Your privacy matters to HSUSA, whether you are visiting our website, or social media platforms for the first time or whether you are a regular visitor please take the time to get to know our best practices. If you have any questions please contact our Privacy Officer at firstname.lastname@example.org.
INFORMATION WE COLLECT FROM OR ABOUT YOU
We collect, process, and retain information from or about you and any devices you may use when you use or interact with our Websites, and create an HSUSA Exchange Visitor Account.
We may automatically collect some non-personally identifiable computer information regarding your use of our websites, such as the type of computer operating system you are using (such as Windows 10, Mac OS, etc.) and web browser that you are using (such as Internet Explorer, Safari, etc.), as well as information regarding your Internet service provider, IP address, and the frequency with which you visit various parts of our web sites.
Information You Provide To Us: When you submit a contact form or create an HSUSA Exchange Visitor Account, we collect your personal information provided to us by you.
The information may include
Home, postal, or other physical address
Account information (username and password)
Telephone number, including mobile and VOIP numbers
Date of Birth
Government-issued ID information, including social security, passport and taxpayer-identification numbers
Emergency contact information
Transaction-related information, including, credit card, routing, or other preferred means of payment or billing information
Third-party personal information, such as name and email for referral purposes
Any other information needed to provide you with our Services
Information From Social Media: When you interact with us on a social media platform, we may collect the personal data that you make available to us on that page, including your account ID or username and other information included in your posts. We are not responsible for the information your release to us through social media platforms and you need to inform yourself of those third-party privacy policies as they relate to those forums.
Information From Other Sources: We may supplement the personal data we collect with information from third parties, such as information collected by HSUSA Home Country Partner Agencies, by HSUSA team members at events, in person or collected over the phone or during your skype interview and add it to your account information. This information may include but is not limited to, demographic information that is publically available, additional contact information, group affiliations, occupational information, and educational background. We also may collect information about you from people you have referred us to, for example, to determine your qualifications.
WHEN AND HOW WE SHARE PERSONAL DATA WITH OTHERS: Except as described in this Privacy Notice, HSUSA will not share your personal data with third parties, rent or sell its mailing list, or share your personal data with third parties for their direct marketing purposes.
SERVICE PROVIDERS: We have third-party service providers that perform functions on behalf of HSUSA, including accounting, housing partners, local area coordinators, and Site of Activity Hosts. These service providers may have access to personal data if necessary or useful to perform their functions. If obtaining access to personal information, these parties will be held accountable to HSUSA’s confidentiality and security obligations with respect to such information.
PARTNERS: HSUSA may share pertinent information about you with our partner agents in order to provide you with the best customer experience, information, programs, and services. We may share information in the process of evaluating your application and completing your placement in a program.
Law Enforcement / Protection: HSUSA reserves the right to share information about you where HSUSA is obligated to comply with a legal requirement. We may disclose information where we are required to do so by law, for example, in response to a court order or a subpoena. To the extent permitted by applicable law, we also may disclose personally identifiable information in response to a law enforcement agency’s request or if we feel that such disclosure may prevent the instigation of a crime, facilitate an investigation related to public safety, protect the security or integrity of our web site(s) and networks, and/or enable us to take precautions against liability, misuse or unauthorized use.
PROTECTION OF YOUR INFORMATION: We at HSUSA have made technical investments and implemented organizational measures in order to protect your personally identifiable information. We limit the information we obtain to the minimum necessary in order to provide our services effectively. We also restrict access to that information by the use of password-protected systems. We may, within our corporate discretion, collect and store personally‑identifiable information using encryption technology. When employed, encryption allows you and us to input before encrypted information is sent via the Internet. We make commercially reasonable efforts intended to ensure that the personally-identifiable information we collect on our website(s) is secured against unauthorized access. However, please be aware (as you see in the News from time to time) that no system is completely secure from hackers, governmental intrusion, network failure, and error, and we cannot guarantee the confidentiality, security, and integrity of information maintained on our web site(s).
Children’s Data: Our program for high school exchange begins at age 15. Information collected for children under the age of 16 will only be done only with parents’ consent. We will not knowingly collect or use any personal data from children that we know to be under the age of 16 that does not come with the consent of the parent/guardian. If we become aware of personal data in our database that was collected from a child under the age of 16 that does not have the accompanying consent of a parent/guardian, we will delete such information.
TRANSFERRING PERSONAL DATA TO THE UNITED STATES: HSUSA 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. CIEE relies on derogations for specific situations as set forth in Article 49 of the GDPR. In particular, HSUSA 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 HSUSA in a manner that does not outweigh your rights and freedoms. HSUSA 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 HSUSA and the practices described in this Privacy Notice.
Opt-Out of Communications HSUSA may use your personally identifiable information (email address, telephone number, etc.) to fulfill requested services and/or follow up with you as is deemed necessary. The information we collect is shared only as necessary with recruiters or administrators who assist in providing support for our internal operations. We also may use this information to notify you of future opportunities and additional services. If you do not want any such updates, either by email or text, simply opt-out of those communications by sending an email to that effect to our privacy-related email address, email@example.com or, via U.S. mail, c/o Privacy Officer, High School in the USA, 2451 Atrium Way, Nashville, TN 37214, indicating “Privacy Opt-Out” in the subject line. Please allow up to 21 days for the opt-out to take effect.
Right to Access Upon email request delivered to firstname.lastname@example.org or via U.S. mail, c/o Privacy Officer, High School in the USA, 2451 Atrium Way, Nashville, TN 37214, indicating “Request for Information” in the subject line, we will provide you, free of charge, an electronic copy of the personally‑identifiable information that we maintain about you. You may request that we correct any factual errors in such information, by notifying us, again, at email address email@example.com or, via U.S. mail, c/o Privacy Officer, High School in the USA, 2451 Atrium Way, Nashville, TN 37214, including your name, e-mail address, and phone number so we can verify your identity, along with any corrected factual information. Please allow us up to 21 days from the date of our receipt of your request for any such updates to take effect.
Right to be Forgotten Upon email request delivered to firstname.lastname@example.org or via U.S. mail, c/o Privacy Officer, High School in the USA, 2451 Atrium Way, Nashville, TN 37214, indicating “Remove Personal Information” in the subject line, along with your name, e-mail address, and phone number so we can verify your identity, we will remove all personally identifiable information to the extent we are able to. Some minimum information may be maintained as required for the auditing of our services provided. The deletion or cessation of collection of information may result in the cancellation of services initially provided to you. Please allow us up to 21 days from the date of our receipt of your request for any such deletion to take effect. HSUSA retains data for the appropriate amount of time, and for all Exchange Visitors we retain your information as regulated by the Department of State.
Individual Rights in EEA or SWITZERLAND
If you are a resident of the EEA or Switzerland, you are entitled to the following rights once the GDPR becomes effective:
The right to request data erasure – you have the right to have your data erased from our Websites if the data is no longer necessary for the purpose for which it was collected, you withdraw consent and no other legal basis for processing exists, or you believe your fundamental rights to data privacy and protection outweigh our legitimate interest in continuing the processing.
The right to restrict or object to our processing – you have the right to restrict or object to our processing if we are processing your data based on legitimate interests or the performance of a task in the public interest as an exercise of official authority (including profiling); using your data for direct marketing (including profiling), or processing your data for purposes of scientific or historical research and statistics.
The right to object to automated decision making – you have a right to avoid being subject to automated decision making and insist on human intervention if we make an automated decision that produces a legal or a similarly significant effect on you.
Breach Notification In the unlikely event a data breach occurs that results in the risk for the rights and freedoms of individuals affected, HSUSA will, without undue delay, notify their customers within 72 hours following first becoming aware of a data breach.