ASPECTFOUNDATION.ORG PRIVACY NOTICE
Aspect Foundation Student Exchange (“Aspect Foundation”) wants you to benefit from the information and services available on our website – www.aspectfoundation.org (the “Site”) – secure in the knowledge that we have implemented fair and transparent information policies and practices designed to protect your privacy.
This Privacy Notice outlines our policies and practices regarding our collection and use of personal data about users of the Site and sets forth your privacy rights. This Privacy Notice does not apply to information we collect through other means, including offline or via any other website used or operated by Aspect Foundation or a third party (such as one of our international partners).
We will update this Privacy Notice from time to time as we adopt new privacy policies or change our personal data practices.
WHO WE ARE
Aspect Foundation is headquartered in San Francisco, California, in the United States. Our full contact information is provided at the end of this Privacy Notice.
Aspect Foundation has appointed an internal data protection officer for you to contact if you have any questions or concerns about Aspect Foundation’s personal data policies or practices. The data protection officer can be contacted at dataprotectionofficer@aspectfoundation.org.
WHY WE COLLECT PERSONAL DATA
Aspect Foundation collects personal data about users of the Site to personalize and continually improve your experience on our Site and provide you and users like you with information about our programs, including by:
- providing you with information or services you request, including newsletters and notifications;
- providing you with information and suggesting programs that match your interests and other criteria you have identified, or that we otherwise believe may be of interest to you;
- streamlining the processes by pre-filling information you have already provided;
- improving our programs, services, and operations;
- providing you and others with advertising, including advertising based on your activity on the Site or activity on third-party sites and applications, such as social media platforms; and
- performing statistical, demographic, and marketing analyses of users of the Site and their behavioral patterns.
HOW WE COLLECT YOUR INFORMATION
The information we collect about our Site users comes to us in several different ways –
Information you provide to us: When you submit a contact form, create an account, or enter a search query on the Site, you may choose to disclose information about you, including your name, physical address, email address, phone number, and date of birth, along with information regarding your interests, educational background, and interests relating to the exchange program.
Information that is automatically collected: Like many websites, we use web analytics tools that rely on cookies, web beacons, and other automated tracking technologies (“Tracking Tools”) to help us analyze how users interact with and use the Site, improve the Site, personalize your Site experience, provide you with information we believe may be of interest to you, and identify others like you who may be interested in our programs and services.
The information we collect automatically includes information about your computer and internet connection (including your IP address, operating system, and browser type) and details regarding your visits to our Site (including your browsing actions and patterns and information about any referring website, search engine, social media platform, or link). We do not use Tracking Tools to collect personally identifiable information (except to the extent you have provided such information to third parties, such as social media platforms – see section below titled “Information from Third Parties”), but we tie information that we gather using Tracking Tools to your personally identifiable information.
Third Party Tracking Tools; Google Analytics
The Tracking Tools we use include services we obtain from third parties. The information generated by these analytics services will be transmitted to and stored by the third parties and will be subject to their privacy policies. We do not control these third parties’ tracking technologies, how they may be used, or the information they may collect, and we are not responsible for these third parties’ privacy policies.
One of the third-party Tracking Tools we use is Google Analytics. The information generated by Google Analytics will be transmitted to and stored by Google and will be subject to Google’s privacy policies. Learn more about Google’s partner services and how to opt out of tracking of analytics by Google.
Cookies and Web Beacons
The Tracking Tools we use rely on cookies and web beacons:
- Cookies. A cookie is a small data file that can be placed on your hard drive when you visit certain websites. Cookies are used to collect and store information, such as the type of computer you are using and how often you log on to a site. Our Site uses both “session cookies,” to improve your navigation across the Site and to remember you over the course of a single visit, and “persistent cookies,” which are stored on your computer until they expire or are deleted and help us provide better service to you over multiple visits to the Site. You can always delete or disable cookies through your browser. If you disable cookies, you may not be able to sign in or take advantage of certain features of the Site that require cookies.
- Web Beacons. In addition to cookies, we deliver “web beacons” through our Site and through emails we send you. Web beacons are small graphic images that may not be visible to Site visitors that collect information about Site usage on an anonymous basis. In some cases, anonymous data may be transmitted to third-party advertising networks. We use web beacons for our own internal analytics, to better understand the ways users interact with our website, and to determine whether a particular email was received and opened. We also use web beacons in connection with our marketing efforts. For example, web beacons allow third-party advertising networks to detect when a user has visited Aspect Foundation’s website, and then serve them ads for Aspect Foundation’s programs when they browse to another site.
Information from third parties and other sources: We supplement the information we collect through the Site with information from third parties (including our advertising partners and other service providers) and information we collect through other means, such as offline or through other websites. This information includes social media profile information, depending on the settings you have established for your social media accounts.
WHEN AND HOW WE SHARE PERSONAL DATA WITH OTHERS
Except as described in this Privacy Notice, Aspect Foundation will not share your personal data with third parties, rent or sell its mailing list, or share your personal data with third parties for marketing purposes.
Service Providers: We have service providers that perform functions on our behalf, including hosting, content management, social media integration, marketing, analytics, and customer service. These entities may have access to personal data if necessary or useful to performance of their functions. If obtaining such access, these third parties will be subject to confidentiality and security obligations with respect to such data.
Partners/Host Families/Schools: Aspect Foundation may share information about you with our partner organizations, host families and schools in order to provide you with information, programs, and services that you have requested or that we believe may be of interest to you. For example, we may share information in the course of evaluating your application or facilitating your placement in our program.
Law Enforcement / Protection: Aspect Foundation reserves the right to share information about you where Aspect Foundation believes that such disclosure is necessary to comply with a legal requirement, such as a subpoena or court order, or to protect the rights or property of Aspect Foundation, you, or third parties.
Consent: Aspect Foundation may share your information in any other manner to which you consent.
PROTECTION OF YOUR INFORMATION
Aspect Foundation makes reasonable efforts to guard your personal data against accidental loss and from unauthorized access, use, alteration, and disclosure. We update and test our security technology on an ongoing basis. We restrict access to your personal data to those employees who need to know that information to provide benefits or services to you. In addition, we train our employees about the importance of confidentiality and maintaining the privacy and security of your information. We commit to taking appropriate disciplinary measures to enforce our employees’ privacy responsibilities.
Unfortunately, the transmission of information via the internet is not completely secure. Although we take measures to protect your personal data, we cannot guarantee its security. Any transmission of personal information to or using our Site is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site. The safety and security of information also depends on you. If we have provided you with (or you have chosen) a username and password for access to certain parts of our Site, you are responsible for keeping such information confidential. Please do not share your username and password with anyone.
YOUR CHOICES ABOUT YOUR PERSONAL DATA
Our Site allows you to create a profile, including personal information. You may update or correct this information at any time to ensure its continued accuracy. You may also delete your profile by contacting us at dataprotectionofficer@aspectfoundation.org.
Additionally, Aspect Foundation provides you choices regarding the way we use the personal data you have provided us. For example, you may sign up to receive newsletters or email notification regarding particular services. You may opt out of receiving these optional communications at any time, by clicking the 'Unsubscribe' link in the footer of these emails. Please note, some emails like account password resets or legal notices will continue to be emailed regardless of unsubscribe settings.
If you wish to discuss any aspect of our processing of your personal data, please contact us at dataprotectionofficer@aspectfoundation.org.
TRANSFERRING PERSONAL DATA TO THE UNITED STATES
Aspect Foundation is located in the United States. Please be aware that any information you provide to us may be transferred to and processed in the United States and be subject to United States law. The privacy and data protection laws in the United States may not be equivalent to the laws in your country of residence.
The United States has not sought nor received a finding of “adequacy” from the European Union under Article 45 of the GDPR. Aspect Foundation relies on derogations for specific situations as set forth in Article 49 of the GDPR. In particular, Aspect Foundation collects and transfers to the U.S. personal data only: with your consent; to perform a contract with you; or to fulfill a compelling legitimate interest of Aspect Foundation in a manner that does not outweigh your rights and freedoms. Aspect Foundation endeavors to apply suitable safeguards to protect the privacy and security of your personal data and to use it only consistent with your relationship with Aspect Foundation and the practices described in this Privacy Notice.
DATA STORAGE AND RETENTION
Your personal data is stored by Aspect Foundation on its servers, and on the servers of the cloud-based database management services Aspect Foundation engages, located in the United States. The Aspect Foundation retains data for the appropriate amount of time. For more information on where and how long your personal data is stored, and for more information on your rights of erasure and portability, please contact Aspect Foundation’s data protection officer at dataprotectionofficer@aspectfoundation.org.
CHILDREN'S PRIVACY
Our Site is not intended for use by children under the age of 13, and we do not knowingly collect personal information from children under the age of 13.
LINKS
This Privacy Notice applies only to information collected by this Site and not to other websites that you may link to from here. Aspect Foundation is not responsible for the privacy practices of other sites. Please be aware that when you leave this Site, you should read the privacy policies of other websites that ask you to provide personal data.
NOTIFICATION OF CHANGES
Any changes to this Privacy Notice will be posted on this Site. Any information that we collect from you will be used in accordance with the version of this Privacy Notice in effect at the time that the information was collected, unless we receive your consent to change our practices with respect to previously collected information.
For further information or comments on our Privacy Notice, please contact our data protection officer at dataprotectionofficer@aspectfoundation.org, or contact Aspect Foundation at the following address:
Aspect Foundation
250 Columbus Ave., Ste. 200
San Francisco, CA 94122
Phone: 1.415.228.8050
E-mail: exchange@aspectfoundation.org
EFFECTIVE: May 25, 2018