOR DOING SO

We collect personal information so that we can operate effectively and provide you with the best possible service. The information we process depends on the context of your interactions with us, with our Partners and with the Summer Institute for the Gifted Website, and your involvement in the Program. It also depends on the choices you make, for example the consents you provide, the functions you use and the privacy settings you select. You may choose not to provide or allow us to collect certain information, but if this is the case, we may be not be able to consider you for the Program (where that information is necessary for us to do so). We will only process personal information where we have a valid lawful basis to do so.

How we use your information:

If you are a SIG Student/Parent:

All of the information that you submit as a part of your SIG student application and any additional documents submitted on the SIG Student Portal, will be shared with SIG staff.

If you are a Visitor to the SIG Website:

Anonymous information to analyze traffic to the Summer Institute for the Gifted Website.

More about the information we use and why

Where we have a legal basis to use your personal information without consent (as we have described above), this Policy fulfills our duty to process personal information transparently, and helps us to do so fairly and lawfully and in a manner that you would expect given the nature of our relationship with you, by giving you appropriate notice and explanation of the way in which your personal information will be used.

Where consent is required for our use of your personal information, we will ask you to positively opt-in by ticking the appropriate consent box or otherwise communicating your consent. For example, if you are a SIG Student/Parent, we will only share your full application if you consent when we first collect this information from you as part of your application to the Program, and you may withdraw this consent at any time prior to your enrollment in the program. Once you are an active participant in the program, you must remain in contact with SIG so we can administer the program for you.

Where you provide us with personal information relating to other individuals (for example, if you are a SIG Student/Parent and you give us your emergency contact’s name and telephone number), you must obtain the consent of those individuals before doing so.

If you have any questions or require any further information regarding our use of personal information please contact our data protection officer (see HOW TO CONTACT SIG).

SHARING YOUR INFORMATION

We may share your personal information with your consent or as is necessary with selected third party service providers, and other companies within our group that support us in the performance of the activities set out in the tables above.

We require all our third party service providers and all other companies within our group to take appropriate and stringent security measures to protect your personal information in line with our policies. We do not allow our third party service providers to use your personal information for their own purposes and we only permit them to process your personal information for specified purposes in accordance with our instructions.

We may also need to share your personal information with a regulator or otherwise to comply with the law or to respond to valid legal process, including from law enforcement or other government agencies.

Why might you share my personal information with third parties?

We may share your personal information with third parties where it is necessary in order to consider you for the Program, where required by law (as above), or where we have another legitimate interest in doing so that is not overridden by your interests and fundamental rights. (For example, to operate and maintain the security of our computer systems.)

We may share your health and medical information with medical professionals in case of a medical emergency while you are on the program.

Who will you share my personal information with?

We will share - and, in some cases, you will provide - certain information about you with and to the following third parties for purposes specified:

  • we use Google to track your usage of the Summer Institute for the Gifted website. We do so to improve our users’ experience of the Summer Institute for the Gifted website.

In addition, if you are an applicable SIG Student/Parent:

  • we may share or ask you to share certain information (including your name, address, passport and/or visa details) with third party suppliers such as travel and accommodation providers (including airlines and hotels); insurance providers; embassies; and border control agencies, who will process that information. We do so to facilitate your travel (if needed) to and from the U.S. and your stay in the U.S. as part of your participation in the Program;
  • we may share or ask you to share certain information (including your name, address, passport and/or visa details) with embassies and government departments (including the Student Exchange Visitor Information Service (SEVIS) – US Department of State); who will process that information. We do so to progress your visa application and to comply with visa regulations as part of your participation in the Program.

 

RETAINING YOUR INFORMATION

We will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including to satisfy any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of your information, the purposes for which we process your information and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances we may anonymize your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Even if you request that we erase your information, we may still need to keep it (see YOUR RIGHTS) or may keep it in a form that does not identify you.

The following retention periods will apply, unless we inform you otherwise (or you request that we erase your information).
If you are a SIG Student/Parent and you:

  • register your interest in or apply to take part in the Program but do not take part in the Program, we may retain some of your personal information (including your name and contact information you provided) for a period of 7 years following the date when you first complete your registration and/or application; or
  • take part in the Program, we will process your personal information while you take part in the Program, and may retain some of your information for a period of 7 years thereafter, for example, to keep in touch with you and/or for legal reasons. We will only retain information as necessary.

If you are a Visitor and you do not use the Summer Institute for the Gifted Website for 1 year, then we will erase your information.

We may keep certain information for longer periods than those stated above if you have agreed to us using it, for example, for keeping in touch about our services or for our promotional purposes (such as part of a blog post on the Summer Institute for the Gifted Website).

Please contact our data protection officer if you would like further details on how long we retain your information (see HOW TO CONTACT SIG).

 

TRANSFERRING YOUR INFORMATION OVERSEAS

This section is only relevant to SIG Students/Parents or Visitors based in the European Economic Area (“EEA”).

If you are a SIG Student/Parent based in the EEA, we will transfer, process and store the information we collect from you to SIG and other relevant third parties based in the U.S. i.e. outside of the EEA. We do so as it is necessary for us to consider you for the Program, and so that you can take part in the Program.

If you are a Visitor based in the EEA, we will transfer, process and store the information we collect from you to SIG and other relevant third parties based in the U.S. We do so as it is necessary for us to understand how the Summer Institute for the Gifted Website is used and so that we can improve the Summer Institute for the Gifted Website.

In each case, we will take all steps reasonably necessary to ensure that your personal information receives an adequate level of protection and is treated in a way consistent with EU laws on data protection.

 

KEEPING YOUR INFORMATION SECURE

All personal information that you provide to us is stored on secure servers. We have put in place (and require anyone we share your information with to put in place) appropriate measures to protect the security of your information.

In addition, we limit access to your information to those of our employees, Partners, contractors and other third parties who have a business need to know. We will require them only to process your information on our instructions and they are subject to a duty of confidentiality.

You should be aware that the transmission of information via the internet is not completely secure. Although we will do our best to protect your information, we cannot guarantee the security of the information transmitted to the Summer Institute for the Gifted Website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access or inadvertent disclosure.

We have also put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

 

UPDATING AND ACCESSING YOUR INFORMATION

You have the right under data protection laws to access personal information held about you, subject to certain conditions, and to request its rectification or deletion.

If you would like to access or amend the personal information which we hold about you or you would like us to stop using your personal information, please contact our data protection officer (see HOW TO CONTACT SIG).

Alternatively, if you are a SIG Student/Parent and you have completed an application to take part in the Program, you can access and amend most of your personal information by signing in to your account on the Summer Institute for the Gifted Portal. However, once we have shared your personal information as described in SHARING YOUR INFORMATION above, you will be unable to amend that information by signing in to your account. If you would like to amend any of your personal information but you are unable to do so by signing in to your account on the Summer Institute for the Gifted Website, please contact our data protection officer (see HOW TO CONTACT SIG).

To learn more about the rights you may have in relation to your personal information see YOUR RIGHTS.

Once you are enrolled as a participant in the program, SIG and your Partner organization must be able to remain in contact with you for the duration of the program until your departure from the U.S.

 

YOUR RIGHTS

By law you have the right to:

  • request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it. We will need to prove your identity before we release any personal information to you.
  • request correction or erasure of your personal information unless we have the legal right to retain it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
  • object to processing of your personal information where we are relying on a legitimate interest (or that of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
  • request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
  • request the transfer of your personal information to another party.
  • change your information processing preferences at any time (where this specifically relates to marketing messages, see MARKETING).

You should be aware that if you ask us to stop processing your personal information in a certain way or to erase your personal information, and this type of processing is necessary to consider you for the Program or for you to participate in the Program, we may not be able to do so. This does not include your right to object to direct marketing, which can be exercised at any time without restriction.

If you want to exercise any of the rights listed above, please contact our data protection officer (see HOW TO CONTACT SIG).

No fee usually required

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
Where you have provided your consent to the collection, use or transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact our data protection officer (see HOW TO CONTACT SIG). Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

 

MARKETING

If you are a SIG Student/Parent, we would like to send you information by email SMS and/or via social media about opportunities or services of ours and other companies in our group which may be of interest to you (including, for example promotional materials and newsletters). We will ask whether you would like us to send you these messages when you apply to take part in the Program.

You have the right at any time to stop us from contacting you for marketing purposes or giving your information to other members of our group. If you no longer wish to be contacted for marketing purposes, you can unsubscribe by using the “unsubscribe” link at the bottom of our marketing messages or by contacting our data protection officer (see HOW TO CONTACT SIG).

We will not provide your personal information to any other third party businesses for marketing purposes.

 

OTHER WEBSITES

The Summer Institute for the Gifted Website contains links to other websites, including Facebook, Twitter and Instagram. This Policy only applies to the Summer Institute for the Gifted Website so when you link to other websites you should read their own privacy policies.

 

CHANGES TO THIS POLICY

We keep this Policy under regular review and will post any updates on this webpage. This Policy was last updated in May 2018.

 

HOW TO CONTACT SIG

SIG is the data controller in respect of your personal information and is registered with the UK Information Commissioner’s Office with registration number Z6393161. AYA UK’s registered office is 37 Queen's Gate, London, SW7 5HR.

We have appointed Gene Maillet as our USA Data Protection officer and Richard Howell as our UK data protection officer to oversee compliance with this Policy. If you have any questions about this Policy or how we handle your personal information please contact our data protection officer at dpo@AYA.co.uk, +44 20 7581 7300, 37 Queens Gate, London SW7 5HR, United Kingdom.

Complaints

If for any reason you are not happy with the way that we have handled your personal information please contact us at dpo@AYA.co.uk, +44 20 7581 7300, 37 Queens Gate, London SW7 5HR, United Kingdom. If you are still not happy, you have the right to make a make a complaint to the Information Commissioner’s Office see: https://ico.org.uk/global/contact-us/.

 

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