ONLINE PRIVACY NOTICE
We at Stephen A. Schwarzman Education Foundation (SASEF) respect your concerns about privacy. This Online Privacy Notice describes the types of Personal Data we collect on https://www.schwarzmanscholars.org (the "Site"), how we use the information, with whom we may share it and the choices available to you regarding our use of the information. We also describe the measures we take to protect the security of the information and how you can contact us about our privacy practices. "Personal Data" has the meaning given in the European General Data Protection Regulation and includes any information relating to an identifiable individual (such as name, address, date of birth or economic information).
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- Information We Obtain
- The types of Personal Data we may collect on the Site includes:
- business and personal contact information (such as name, postal and email addresses, and telephone number); and
- other information you submit to us (such as information provided by registering for email alerts or filling in online application forms).
- In connection with a job inquiry or an application on our admissions pages, you may provide: login credentials; information regarding your work authorization status, education history, employment history and professional designations; and other information about your background and qualifications. In addition, where legally permissible, you may provide information regarding your gender, race/ethnicity, and your disability status. SASEF will not consider either this information or your choice to decline to provide it in evaluating your qualifications for employment purposes or as part of your admission to a scholarship program with us. This information will be used only for Equal Employment Opportunity reporting and other legal and compliance purposes.
- In connection with our application, you may provide detailed personal and biographical data, and education and work history.
- The types of Personal Data we may collect on the Site includes:
- Information We Obtain By Automated Means
- We may use third-party web analytics services on our Site, such as those of Google Analytics. These service providers help us analyse how visitors use the Site. The information obtained for this purpose (including your IP address and other information collected by automated means) may be disclosed to or collected directly by these service providers. To learn about opting out of Google Analytics, please click here.
- The providers of third-party plugins and widgets on our Site, such as embedded videos and social media sharing tools, may use automated means to collect information regarding your use of the Site and your interactions with the plugins and widgets. This information is subject to the privacy policies or notices of the providers of the plugins and widgets. Information about our cookie practices is available here.
- How We Use the Information We Obtain
- We may use the information described above for the following purposes to:
- operate, evaluate and improve our business (including developing new scholarship programs and other services; enhancing, improving and analysing our scholarship programs and other services; managing our communications; and performing accounting, auditing and other internal functions);
- create and manage your account;
- manage your relationship with the scholarship program (including as a candidate, scholar, applicant, or donor);
- comply with and enforce applicable legal requirements, relevant industry standards and our policies, including our Terms and Conditions of Use;
- protect against, identify and prevent fraud and other unlawful activity;
- in some cases, in order to operate, administer and improve the user's experience of the Site;
- provide information on our scholarship programs and other services to you, such as market commentary and email alerts;
- send you promotional materials, newsletters and other communications;
- communicate with you about, and administer your participation in, special events, programs, promotions, offers, surveys and market research;
- respond to your inquiries;
- manage your admissions application, assess your qualifications with us for full information about how and why we use your Personal Data in this context;
- verify your information; and
- perform data analyses (including market research, demographic analyses and anonymization and aggregation of information).
- In addition, we use information collected through cookies, web beacons, web server logs and other automated means for purposes such as (i) customising our users' visits to our Site, (ii) delivering content tailored to our users' interests and the manner in which our users browse our Site, and (iii) managing our Site and other aspects of our business.
- We also may use the information in other ways for which we provide a specific notice at the time of collection.
- We will only process your Personal Data as necessary so that we can pursue the purposes described above.
- Where we process your Personal Data for our legitimate interests as a business, we do so only where we have concluded that our processing does not prejudice you or your privacy in a way that would override our legitimate interest in pursuing those purposes.
- When we collect Personal Data from you, unless indicated otherwise, you should assume that, if we ask you for information, we need it for our business or compliance purposes. In limited circumstances, we are required to collect Personal Data to comply with a legal obligation and/or might ask you to provide information which is purely voluntary; in either case, this will be indicated to you.
- If you are a former employee, agency worker, consultant, individual contract worker, member, director, officer of SASEF or other individual such as applicant, student, donor or alumni, we will continue to process your Personal Data for a reasonable period following the end of your employment and / or affiliation with SASEF for our legitimate business and / or our legal compliance purposes and / or for the establishment or defence of a legal claim. Further, in some instances, we may process your data to perform our obligations under the contract between us (e.g. to pay you your final salary payment after your termination date). We only carry out such processing where we have concluded that our processing does not prejudice you or your privacy in a way that would override our legitimate interests in pursuing those purposes. Your data will be retained and deleted in accordance with our retention policies and procedures (as discussed further in paragraph 8 below).
- We may use the information described above for the following purposes to:
- Online Tracking and Interest-Based Advertising
- We and third parties acting on our behalf (such as Facebook, Instagram, Twitter and LinkedIn may collect information about your online activities over time and across third-party websites to provide you with advertising about our scholarship programs and related services tailored to your interests. Where required by applicable law, we will obtain your consent for the processing of your Personal Data for direct marketing purposes.
- You may see our ads on other websites or mobile apps because we participate in advertising networks. Ad networks allow us to target our messaging to users by considering demographic data, users’ inferred interests and browsing context. These networks track users’ online activities over time by collecting information through automated means (such as by cookies, web server logs, web beacons and other similar technologies). The networks use this information to show ads that may be tailored to individuals’ interests, to track users’ browsers or devices across multiple websites or apps, and to build a profile of users’ online browsing activities. The information our ad networks may collect includes data about users’ visits to websites and apps that participate in the relevant ad networks, such as the pages or ads viewed and the actions taken on the websites or apps. This data collection takes place both on the Site and on third-party websites and apps that participate in the ad networks. This process also helps us track the effectiveness of our marketing efforts.
- The Site is not designed to respond to “do not track” signals received from browsers. To learn how to opt out of ad network interest-based advertising, please visit www.aboutads.info/choices, http://www.networkadvertising.org/choices/ or http://www.youronlinechoices.eu/.
- Information We Disclose to Others
- We do not disclose Personal Data we obtain about you through the Site, except as described in this Online Privacy Notice. We may share your Personal Data with our authorised third parties including Tsinghua University (which must accept you into the university if you wish to become a scholar). We may also share Personal Data with service providers who perform services on our behalf based on our instructions. We do not authorize these service providers to use or disclose the information except as necessary to perform services on our behalf or comply with legal requirements.
- We also may disclose information about you (i) if we are required to do so by law or legal process, (ii) to law enforcement authorities, regulators and/or other government entities and/or other competent authorities based on a lawful disclosure request, or (iii) when we believe disclosure is necessary or appropriate to prevent harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity.
- In addition, we may share anonymous / aggregated information with third parties, such as service providers such as Facebook, Twitter, LinkedIn and Instagram, in order to promote our scholarship program.
- Information collected through third-party plug-ins and widgets on the Sites (such as information relating to your use of a social media sharing tool) is collected directly by the providers of the plug-ins and widgets. This information is subject to the privacy policies of the providers of the plug-ins and widgets, and SASEF is not responsible for those providers' information practices.
- Data Transfers
We may transfer the Personal Data we collect about you to recipients in countries other than the country in which the information originally was collected. Where you are based in the UK (after it has left the EU) or the EU, this includes transfers outside of the UK and the European Economic Area ("EEA"). Those countries may not have the same data protection laws as the country in which you initially provided the information. Where we transfer Personal Data outside of the UK or the EEA within SASEF's organisation (including, for example, to Tsinghua University), or to our service providers, we will ensure that our arrangements with them are governed by data transfer agreements, designed to ensure that your Personal Data is protected (including, where appropriate, under an agreement on terms approved for this purpose by the European Commission).
- Retention and Deletion of your Information
- We intend to keep your Personal Data accurate and up-to-date. We will delete the information that we hold about you when we no longer need it.
- We will retain your information in line with our retention policies and, in any event, for no longer than is necessary given the purpose for which it was collected, after which it will be deleted or anonymized.
- Note that we may retain some limited information about you (even when we know that you have left the scholarship program you were part of or the organisation that you represent) so that we can maintain a continuous relationship with you if and when we are in contact with you again.
- Your Rights and Choices
We offer you certain choices in connection with the Personal Data we collect from you. To update your preferences or submit a request, please contact us as indicated in the "How to Contact Us" section of this Online Privacy Notice. To the extent provided by the law of your jurisdiction, you may request access to the Personal Data we maintain about you or request that we correct, amend, delete or block the information by contacting us as indicated below. Where provided by law, you may withdraw any consent you previously provided to us or object at any time on legitimate grounds to the processing of your Personal Data, and we will apply your preferences going forward. You can also lodge a complaint about our processing of your Personal Data with the body regulating data protection in your country.Your specific rights where you are a user in the UK or the EU are as follows:Rights of access, correction and deletion. You have a right of access to the Personal Data that we hold about you under European data protection legislation, and to some related information, including the purpose for processing the Personal Data, the recipients of that Personal Data to the extent it has been transferred internationally, and, where the Personal Data has not been collected directly from you, the source. You can also require any inaccurate Personal Data to be corrected or deleted.Right to object. You can object to our use of your Personal Data for direct marketing purposes at any time and you may have the right to object to our processing of some or all of your Personal Data (and require them to be deleted) in some other circumstances.If you wish to exercise any of these rights, please Contact us as set out below.Complaints. You can also lodge a complaint about our processing of your Personal Data with the body regulating data protection in your country.
- How We Protect Personal Data
We maintain administrative, technical and physical safeguards designed to protect Personal Data we obtain through the Sites against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.
- Links To Other Websites
- Our Sites may provide links to other websites for your convenience and information. These websites may operate independently from us. If you visit any website linked to this Site, such as the website of Tsinghua University, you are subject that website’s own privacy policies. Linked websites may have their own privacy notices or policies, which we strongly suggest you review.
- To the extent any linked websites are not owned or controlled by us, we are not responsible for their content, any use of the websites, or the privacy practices of the websites.
- Updates To Our Online Privacy Notice
This Online Privacy Notice may be updated periodically and without prior notice to you to reflect changes in our Personal Data practices. We will post the updated version on the Sites and indicate at the top of the Notice when it was most recently updated.
- How To Contact Us
If you have any questions or comments about this Online Privacy Notice, or if you would like us to update information we have about you or your preferences, please email us at firstname.lastname@example.org. You also may write to:Address for Legal Notices:
Stephen A. Schwarzman Education Foundation
641 Lexington Avenue, 23rd Floor | New York, NY 10022
Attn: Amy Stursberg