Effective Date: April 19, 2013
1. Information you submit
In connection with your use of the Site, you may be asked to submit Personal Data, including your name, address, and telephone number. For example, if you apply for a scholarship through the Site, you will be asked to submit information (including Personal Data) about yourself, to assist us in evaluating your application. If you wish to receive further information about the Schwarzman Scholars Program via the Site, you will be asked to submit information (including Personal Data) to allow us to send you the information. Please note that it is always your choice whether to provide Personal Data about yourself, and if you submit Personal Data about any other person, you must first obtain his or her consent. Please do not submit Personal Data about any person other than yourself unless you have first obtained such person’s consent. By submitting Personal Data about others, you hereby represent and warrant to the Foundation that you have such person’s consent and full authority to do so.
2. Other information we collect
We sometimes collect information about you without your submitting it, including non-personally identifiable aggregate data, to improve the quality of the Site and maintain the Site’s proper operation. For instance, we may collect your IP address each time you request a page during a visit to the Site. We collect some information automatically from visitors to the Site, such as by the use of “cookies”, “web beacons”, and other tracking mechanisms. “Cookies” are small files placed on the hard drive of your computer; each website can send its own cookie to your browser if your browser preferences allow it. If you do not want to receive cookies, you may set your browser to reject them. However, if you turn cookies off, you may not have access to some of the Site’s features. “Web beacons” are communications with a server performed when retrieving the content of a webpage, and enable us to track the number and timing of visitors to certain sections of the Site. We may employ web beacons to help us compile aggregated statistics regarding the operations of the Site. We prohibit web beacons on our Site from being used by third parties to collect or access your Personal Data.
3. Use/sharing of your information
We may use Personal Data we collect about you (whether or not through the Site) and disclose it to our partners and other third parties (including persons outside the United States) for any authorized purpose relating to the charitable purposes of the Foundation and/or the Schwarzman Scholars Program. For example, if you apply for a scholarship, we may provide information about your candidacy to Foundation personnel and authorized third parties, including Tsinghua University (which must accept you into the university if you wish to become a Schwarzman Scholar) in connection with the evaluation process
We may from time to time review information about you held in our systems – including the contents of and other information related to your email and other communications with us – for compliance and business-protection purposes as described above. This may include reviews for the purposes of disclosure of information relevant to litigation and/or reviews of records relevant to internal or external regulatory or criminal investigations. To the extent permitted by applicable law these reviews will be conducted in a reasonable and proportionate way and approved at an appropriate level of management. They may ultimately involve disclosure of your information to governmental agencies and litigation counterparties, following a subpoena, court order or discovery request, or when we act in good faith to protect the rights of the Foundation, the Site and its users as described below. Your emails and other communications may also occasionally be accessed by persons other than the member of staff with whom they are exchanged for ordinary business management purposes (for example, where necessary when a staff member is out of the office or has left us).
We will only process your personal information as necessary so that we can pursue the purposes described above, and then 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. In exceptional circumstances we may also be required by law to disclose or otherwise process your personal information. We will tell you, when we ask you to provide information about yourself, if provision of the requested information is necessary for compliance with a legal obligation or, on the other hand, if it is purely voluntary and there will be no implications if you decline to provide the information. Otherwise you should assume that we need the information for our business or compliance purposes (as described above). If you are uncertain as to our need for information that we request from you, please contact our representative asking for the information, or contact us with your query.
4. Disclosure and international transfer of your information
We may disclose personal information about you, where reasonably necessary for the various purposes set out above to:
• Tsinghua University;
• service providers who host our websites or other information technology systems or otherwise hold or process your information on our behalf, under strict conditions of confidentiality and security;
• partners who run any events that you sign up to through our websites;
• a person who takes over the conduct and/or administration of Foundation programs, or relevant parts of them; or
• in exceptional circumstances:
o to competent regulatory, prosecuting and other governmental agencies, or litigation counterparties, in any country or territory; or
o where we are required by law to disclose.
These disclosures may involve transferring your personal information overseas. If you are dealing with us within the European Economic Area (or the UK, after it has left the European Economic Area), you should be aware that this may include transfers to countries outside the European Economic Area / UK, which do not have similarly strict data privacy laws. In those cases, where we transfer personal data to other members of the Foundation or our service providers, we will ensure that our arrangements with them are governed by data transfer agreements, designed to ensure that your personal information is protected, on terms approved for this purpose by the European Commission. Please Contact us (see below) if you would like to know whether any such agreements are in place or, if so, to see a copy.
4. Retention and Deletion of your information
We will delete the information that we hold about you when we no longer need it. Specific information about our record retention policies is available on request. Please Contact us (see below)).
Note that we may retain some limited information about you even when we know that you have left 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, representing a different organisation.
4. Maintaining your information
Our systems allow you to update any Personal Data you submit to the Site. If you have created an account with us (such as for a scholarship application), you may access and update your information at [insert link to update application] until your application has been finally submitted. We may retain your Personal Data for the term permitted by applicable law. We may also discard your Personal Data at our discretion, so you should retain your own records of any information that you submit to us.
5. Other websites
Please note that this Policy applies only to www.schwarzmanscholars.org. 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. We do not control the privacy or other policies of other websites. You should review the privacy policies of all third-party websites before you visit them.
4. Your rights
You may have a right of access to the personal information that we hold about you, and to some related information, under data protection law. You can also require any inaccurate personal information to be corrected or deleted. You can object to our use of your personal information 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 information (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. You can also lodge a complaint about our processing of your personal information with the relevant local authorities. An overview of the relevant contact details is available upon request.
6. Information Security
The Foundation is concerned about the security of your information. We endeavor to protect your Personal Data, using technical, administrative and physical security measures. However, there is no such thing as perfect security on the Internet, and you provide Personal Data to us at your own risk that it may be viewed or used by unauthorized persons. The Foundation expressly disclaims all liability for any damages, losses or claims of any kind relating to any Personal Data that you provide to the Foundation or others through the Site. Notwithstanding the foregoing, if you believe that you have been a victim of identity theft through the Site, please notify the Foundation at the address for Legal Notices below.
7. Children’s privacy
We do not seek or desire to collect information from children under the age of 13. Therefore, we will not knowingly request information from persons under such age. As noted in the instructions for the scholarship application, you must be at least 18 years of age to submit a scholarship application. Please do not provide any Personal Data to the Foundation for any reason unless you are at least 13 years of age, and please caution your children not to do so. If a child under 13 has provided Personal Data to us through the Site without parental consent, a parent or guardian may inform the Foundation at the address in Section 11 below, and we will use commercially reasonable efforts to delete such information, subject to applicable law.
9. Governing law/venue
This Policy and your use of the Site are governed by New York law. Any dispute between us relating to this Policy or your use of this Site shall be resolved solely in the state or federal courts located in the borough of Manhattan, New York City.
10. International use
This Policy is intended to comply with the laws and regulations of the United States, and we make no claim that the Site is appropriate or lawful for use or access outside the United States. Furthermore, the database in which our information is stored, including PII you submit for any purpose, is located in the United States. If you access the Site from outside the United States, you do so at your own risk. You are solely responsible for complying with all local laws, rules and regulations regarding online conduct and website access. By sending us your data for any reason, including in the form of scholarship application materials, you consent to transfer to and storage within the United States.
11. Legal notices
If you have any questions or issues with respect to this Policy, please contact us as set forth below. To the fullest extent permitted by law, you agree to receive all legally required notices regarding this Policy or any privacy or security breach relating to this Site by email at the address you use to contact the Site.
Address for Legal Notices:
Stephen A. Schwarzman Education Foundation
641 Lexington Avenue, 23rd Floor | New York, NY 10022
Attn: Amy Stursberg 646.313.6500