EFFECTIVE DATE: January 15, 2019
By visiting the Site, using or downloading the Application, or using any of our Services, you acknowledge that your personal information will be handled as described in this Policy. Your use of our Site or Services, and any dispute over privacy, is subject to this Policy and our Terms of Service , including its applicable limitations on damages and the resolution of disputes. The IBSC Terms of Service are incorporated by reference into this Policy.
- The Information We Collect About You
- How We Use Your Information
- How We Share Your Information
- Third-Party Links
- Security of My Personal Information
- Access To My Personal Information
- What Choices Do I Have Regarding Promotional Emails?
- Children Under 13
- Contact Us
- Changes to this Policy
- Additional Information for EU Individuals
1. THE INFORMATION WE COLLECT ABOUT YOU
We collect information about you directly from you and from third parties, as well as automatically through your use of our App, Site, and Services.
Information We Collect from Our Member Organizations. Our member schools and organizations provide us with information about their respective employees and administrators that will participate in IBSC activities. For example, to create an account for the Site, our members provide us with the name, business email address, and school/organization name of the respective individual(s) who will access the member-areas of the Site.
Information We Collect Directly From You. The information we collect from you depends on how you use our Site, App, and Services.
- Users and Visitors of Our Site. If you log in to a member-area part of the Site, we will collect your assigned username and password. Member users also may provide additional information about their account, including a photo, title, nickname, and additional email addresses. If you contact us through the Site, we will collect your email address and your messages to us.
- Individual Memberships. If you become an IBSC member as an individual (and not through a school or organization), we will collect your name, address, contact information, your research role in boys’ education, your professional information (title, business information), and your payment information. If you do not provide us with this information, we will be unable to process your membership application.
- Conferences, Events and Online Courses. To register as an attendee for our conferences, events or online courses, whether through our Site or by contacting us directly, we will collect your name, business contact information, mobile phone number, emergency contact information, payment information, and, if applicable, your meal preferences. If you do not provide us with this information, you will be unable to sign up for our events.
- Users of our App. Our App provides information about our annual conference. App users may voluntarily create an App profile by providing their name, email address, school or organization information, job title, phone number, and links to their social media profiles.
Information We Collect Automatically. We automatically collect information about your use of our Site and Apps through cookies, web beacons, and other technologies, including technologies designed for mobile apps. To the extent permitted by applicable law, we may combine this information with other information we collect about you, including your personal information. Please see the section “Cookies and Other Tracking Mechanisms” below for more information.
- your domain name;
- your browser type and operating system;
- web pages you view;
- links you click; your IP address;
- the length of time you visit our Site and/or use our Services; and
- the referring URL, or the webpage that led you to our Site.
- mobile device ID;
- location and language information;
- device name and model;
- operating system type, name, and version;
- your activities within the Application; and the length of time that you are logged into our Application.
2. HOW WE USE YOUR INFORMATION
We use your information, including your personal information, for the following purposes:
- To provide our services to you, to communicate with you about your use of our services, to respond to your inquiries, to fulfill your orders, and for other customer service purposes.
- To tailor the content and information that we may send or display to you, to offer personalized help and instructions, and to otherwise personalize your experiences while using the Site, App, or our services.
- For marketing and promotional purposes. For example, we may use your information, such as your email address, to send you news and newsletters, special offers, and promotions, or to otherwise contact you about products or information we think may interest you, including information about third parties’ products and services.
- To administer surveys and questionnaires, such as for market research or member satisfaction purposes.
- To better understand how users access and use our Site, App, and Services, both on an aggregated and individualized basis, in order to improve our Site, App, and Services and respond to user desires and preferences, and for other research and analytical purposes.
- To comply with legal obligations, as part of our general business operations, and for other business administration purposes.
3. HOW WE SHARE YOUR INFORMATION
We may share your information, including personal information, as follows:
- Conference Attendees and Presenters. We share information about our annual conference attendees, such as their names, organizations, and business email addresses, with other attendees and conference sponsors through our Site. Via our App, conference presenters’ names are shared with App users, and attendees may opt in to share their information with App users.
- Event Hosts and Sponsors. Unless you opt-out of such sharing, we may share event attendees’ information with conference and event sponsors. This may include attendees names, titles, school/organization name and location. To opt-out of this type of sharing, please contact IBSC@theibsc.org. We also share event attendee information with the hosting location for security purposes. If your institution is hosting an IBSC event, and you have been designated a point of contact for information about that event, we may share this information with the public through our Site, App, and Services. We may share your information to enable attendees (members of the public) to contact you, such as your name, email address, phone number, job title, and name of institution.
- Affiliates. We may disclose the information we collect from you to our affiliates or subsidiaries; however, if we do so, their use and disclosure of your personally identifiable information will be subject to this Policy.
- Service Providers. We may disclose the information we collect from you to third party vendors, service providers, contractors or agents who perform functions on our behalf.
We also disclose information in the following circumstances:
- Business Transfers. If (i) we or our affiliates are or may be acquired by, merged with, or invested in by another organization, or (ii) if any of our assets are or may be transferred to another organization, whether as part of a bankruptcy or insolvency proceeding or otherwise, we may transfer the information we have collected from you to the other organization. As part of the business transfer process, we may share certain of your personal information with lenders, auditors, and third party advisors, including attorneys and consultants.
- In Response to Legal Process. We also may disclose the information we collect from you in order to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a court order or a subpoena.
- To Protect Us and Others. We also may disclose the information we collect from you where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Service or this Policy, or as evidence in litigation in which IBSC is involved.
- Aggregate and De-Identified Information. We may share aggregate or de-identified information about users with third parties for marketing, advertising, research or similar purposes.
Cookies. Cookies are alphanumeric identifiers that we transfer to your device’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Site and Services, while others are used to enable a faster log-in process or to allow us to track your activities at our Site and Service. There are two types of cookies: session and persistent cookies.
- Session Cookies. Session cookies exist only during an online session. They disappear from your device when you close your browser or turn off your device. We use session cookies to allow our systems to uniquely identify you during a session or while you are logged into the Site. This allows us to process your online transactions and requests and verify your identity, after you have logged in, as you move through our Site.
- Persistent Cookies. Persistent cookies remain on your device after you have closed your browser or turned off your device. We use persistent cookies to track aggregate and statistical information about user activity.
Disabling Cookies. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Site who disable cookies will be able to browse certain areas of the Site, but some features may not function.
Clear GIFs, pixel tags and other technologies. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your device’s hard drive, clear GIFs are embedded invisibly on Site or App pages. We may use clear GIFs (a.k.a. web beacons, web bugs or pixel tags), in connection with our Site and App to, among other things, track the activities of Site visitors and App users, help us manage content, and compile statistics about usage of our Site and App. We and our third party service providers also use clear GIFs in HTML emails to our customers, to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.
Do Not Track. Currently, our systems do not recognize browser “do-not-track” requests. You may, however, disable certain tracking as discussed in this section (e.g., by disabling cookies).
Users in the United States may opt out of many third-party ad networks. For example, you may go to the Digital Advertising Alliance (“DAA”) Consumer Choice Page for information about opting out of interest-based advertising and their choices regarding having information used by DAA companies. You may also go to the Network Advertising Initiative (“NAI”) Consumer Opt-Out Page for information about opting out of interest-based advertising and their choices regarding having information used by NAI members. If you are in the European Union, you may opt-out of certain third party cookies that we and other websites may use for targeted advertising through the European Interactive Digital Advertising Alliance (EDAA) Your Online Choices Page or www.aboutads.info.
Opting out from one or more companies listed on the DAA Consumer Choice Page or the NAI Consumer Opt-Out Page will opt you out from those companies’ delivery of interest-based content or ads to you, but it does not mean you will no longer receive any advertising through our Site or on other websites. You may continue to receive advertisements, for example, based on the particular website that you are viewing (i.e., contextually based ads). Also, if your browsers are configured to reject cookies when you opt out on the DAA, NAI or EDAA websites, your opt out may not be effective. Additional information is available on the DAA’s website at www.aboutads.info, the NAI’s website at www.networkadvertising.org, or the EDAA’s website www.edaa.eu.
5. THIRD-PARTY LINKS
Our Site, App, and Services may contain links to third-party websites. Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those third party websites. We are not responsible for the information practices of such third party websites.
6. SECURITY OF YOUR PERSONAL INFORMATION
We have implemented reasonable precautions to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our efforts, no data security measures can guarantee security.
You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.
7. ACCESS TO YOUR PERSONAL INFORMATION
If you have a user account for the Site, you may modify the personal information that you have submitted by logging into your account and updating your profile information. Please note that copies of information that you have updated, modified or deleted may remain viewable in cached and archived pages of the Site for a period of time.
If you are a resident of the European Union, please see the Additional Information for EU Individuals section below for additional information on accessing your information and other legal rights available to you under European Union law.
8. WHAT CHOICES DO I HAVE REGARDING Promotional Emails?
In accordance with applicable law, we will send periodic promotional emails to you. You may opt-out of promotional communications by following the opt-out instructions contained in the email. Please note that it may take up to 10 business days for us to process opt-out requests. If you opt-out of receiving promotional emails about recommendations or other information we think may interest you, we may still send you emails about your account or any services you have requested or received from us.
9. CHILDREN UNDER 13
Our Services are not designed for children under 13. If we discover that a child under 13 has provided us with personal information, we will delete such information from our systems.
10. CONTACT US
If you have questions about the privacy aspects of our Services or would like to make a complaint, please contact us at IBSC@theibsc.org
11. CHANGES TO THIS POLICY
This Policy is current as of the Effective Date set forth above. We may change this Policy from time to time, so please be sure to check back periodically. We will post any changes to this Policy on our Site and App. If we make any changes to this Policy that materially affect our practices with regard to the personal information we have previously collected from you, we will endeavor to provide you with notice in advance of such change by highlighting the change on our Site and App.
12. ADDITIONAL INFORMATION FOR EU INDIVIDUALS
The information we collect is controlled by International Boys School Coalition, which is headquartered in the United States at PO Box 3165, La Jolla, California, USA.
The Legal Bases for Using Your Personal Information. We collect your information as a data controller when we have a legal basis to do so. The following legal bases pertain to our collection of data:
- Our use of your personal information is in our legitimate interest as a not-for-profit organization (for example in order to make improvements to our offerings and services and to provide you with information you request); you have a right to object to processing as explained in the section below entitled Your Legal Rights;
- Our use of your personal information is necessary to perform a contract or take steps to enter into a contract with you (for example, to facilitate your individual membership with IBSC or if you attend one of our conferences or events); and/or
- Our use of your personal information is necessary to comply with a relevant legal or regulatory obligation that we have (for example, where we are required to disclose personal information to a court or tax authority).
- Our use of your personal information is in accordance with your consent (for example, when you consent to sharing your personal information with a third party for their own marketing).
If you would like to find out more about the legal bases on which we process personal information, please see Appendix A at the end of this policy or contact us using the details below.
Retention of Your Personal Information. We retain your personal information for as long as necessary to provide our services to you, to fulfil the purposes described in this Policy and/or our business purposes, or as required by law, regulation, or internal policy.
Your Legal Rights. Subject to certain exemptions, and in some cases dependent upon the processing activity we are undertaking, when IBSC acts as a data controller, European Union individuals have certain rights in relation to their personal information:
Right to access, correct, and delete your personal information: You have the right to request access to the personal information that we hold about you and: (a) the source of your personal information; (b) the purposes, legal basis and methods of processing; (c) the data controller’s identity; and (d) the entities or categories of entities to whom your personal information may be transferred.
You also have the right to request that we delete your information.
We are not required to comply with your request to erase personal information if the processing of your personal information is necessary for compliance with a legal obligation or for the establishment, exercise, or defense of legal claims.
Right to restrict the processing of your personal information: You have the right to restrict the use of your personal information when (i) you contest the accuracy of the data; (ii) the use is unlawful but you do not want us to erase the data; (iii) we no longer need the personal information for the relevant purposes, but we require it for the establishment, exercise, or defense of legal claims; or (iv) you have objected to our personal information use where such use is justified on our legitimate interests and we must verify as to whether we have a compelling interest to continue to use your data.
We can continue to use your personal information following a request for restriction, where:
- we have your consent; or
- to establish, exercise, or defend legal claims; or
- to protect the rights of another natural or legal person.
Right to data portability: To the extent that we process your information (i) based on your consent or under a contract; and (ii) through automated means, you have the right to receive such personal information in a structured, commonly used, machine-readable format, or you can ask to have it transferred directly to another data controller.
Right to object to the processing of your personal information: You can object to any processing of your personal information which has our legitimate interests as its legal basis, if you believe your fundamental rights and freedoms outweigh our legitimate interests. If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.
Right to obtain a copy of personal information safeguards used for transfers outside your jurisdiction: You can ask to obtain a copy of, or reference to, the safeguards under which your personal information is transferred outside of the EEA.
Right to lodge a complaint with your local supervisory authority: You have a right to lodge a complaint with your local supervisory authority if you have concerns about how we are processing your personal information.
We ask that you please attempt to resolve any issues with us first, although you have a right to contact your supervisory authority at any time.
How to Exercise Your Rights: If you would like to exercise any of the rights described above, please send us a request at IBSC@theibsc.org. In your message, please indicate the right you would like to exercise and the information that you would like to access, review, correct, or delete.
We may ask you for additional information to confirm your identity and for security purposes before disclosing the personal information requested to you. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.
We may not always be able to fully address your request, for example if it would affect the duty of confidentiality we owe to others or if we are legally entitled to deal with the request in a different way.
Cross-border Transfer of Information: We generally maintain servers and systems in the United States hosted by third party service providers. Our member schools and organizations may transfer personal information to us in the United States, and we also may subcontract the processing of your information to, or otherwise share your information with, other third parties in the United States or countries other than your country of residence. As a result, where the personal information that we collect through or in connection with the Site, App, or our services, or is provided to us by our member schools and organizations, is transferred to and processed in the United States or anywhere else outside the European Economic Area (EEA) for the purposes described above, we will take steps to ensure that the information receives the same level of protection as if it remained within the EEA, including entering into data transfer agreements, using the EU Commission approved Standard Contractual Clauses, or by relying on certification schemes such as the E.U. – U.S. Privacy Shield. You may have a right to details of the mechanisms under which your data is transferred outside the EEA.
Appendix A: Our Legal Bases for Processing Personal Information of European Union Individuals
Type of Personal Information
Our Legal Basis
Name, business email address, school/organization name, username and password, photo, title, nickname, additional email addresses, payment information
Creating and managing users’ membership accounts
To provide IBSC services
Name, business email address, school/organization name
Administering member schools’ and organizations’ accounts
Name, business contact information, mobile phone number, emergency contact information, payment information, meal preferences
Managing conferences, events, and online courses
Name, business email address, school/organization name
Marketing IBSC and IBSC conferences and events
Computer and mobile device information, including IP address
To provide and improve the IBSC Site and App
Name, business email address, school/organization name
To administer surveys and questionnaires