The following discloses our information gathering and dissemination practices and is effective August 1, 2017.
Gathering, Use, and Disclosure of Non-Personally-Identifying Information
Users of the Website Generally
“Non-Personally-Identifying Information” is information that, without the aid of additional information, cannot be directly associated with a specific person. “Personally-Identifying Information,” by contrast, is information such as a name or email address that, without more, can be directly associated with a specific person. Like most website operators, the School gathers from users of the Website Non-Personally-Identifying Information of the sort that web browsers, depending on their settings, may make available. That information includes the user’s Internet Protocol (IP) address, operating system, browser type, and the locations of the websites the user views right before arriving at, while navigating, and immediately after leaving the Website. Although such information is not Personally-Identifying-Information, it may be possible for the School to determine from an IP address a user’s internet service provider and the geographic location of the visitor’s point of connectivity, as well as other statistical usage data. The School analyzes Non-Personally-Identifying Information gathered from users of the Website to help the School better understand how the Website is being used. By identifying patterns and trends in usage, the School is able to better design the Website to improve users’ experiences, but in terms of content and ease of use. From time to time, the School may also release the Non-Personally-Identifying Information gathered from Website users in the aggregate, such as by publishing a report on trends in the usage of the Website.
A “Web Beacon” is an object that is embedded in a web page or email that is usually invisible to the user and allows website operators to check whether a user has viewed a particular web page or an email. The School may use web beacons on the Website and in emails to count users who have visited particular pages and viewed emails. Web beacons are not used to access users’ Personally-Identifying Information. They are a technique the School may use to compile aggregated statistics about Website usage. Web beacons collect only a limited set of information, including a cookie number, time and date of a page or email view, and a description of the page or email on which the web beacon resides. You may not decline web beacons; however, they can be rendered ineffective by declining all cookies or modifying your browser setting to notify you each time a cookie is tendered, permitting you to accept or decline cookies on an individual basis.
We may use third-party vendors, including Google, who use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to inform, optimize, and serve ads based on your past activity on the Website, including Google Analytics for Display Advertising. The information collected may be used to, among other things, analyze and track data, determine the popularity of certain content, and better understand online activity. If you do not want any information to be collected and used by Google Analytics, you can install an opt-out on your browser (https://tools.google.com/dlpage/gaoptout/) and/or opt out from Google Analytics for Display Advertising or the Google Display Network by using Google’s Ads Settings (https://www.google.com/settings/ads).
Aggregated and Non-Personally-Identifying Information
We may share aggregated and Non-Personally-Identifying Information we collect under any of the above circumstances. We may also share it with website providers and other third parties to develop and deliver targeted advertising on the websites of third parties. We may combine Non-Personally-Identifying Information we collect with additional Non-Personally-Identifying Information collected from other sources. We also may share aggregated information with third parties, including advisors and advertisers, for the purpose of conducting general business analysis. This information does not contain any Personally-Identifying Information and may be used to develop Website content and services that we hope you and other users will find of interest and to target content and advertising.
We may use hyperlinks on the Website that will redirect you to a social network if you click on the link; however, when you click on a social plug-in, such as Facebook’s “Like” button or Twitter’s “tweet” button, that particular social network’s plug-in will be activated and your browser will directly connect to that provider’s servers. If you do not use these buttons, none of your data will be sent to the respective social network’s plug-in provider. So for example, when you click the Facebook “Like” button on the Website, Facebook will receive your IP address, the browser version and screen resolution, and the operating system of the device you have used to access the Website. Settings regarding privacy protection can be found on the websites of these social networks and are not within our control.
Collection, Use, and Disclosure of Personally-Identifying Information
As defined above, Personally-Identifying Information is information that can be directly associated with a specific person. The School may collect a range of Personally-Identifying Information from and about Website users. Much of the Personally-Identifying Information collected by the School about users is information provided by users themselves when (1) creating an account and submitting an inquiry or application on the Application Portal; (2) updating student or parent profiles with the School’s administration, on the Community Portal, or on the Forms and Student Data Hub; (3) subscribing to an email list, like the weekly or monthly Blog digest; or (4) communicating with us. That information may include each user’s name, address, email address, and telephone number, as well as financial information such as your payment method. We also may request information about your interests and activities, your gender, age, date of birth, username, hometown, and other demographic or relevant information as determined by the School from time to time. We also collect information about users’ children for the purpose of processing applications for admission and providing educational services. Users of the website are under no obligation to provide the School with Personally-Identifying Information of any kind, with the caveat that a user’s refusal to do so may prevent the user from using certain Website features or from applying to the School.
By registering with or using the Website, you consent to the use and disclosure of your Personally-Identifying Information as described in this section.
We may occasionally use your name and email address to send you notifications we think you may find valuable. We may also send you service-related announcements from time to time through the general operation of the service. Generally, you may opt out of such emails at the time of registration or through your account settings, though we reserve the right to send you notices about your account, such as service announcements and administrative messages, even if you opt out of all voluntary email notifications.
The School will disclose Personally-Identifying Information under the following circumstances:
- By Law or to Protect Rights. When we believe disclosure is appropriate, we may disclose Personally-Identifying Information in connection with efforts to investigate, prevent, or take other action regarding illegal activity, suspected fraud, or other wrongdoing; to protect and defend the rights, property, or safety of the School, our users, our employees, or others; to comply with applicable law or cooperate with law enforcement; to enforce our agreements or policies, in response to a subpoena or similar investigative demand, a court order, or a request for cooperation from law enforcement or other government agency; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law. In such cases, we may raise or waive any legal objection or right available to us.
- Marketing Communications. Unless users opt out from receiving School marketing materials upon registration, the School may email users about its services that the School believes may be of interest to them. If you wish to opt out of receiving marketing materials from the School, you may do so by following the unsubscribe link in the email communications, by going to your account settings (if applicable), or contacting us using the contact information below.
- Third-party Service Providers. We may share your Personally-Identifying Information, which may include your name and contact information (including email address) with our authorized service providers that perform certain services on our behalf. These services may include providing marketing assistance, performing business and sales analysis, supporting the Website’s functionality and supporting features offered through the Website. We may also share your name, contact information, and credit card information with our authorized service providers who process credit card payments. These service providers may have access to personal information needed to perform their functions but are not permitted to share or use such information for any other purpose.
Changing Personally-Identifying Information; Account Termination
You may at any time review or change your Personally-Identifying Information by going to the Forms and Student Data Hub or the Application Portal, or by contacting us using the contact information below. Upon your request, we will deactivate or delete your account and contact information from our active databases. Such information will be deactivated or deleted as soon as practicable based on your account activity and accordance with our deactivation policy and applicable law. To make this request, either go to your account settings or contact us as provided below. We will retain in our files some Personally-Identifying Information to prevent fraud, to troubleshoot problems, to assist with any investigations, and to comply with legal requirements as is permitted by law. Therefore, you should not expect that all your Personally-Identifying Information will be completely removed from our databases in response to your requests.
The School uses the Personally-Identifying Information in the file we maintain about you, and other information we obtain from your current and past activities on the Website (1) to deliver the services that you have requested; (2) to manage your account and provide you with Website support; (3) to communicate with you by email, postal mail, telephone, and/or mobile devices; (4) to develop and display content tailored to your interests on the Website and other sites; (5) to resolve disputes and troubleshoot problems; (6) to measure consumer interest in our services; (7) to inform you of updates; (8) to customize your experience; (9) to detect and protect us against error, fraud, and other criminal activity; (10) to do as otherwise described to you at the time of collection. At times, we may look across multiple users to identify problems. In particular, we may examine your Personally-Identifying Information to identify users using multiple user IDs or aliases. We may compare and review your Personally-Identifying Information for accuracy and to detect errors and omissions. We may use financial information or payment method to process payment for any purchases made on the Website, to enroll you in programs in which you elect to participate, to protect against or identify possible fraudulent transactions, and otherwise as needed to manage our business.
Collection and Use of Information by Third Parties Generally
We take the security of your Personally-Identifying Information seriously and use reasonable electronic, personnel, and physical measures to protect it from loss, theft, alteration, or misuse. Please be advised, however, that even the best security measures cannot fully eliminate all risks. We cannot guarantee that only authorized persons will view your information. We are not responsible for third-party circumvention of any privacy settings or security measures.
We are dedicated to the protection of all information on the Website; however, you are responsible for maintaining the confidentiality of your Personally-Identifying Information by keeping your password confidential. You should change your password immediately if you believe someone has gained unauthorized access to it or your account. If you lose control of your account, you should notify us immediately.
The Children’s Online Privacy Protection Act (“COPPA”) protects the online privacy of children under 13 years of age. We do not knowingly collect or maintain Personally-Identifying Information from anyone under the age of 13, unless or except as permitted by law. We do, however, collect information about children under 13 years of age as a necessary step in accepting applications for our preschool through 5th grade school, exclusively from or on behalf of a parent or guardian. Any person who provides Personally-Identifying Information through the Website represents to us that he or she is 13 years of age or older. Any person who provides Personally-Identifying Information about a person under the age of 13 represents to us that he or she is 13 years of age or older and either is the parent or guardian of that child or is acting as the legal agent of a parent or guardian of that child. If we learn that Personally-Identifying Information has been collected from a user under 13 years of age on or through the Website – or that information about a child under 13 years old was provided without the consent of that child’s parent or guardian – we will take the appropriate steps to cause this information to be deleted.
California Privacy Rights
California Civil Code Section 1798.83, also known as the “Shine the Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about Personally-Identifying Information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of the Personally-Identifying Information that was shared and the names and addresses of all third parties with which we shared Personally-Identifying Information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to our Communications Office, as listed below.
Most web browsers and some mobile operating systems include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. Because there is not yet a common understanding of how to interpret the DNT signal, the Website currently does not respond to DNT browser signals or mechanisms.
Phillips Brooks School
Attn: Communications Office
2245 Avy Avenue
Menlo Park, CA 94025