AIFS Study Abroad Privacy Policy

AIFS Study Abroad is a trading name of the American Institute for Foreign Study, Inc (“AIFS US”).

American Institute for Foreign Studies (UK) Limited (“AIFS UK”) assists AIFS US in the administration of the Program (defined below). AIFS UK is the EU representative of AIFS UK for data protection purposes. Contact details for AIFS UK (including details of its registration with the UK Information Commissioner’s Office) are at the end of this Policy (see HOW TO CONTACT AIFS UK below).

AIFS US and AIFS UK (collectively “AIFS”/“we”/“our”/“us”) take your privacy very seriously and are committed to protecting and respecting your privacy.

This Policy, together with a) our Website Terms of Use, b) our Cookie Policy, and c) our Terms and Conditions (each as described in OTHER TERMS WHICH MAY APPLY TO YOU below), applies to personal information that we collect about you.

Where we refer to the “Program”, we mean the AIFS Study Abroad program where students are placed by AIFS US at educational institutions around the world.

Where we refer to your “Home College”, we mean the college where you study before participating in the Program. By “College Abroad”, we mean the institution where you study while on the Program, and by “Internship Provider”, we mean the organisation(s) providing internship placements which you may be considered for, or take part in, as part of the Program.

Where we refer to the “Study Abroad Website” in this Policy, we mean the website which can be accessed at https://www.aifsabroad.com/ and any other “Study Abroad” website operated by us (including any updates or supplements to them).

Please read this Policy carefully to understand our views and practices regarding your personal information and how we will treat it.

Topics Covered

• WHO THIS POLICY APPLIES TO
• OTHER TERMS WHICH MAY APPLY TO YOU
• INFORMATION WE COLLECT (INCLUDING WHEN AND HOW WE COLLECT IT)
• HOW WE USE YOUR INFORMATION AND OUR LEGAL BASIS FOR DOING SO
• SHARING YOUR INFORMATION
• RETAINING YOUR INFORMATION
• TRANSFERRING YOUR INFORMATION OVERSEAS
• CHILDREN’S INFORMATION
• KEEPING YOUR INFORMATION SECURE
• UPDATING AND ACCESSING YOUR INFORMATION
• YOUR RIGHTS
• MARKETING
• OTHER WEBSITES
• CHANGES TO THIS POLICY
• HOW TO CONTACT AIFS STUDY ABROAD

Who This Policy Applies to

This Policy applies to:

• “Participants”, i.e. someone who participates in the Program; and
• “Visitors” to the Study Abroad Website.

“EU” means the following countries: Austria, Belgium, Bulgaria, Croatia, Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden and, until it leaves the EU, the UK.

Other Terms Which May Apply to You

This Policy refers to the following additional terms, which also apply to your use of the Study Abroad Website and, if applicable, your participation in the Program:

Website Terms of Use
Our “Website Terms of Use” govern your use of the Study Abroad Website.

Cookie Policy
Our “Cookie Policy” sets out information about the cookies we use on the Study Abroad Website.

Agreement and Release
The “Agreement and Release” that you accept when you apply for the Program.

Information We Collect (Including When and How We Collect It)

We collect the following personal information from and about you:

• Information you give us
• Information we collect when you visit the Study Abroad Website
• Information provided by third parties

1. Information you give us. You may give us information about you:
   • when you apply for the Program;
   • when you use the Study Abroad Website;
   • if you complete a survey or provide feedback, on the Study Abroad Website or otherwise;
   • if you report a problem with the Study Abroad Website; and
   • if you contact or correspond with us (for example, by phone, e-mail or otherwise) for any other reason.

     If you are a Participant, when applying to take part in the Program and/or to help us arrange your participation in the Program, you:

   • must provide us with your name, gender, date of birth, address, email address, cell phone number (s);
   • must provide us with your Home College name, state and country, class, projected graduation year, major, your personal campus address and contact number and how you found out about AIFS Study Abroad;
   • may provide us with a cv, including details of your academic performance;
   • must tell us when you would like to study abroad, which country you would like to study in and at which institution in that country;
   • must select which flights you would prefer;
   • may provide us with your personal Home College phone number;
   • must provide us with your nationality, passport and visa details (including, if you ask us to help apply for a visa, your town and country of birth);
   • must provide us with details of any medical conditions which are relevant to your ability to take part in the Program, which may include details of your medical history and any medical or health conditions (including any disabilities); and
   • must provide us with information to enable us to provide you with insurance.
   • When taking part or after taking part in the Program, you:
     • may provide us with information about you, for example, in any feedback, comments, blog articles or complaints you make or provide about the Program or your involvement in it; and
     • may provide us with your then-current contact details to enable us to keep in touch with you.
2. Information we collect when you visit the Study Abroad Website. Each time you visit the Study Abroad Website, we will automatically collect the following:
   • certain technical information, for example, the type of device (and its unique device identifier) you use to access the Study Abroad Website, the internet protocol (IP) address used to connect your device to the internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system, mobile network information and platform;
   • information about your visit to the Study Abroad Website, including the full Uniform Resource Locators (URL), clickstream to, through and from the Study Abroad Website (including date and time), pages you viewed, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page; and
   • certain cookies that are capable of identifying your device (see our Cookie Policy to understand which cookies the Study Abroad Website uses).
3. Information provided by third parties.When you apply for the Program:
   • with your consent, your Home College will provide your academic transcript and disciplinary record to AIFS US, who will share it with AIFS UK.When taking part or after taking part in the Program:
   • your College Abroad may provide us with updates on your attendance and performance and other feedback and information about you (for example if you wish to return home early);
   • if you take part in an internship placement, your Internship Provider may give us feedback about you (e.g. details of your performance as part of that internship); and
   • occasionally Participants may give us feedback about other Participants (e.g. if they have concerns about behaviour or health and safety).

How We Use Your Information and Our Legal Basis for Doing So

We collect personal information so that we can operate effectively and provide you with the best possible service. The information we process depends on the context of your interactions with us and with the Study Abroad Website, and your participation in the Program. It also depends on the choices you make, for example the consents you provide, the functions you use and the privacy settings you select. You may choose not to provide or allow us to collect certain information, but we may then not be able to consider you for the Program or enable you to participate in it (where that information is necessary for us to do so).

Learn more below about how we use your information and (if you are studying in the EU or the UK) what our legal basis is for using it.

In this table, “Contact Details” means your name, telephone number(s), email address, address and any other contact details you provide.

Participants

Visitors

More about the information we use and why

Where we have a legal basis to use your personal information without consent (as we have described above), this Policy fulfils our duty to process personal information transparently, and helps us to do so fairly and lawfully and in a manner that you would expect given the nature of our relationship with you, by giving you appropriate notice and explanation of the way in which your personal information will be used.

Where consent is required for our use of your personal information, we will ask you to positively opt-in by ticking the appropriate consent box or otherwise communicating your consent.

Where you provide us with personal information relating to other individuals (for example, if you give us your emergency contact’s details), you must obtain the consent of those individuals before doing so.

If you have any questions or require any further information regarding our use of personal information please contact our data protection officer (see HOW TO CONTACT AIFS UK).

Sharing Your Information

We may share your personal information with your consent or as is necessary between AIFS US and AIFS UK, with your Home College, your College Abroad, any relevant Internship Provider (if applicable), selected third party service providers, and other companies within our group that support us in the performance of the activities set out in the tables above. See below for more details.

We require all our third party service providers and all other companies within our group to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third party service providers to use your personal information for their own purposes and we only permit them to process your personal information for specified purposes in accordance with our instructions.

Your Home College, College Abroad and any relevant Internship Provider (if applicable) will process your personal information for their own purposes (for example, to keep track of your attendance and/or performance). To find out more about how they process your personal information, please see the privacy policies available on their websites (or get in touch with them for further details).

We may also need to share your personal information with a regulator or otherwise to comply with the law or to respond to valid legal process, including from law enforcement or other government agencies.

Why might you share my personal information with third parties?

We may share your personal information with third parties where it is necessary in connection with your participation in the Program, where required by law (as above), or where we have another legitimate interest in doing so that is not overridden by your interests and fundamental rights (for example, to protect other Students, or to operate and maintain the security of our computer systems.)

Who will you share my personal information with?

We will share certain information about you as follows:

• we will share the following information with your Home College: updates on your progress at your College Abroad (including academic issues and health and safety matters); and any matters falling under Title IX;
• if you take part in or are considered for an internship placement as part of the Program, we will share certain information (including your name and details of your academic performance in your cv or otherwise) with any relevant Internship Provider. We do so to enable the Internship Provider to consider you for such an internship and to facilitate your participation in that internship;
• we use Google to track your usage of the Study Abroad Website. We do so to improve our users’ experience of the Study Abroad Website;
• we may share certain information (including your name, gender, date of birth and address) with third party suppliers such as travel and accommodation providers (including airlines); insurance providers; embassies; and border control agencies. We do so to facilitate your participation in the Program;
• we may share certain information (including your name, gender, date of birth and address) with embassies and government departments. We do so to progress your visa application and to comply with visa regulations for your Program;
• where we are arranging your visa, we may share your contact details (including your name and address) with DHL, the mail and logistics company. We do so to enable DHL to deliver a visa pack to you for your visa application; and
• we will ask you to share your financial and/or payment details with a third party payment processor, (although we ourselves will never access that information). We do so to collect any payments associated with your Program (for example if you wish to change your booking or add to your itinerary);
• we may need to register you with the local police, to comply with immigration laws.

Retaining Your Information

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including to satisfy any legal, accounting, or reporting requirements. To decide the appropriate retention period, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorised use or disclosure of it, the purposes for which we process your information, and the applicable law.

In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Even if you request that we erase your information, we may still need to keep it (see YOUR RIGHTS) or may keep it in a form that does not identify you.

The following retention periods will apply, unless we inform you otherwise (or you request that we erase your information):

• if you are a Participant, we may retain some of your information for a period of 7 years from the end of your participation in the Program, for example, to keep in touch with you and/or for legal reasons.
• if you are a Visitor and you do not use the Study Abroad Website for one year, then we will erase your information.

We may keep certain information for longer periods than those stated above if you have agreed to us using it, for example, for promotional purposes.

Please contact our data protection officer if you would like further details on how long we retain your information (see HOW TO CONTACT AIFS UK).

Transferring Your Information Between Countries

If you are a Participant, we will need to transfer, process and store certain information we collect from you between AIFS US, AIFS UK, your Home College, and your College Abroad. We do so as it is necessary for us to communicate with these entities in relation to your participation in the Program, and so that you can take part in the Program (i.e. necessary for the performance of our obligations under our agreement with you).

If you are a Visitor based in the EEA, we will transfer the information we collect from you to AIFS US and other relevant third parties based in the U.S. We do so because part of the Study Abroad Website is operated out of, and accessed in, the U.S. and it is necessary for us to understand how it is used, so that we can improve it.

In each case, we will take all steps reasonably necessary to ensure that your personal information receives an adequate level of protection and is treated in a way consistent with EU laws on data protection.

Children’s Information

We do not knowingly collect information from anyone under the age of 16 and you should not register your interest in or apply to take part in the Program if you are under the age of 16. If you become aware that your child or any child under your care has provided us with information without your consent please contact our data protection officer (see HOW TO CONTACT AIFS UK).

Keeping Your Information Secure

All personal information that you provide to us is stored on secure servers. We have put in place (and require anyone we share your information with to put in place) appropriate measures to protect the security of your information.

In addition, we limit access to your information to those of our employees, agents, contractors and other third parties who have a business need to know.

You should be aware that the transmission of information via the internet is not completely secure. Although we will do our best to protect your information, we cannot guarantee the security of the information transmitted to the Study Abroad Website or by email; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access or inadvertent disclosure.

Updating And Accessing Your Information

You have the right under data protection laws to access personal information held about you, subject to certain conditions, and to request its rectification or deletion.

If you would like to access or amend the personal information which we hold about you or if you would like us to stop using your personal information, please contact our data protection officer (see HOW TO CONTACT AIFS UK).

To learn more about the rights you may have in relation to your personal information see YOUR RIGHTS.

Your Rights

By law you may have the right to:

• Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it. We will need you to prove your identity before we release any personal information to you.
• Request correction or erasure of your personal information (unless we have the legal right to retain it). You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
• Object to processing of your personal information where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
• Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of personal information that you have provided to us to another party.
• Change your information processing preferences at any time (where this specifically relates to marketing messages, see MARKETING).

You should be aware that if you ask us to stop processing your personal information in a certain way or to erase your personal information, and this type of processing is necessary in order for you to participate in the Program, then we may not be able to continue to provide our services to you and you may need to leave the Program. This does not include your right to object to direct marketing, which can be exercised at any time without restriction.

If you want to exercise any of the rights listed above, please contact our data protection officer (see HOW TO CONTACT AIFS UK).

No fee usually required to access your personal information

You will not normally have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

What we may need from you

We may need to request specific information from you to confirm your identity and verify your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

Right to withdraw consent

Where you have consented to the collection, use or transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact our data protection officer (see HOW TO CONTACT AIFS UK). Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

Marketing (This section applies if you are studying in the EU/UK)

If you are a Participant, or if you request information from us, we would like to send you information by email, SMS and/or via social media about opportunities or services of ours and other companies in our group which may be of interest to you (including, for example promotional materials and newsletters). We will ask whether you would like us to send you these messages when you request a brochure/ information or apply for the Program.

You have the right at any time to stop us from contacting you for marketing purposes. If you no longer wish to be contacted for marketing purposes, you can unsubscribe by using the “unsubscribe” link at the bottom of our marketing messages or by contacting our data protection officer (see HOW TO CONTACT AIFS UK).

We will not provide your personal information to any businesses outside our group for marketing purposes.

Other Websites

The Study Abroad Website contains links to other websites, including Facebook, Twitter and Instagram. This Policy only applies to the Study Abroad Website so when you link to other websites you should read their own privacy policies.

Changes to This Policy

We keep this Policy under regular review and will post any updates on this webpage. This Policy was last updated in August 2019.

How to Contact AIFS UK

In the UK, AIFS UK is the data controller in respect of your personal information and is registered with the UK Information Commissioner’s Office with registration number Z6393161. AIFS UK’s address is 37 Queen’s Gate, London, SW7 5HR.

We have appointed Richard Howell as our data protection officer to oversee compliance with this Policy. If you have any questions about this Policy or how we handle your personal information please contact him at dpo@aifs.co.uk, +44 20 7581 7300, 37 Queens Gate, London SW7 5HR, United Kingdom.

Complaints

If for any reason you are not happy with the way that we have handled your personal information please contact us at dpo@aifs.co.uk, +44 20 7581 7300, 37 Queens Gate, London SW7 5HR, United Kingdom. If you are still not happy, you have the right to make a make a complaint to the Information Commissioner’s Office, see: https://ico.org.uk/global/contact-us/.