Privacy Policy

May 24, 2018

 

NAFSA: Association of International Educators (NAFSA) is committed to building user trust and confidence by promoting, and complying with, business practices that help protect the privacy of our customer and user data. This Privacy Policy covers all information collected by NAFSA.

NAFSA has prepared this Privacy Policy to describe to you, or if you represent an entity or other organization, that entity or organization, (in either case,"you," "your," or "User") our practices regarding the personal information that NAFSA collects, uses, and shares. This includes information used by our iMIS association management system (AMS), the NAFSA websites (including Network.NAFSA online networking, surveys, job board, Adviser's Manual 360, and e-learning), the Experient registration system, the annual conference mobile application, and the eventBit tracking system. Hereafter, these various technologies will be known as the NAFSA "Platform."

NAFSA reserves the right, at any time, to modify this Privacy Policy. If we make revisions that change the way we collect, use, or share personal information, we will post those changes in this Privacy Policy. You should review this Privacy Policy periodically so that you keep up to date on our most current policies and practices. We will note the effective date of the latest version of our Privacy Policy at the end of this Privacy Policy.

Please read this Privacy Policy carefully to understand NAFSA’s views and practices regarding your personal information and how we will treat it. By visiting this Platform, you are freely accepting and consenting to the practices in this Privacy Policy. You may withdraw your consent at any time and for any reason with effect to future data processing by contacting us at the address listed below in the Section titled "Communications." Without your consent, NAFSA will use personal information, only insofar as such processing is permitted by applicable law (e.g., for the performance of a contract or agreement between NAFSA and you) or where such processing is necessary for compliance with a legal obligation to which NAFSA is subject.

COLLECTION OF PERSONAL INFORMATION

Through your interactions with NAFSA, NAFSA collects “personal information,” which is information that identifies an individual or relates to an identified individual. Non-personal information means information that does not directly identify an individual. We collect both types of information about you.

The following provides some examples of the type of data that we collect from you:

Context Types of Data and Purpose for Collection
Registration Information When you create an Account, we may collect your name, contact information, and other Registration Information. Such information shall be associated with your Account, and you may update such information by editing the information associated with your Account.
Cookies We may use cookies and clear GIFs. “Cookies” are small pieces of information that a website sends to your device while you are viewing a website. Among other things, cookies allow us to provide you with a more personal and interactive experience and to improve our marketing efforts. If you choose to disable cookies, some areas or features of our websites may not work properly.
Demographic Information We may collect personal information from you, such as your photo or location.
Digital Fingerprinting We may from time to time use digital fingerprinting technologies in an effort to protect and ensure the integrity of our Platform. In general, digital fingerprinting technologies assign a unique identifier or “Machine-ID” to a user’s computer to identify and track the computer’s survey activity. NAFSA will not use digital fingerprinting technology to collect personal information or track the online activities of the user of a computer and will not disrupt or interfere with the use or control of a computer or alter, modify, or change the settings or functionality of a computer. The technology will analyze publicly available information and data obtained from the computer’s web browser and from other publicly available data points, including without limitation the technical settings of the computer, the characteristics of the computer, and the computer’s Internet Protocol (IP) address, to create a unique identifier assigned to the computer. The unique identifiers are typically alpha-numeric IDs and after creating the unique identifier, NAFSA does not retain the information analyzed by the technology to create the unique identifier.
Geo-Location Information When you use one of our Applications or a badge or device provided by NAFSA, we may collect your location using GPS, Wi-Fi, cellular technology, radio-frequency identification (RFID), Bluetooth Low Energy (BLE) beacon technology, or other similar location-tracking technologies. NAFSA may capture proximity and duration information for providing personalized products and services, demographic analysis, or behavioral analysis. Such information, and any derived information, may be shared with third parties that have a relationship with NAFSA.
E-mail Interconnectivity If you receive e-mail from us, we may use certain tools to capture data related to when you open our message, click on any links or banners it contains and make purchases.
Employment If you apply for a job posting, or become an employee, we may collect personal information necessary to process your application. This may include, among other things, your Social Security Number or tax identification number.
Feedback/Support If you provide us feedback or contact us for support we will collect your name and e-mail address and possibly other personal information, as well as any other content that you send to us in order to reply.
Mailing List When you sign up for one of our mailing lists we may collect your e-mail address or postal address.
Market Research Studies We perform marketing research studies to collect data for research purposes. The information you provide is used for research analysis and we analyze the answers in aggregate. Information you provide in response to or in connection with a market research study is and will be provided to our clients or other entities or the public as part of cumulative market research information or statistical data in the ordinary course, but without identifying you individually, directly or indirectly.
Mobile Devices We may collect information from your mobile device such as unique identifying information broadcast from your device or hardware and software specifications.
Order Placement We may collect your name, billing address, shipping address, e-mail address, phone number, shipping preferences, and credit card number when you place an order.
Surveys/Partner Promotion When you participate in a survey we may collect additional information that you provide through the survey. If the survey is provided by a third-party service provider, the third party’s privacy policy applies to the collection, use, and disclosure of your information.
Web Logs/Third-Party Tracking We may collect information from you, including your browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to your computer when you use the Internet), domain name, click-activity, referring website, or a date/time stamp for your visit. In addition to information stored by our servers, we may also use cookies and clear GIFs.

In addition to the information that we collect from you directly, we may also receive information about you from other sources, including third parties, business partners, our affiliates, or publicly available sources.

USE OF PERSONAL INFORMATION

In addition to the uses described above, NAFSA uses the personal information collected in an effort to improve your experience, to provide services to you, and to communicate with you about information that you request. NAFSA may also use personal information to help target specific offers to you and to help NAFSA develop and improve its services. Additionally, NAFSA may use your personal information:

  • To identify you when you access and use any Sites or Applications.
  • To administer Accounts.
  • To provide services and content to our clients.
  • To provide you with products and services you request, or that maybe be of interest to you.
  • To streamline your checkout process.
  • To send marketing and promotional materials, including information relating to products, services, sales, or promotions.
  • To respond to your inquiries related to support, employment opportunities, or other requests.
  • To conduct research and analysis.
  • For internal administrative purposes, as well as to manage our relationship with you.

SHARING OF PERSONAL INFORMATION

In addition to the specific situations discussed elsewhere in this Privacy Policy, NAFSA may disclose personal information in the following situations:

  • Other Disclosures with Your Consent. We may ask if you would like us to share your information with other unaffiliated third parties who are not described elsewhere in this policy, and we may do so with your consent.
  • Other Disclosures without Your Consent. We may disclose personal information in response to subpoenas, warrants, or court orders, or in connection with any legal process, or to comply with relevant laws. We may also share your personal information in order to establish or exercise our rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our Terms of Use, or to comply with your request for the shipment of products to or the provision of services by a third-party intermediary.
  • Public. Some of our Sites or Applications provide the opportunity to post comments, or reviews, in a public forum. If you decide to submit information at these locations, that information may be publicly available.
  • Service Providers. We may share your personal information with service providers. Among other things service providers may help us to administer our website, plan or facilitate events or travel, conduct surveys, provide technical support, or sending marketing, promotions, and communications related to our business, payment processing, and for other legitimate purposes permitted by law.

SECURITY OF PERSONAL INFORMATION

NAFSA has implemented reasonable and appropriate security measures to help protect the personal information NAFSA collects from loss, misuse, unauthorized access, disclosure, alteration, and destruction. Although NAFSA attempts to protect the personal information in its possession, no security system is perfect, and NAFSA cannot promise that your personal information will remain absolutely secure in all circumstances.

RETENTION OF PERSONAL INFORMATION

NAFSA will retain your personal information as needed to fulfill the purposes for which it was collected. NAFSA will retain and use your personal information as necessary to comply with NAFSA’s business requirements, legal obligations, resolve disputes, protect our assets, and enforce our agreements.

DATA INTEGRITY AND PURPOSE LIMITATION

NAFSA limits the use of personal information to ways that are compatible and relevant to the purposes for which the personal information was collected or subsequently authorized or for which consent was obtained. NAFSA will take reasonable steps to ensure that personal information is reliable for its intended use, accurate, complete, and current.

YOUR CHOICES

You can make the following choices regarding your personal information by logging into the Communication Preferences section in My NAFSA in your NAFSA account:

  • Electronic and Print Communications. You may choose to consent to allowing us to send free NAFSA-specific newsletters, surveys, offers, and other promotional materials to you.
  • Third-Party Communications. You may choose to consent for the purpose of allowing targeted offers from third parties or NAFSA’s clients or business partners. At any time, you can stop receiving promotional e-mails by updating your communications preference or by following the unsubscribe instructions in e-mails that you receive. Clicking on an unsubscribe link will take you to a webpage where you can complete the opt-out process. Certain programs will provide a contact for support or other means to remove your name to remove your name from our contact list. If you decide not to receive promotional e-mails, we may still send you transactional communications, such as those about your Account, to fulfill orders you have made, to ask you to rate a product you purchased, event you attended, or other service-related communications.
  • Changes to Your Personal Information. We rely on you to update and correct your personal information. Note that we may keep historical information in our backup files as permitted by law. All requests to correct your information must be directed to the contact in the “Communications” section below.
  • Access to Your Personal Information. If required by law (for example, the European Union General Data Protection Regulation), upon request, we will grant reasonable access to the personal information that we hold about a User. All requests must be directed to the contact in the “Communications” section below.
  • Deletion of Your Personal Information. Typically, we retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. Some Users may have the legal right (for example, under the European Union General Data Protection Regulation) to request that we delete their personal information. All deletion requests must be directed to the contact in the “Communications” section below. We may also decide to delete your personal information if we believe that the data is incomplete, inaccurate, or that our continued use and storage are contrary to our obligations to other individuals or third parties. When we delete personal information, it will be removed from our active database, but it may remain in archives where it is not practical or possible to delete it. In addition, we may keep your personal information as needed to comply with our legal obligations, resolve disputes, or enforce any of our agreements.
  • Revocation of Consent. We rely on the processing of personal information that you have provided. If you revoke your consent for the processing of personal information, then we may no longer be able to provide you services. In some cases, we may limit or deny your request to revoke consent if the law permits or requires us to do so, or if we are unable to adequately verify your identity.
  • European Economic Area Citizens. Where you believe that we have not processed your personal information in accordance with the applicable provisions of the European Union General Data Protection Regulation, you may lodge a complaint with the respective European Union data protection authority (DPA).

CROSS-BORDER TRANSFER OF PERSONAL INFORMATION

NAFSA may transfer your personal information to NAFSA’s entities in the United States, or to third parties as described in this Privacy Policy that are located in various countries around the world. By using NAFSA’s Platform or providing any personal information to NAFSA, where applicable law permits, you consent to the transfer, processing, and storage of such information outside of your country of residence where data protection standards may be different. When NAFSA collects information in one country, and transfers it to another, to the extent possible it applies the same level of data protection required under the laws in the first country even when the data is in the second country. In particular, users in the European Union should be aware that while the European Commission has not found United States law to adequately protect the rights of data subjects, NASFA takes reasonable precautions to ensure that all processing activities conducted on our behalf are compliant with the European Union General Data Protection Regulation.

DISPUTE RESOLUTION

NAFSA commits to resolve complaints about your privacy and our collection or use of your personal information. European Union individuals with questions or concerns about our use of personal information or our privacy policy should submit a written request to us using the information in the “Communications” section below.

NAFSA commits to cooperate with European Union data protection authorities (DPAs) and comply with the advice given by such authorities with regard to human resources data transferred from the European Union in the context of the employment relationship.

Communications

Questions, concerns, or complaints should be directed to our privacy agent as follows:

  • By phone: +1-202-737-3699
  • By e-mail: nafsaprivacy[at]nafsa.org

Through mail:
Attn: Alan Williams, COO, NAFSA, 1307 New York Ave. NW, Washington, D.C. 20005 USA

If NAFSA is required to contact you about your personal information we may do so by mail, phone, or e-mail.

Effective as of May 25, 2018.
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