Privacy Statement and Policy
NOVEMBER 11, 2019
Minors: It is School Group’s policy not to solicit knowingly any personally identifiable information from children under the age of 13. Children under 13 are not authorized to make a donation or purchase, sign up for an event or program, or otherwise provide any personally identifiable information without consent from a parent or legal guardian.
What about data you provide to other School Group organizations?
Outside the U.S. and Canada: Each School Group Global Organization is responsible for its own compliance with local data protection laws and regulations.
Sharing of information within the School Group network: We may share your data with a School Group Global Organization, such as in connection with your participation in a global pilot program, or to enable a School Group Global Extension where you have expressed interest to update you about its own programs and campaigns. Before we will share your personal data, School Group requires that the School Group School Group Global Organization receiving the data (the “Receiving Organization”) maintain security controls that will assure that your data is securely stored and accessible only by appropriately trained personnel. Unless you inform us that you do not consent, Receiving Organizations may in the future contact you about their own programs and activities.
Likewise, when you provide personal data to a School Group Global Organization in connection with your participation in a global pilot program or other international volunteer event that School Group sponsors, your personal data may be shared between (i) the Receiving Organization and any other School Group School Group Global Organization that hosts the event and (ii) the Receiving Organization and School Group. Unless you inform School Group or the Receiving Organization that you do not consent to marketing by Hosting Organization, the Hosting Organization may also contact you about its own programs and activities in the future.
III. Why do we hold and process personal data?
School Group may request from you, or you may volunteer to provide, your contact information, including your name, mailing address, phone number(s), social media handles and email address(es). We hold and process supporters’ personal data for a number of reasons:
To keep a record of donations made and actions taken by our supporters and our communications with them
To send our supporters marketing information about our projects, fundraising activities and appeals where we have their consent or are otherwise permitted to do so
To fulfil contractual obligations entered into with supporters
To support volunteers, such as during campaigns or fundraising events
To support global based fundraising and campaigning
To ensure we do not send unwanted information to supporters or members of the public who have informed us they do not wish to be contacted
Manage supporters’ accounts and provide customer service.
Offer sweepstakes, contests, giveaways or other promotions.
Enforce the Website terms of service.
Perform other functions as described at the time School Group collects information.
If you make a donation or a purchase with School Group, or otherwise provide us your information, School Group may contact you from time to time about opportunities to make additional donations or purchases or to provide you information about upcoming programs.
Unless we are informed that we do not have consent (see guidelines below for modifying your consent), School Group may also share the data of its U.S. and Canadian resident supporters with select third-party sponsors, service providers and other organizations with which School Group partners, whose products and services may be of interest to those supporters. We may also provide our U.S. and Canadian resident supporters with information about services from third parties. See guidelines for modifying your consent (below, at “How to control what we send you or update your personal information”).
When will we send you personalized marketing communications?
School Group will contact you for marketing purposes—for example, to keep you up to date on our work, or let you know how you can support that work—only where we have your consent or we are otherwise allowed to do so because of your prior engagement with School Group, as explained further below (see “Our Reliance on Your Prior Support”).
We will make it easy for you to tell us if you would like to receive marketing communications from us and hear more about our work and the ways in which you would like to receive this information. We will not send you marketing material if you tell us that you do not wish to receive it. Instructions for how to do so are below (see “How to control what we send you or update your personal information”).
Duration: Where you give us your consent to send marketing information, we will wherever possible let you know how long this consent will last. School Group will presume your consent to last for 24 months, unless you withhold consent to this duration (see below, “How to control what we send you or update your personal information”). After this time, in order for us to continue to update you, School Group will seek your refreshed consent. You can update or withdraw your consent at any time.
School Group will presume a longer period of consent in several exceptions:
Where you have committed to making a regular (for example, monthly) donation.
In this situation, and unless you withdraw your consent, we will treat consent as lasting until you cancel your donation, at which point your consent will expire 24 months after the last donation. This period allows School Group to keep you up to date with the impact of your contributions, and to ask whether alternative support would be of interest.
Where you have notified us that you will be leaving a legacy to School Group.
Our Reliance on Your Prior Support: You may also receive marketing information from School Group if you have previously made a similar donation to, or have previously purchased similar goods and services from, School Group, a School Group Affiliate, or a School Group School Group Global Organization. However, we will not rely on your prior support as the basis for our continued marketing to you if you have opted out of receiving emails, newsletters, or other marketing materials in your communications to School Group or a School Group School Group Global Organization.
How and when do we obtain information about you?
School Group may obtain your personal data in the following circumstances:
When you give it to School Group
We will obtain your personal data directly when you make a donation, sign up for one of our events, purchase products from the School Group on-line retail store, or when you communicate with us directly in some other way.
When you give it to a School Group School Group Global Organization
We may obtain your personal information indirectly when you sign up for an event sponsored by a School Group Global Organization, such as a campaign or pilot program. In such cases, the School Group School Group Global Organization will share your data with School Group to enable us to contact you about your campaign or about future School Group programs and support opportunities. It may also be shared if it is a necessary part of completing a contract or other legal obligations to you in connection with your participation in an event.
When you give it to School Group indirectly
We will obtain your personal data when you communicate to your employer or to a retail partner of School Group during your point of purchase that you affirmatively designate School Group to receive a personal contribution from you.
Sometimes your personal data is collected by an organization working on School Group’s behalf (for example, a client management system). In such cases, the agency is acting on our behalf, and we are the “data controller” responsible for the security and proper processing of your data, just as if you had given it to School Group directly.
When you access School Group’s sponsored social media
We might also obtain your personal data through your use of social media such as Facebook, WhatsApp, Twitter or LinkedIn, depending on your settings or the privacy policies of these social media and messaging services. To change your settings on these services, please refer to their privacy notices, which will tell you how to do this.
When the information is publicly available
We might also obtain personal data about individuals who may be interested in giving major gifts to charities or organizations like School Group. In these cases, we may seek to find out more about these individuals’ interests and motivations for giving through publicly available information. The information sources may include newspaper or other media coverage, open postings on social media sites such as LinkedIn, and services that aggregate data on charitable giving. School Group will not retain publicly available data relating to major donors without their consent, which will be sought at the earliest practical opportunity.
What personal information might School Group collect?
School Group will only collect personal data about you that is relevant to the type of transaction or project you have engaged in with us.
For example, we may receive and retain personal information about you when you contact School Group to make a donation, purchase an item at The School Group Store online, or sign up to any of School Group’s activities or online content (such as newsletters or message boards); or when you telephone, email, or write to us, or engage with us via social media channels. In each of these cases, the information we collect is relevant to the type of transaction you are entering into. Data such as your name email or postal address, telephone or mobile number will be necessary both to execute these transactions as well as to enable us contact you for further engagement. Bank account or credit card details will be necessary to process any donations. Age and travel restrictions will be relevant if you are signing up for an international build.
Sensitive Personal Data: We do not collect your “sensitive personal data” (e.g., health or dietary information) unless there is a clear reason for doing so—such as your participation in a sponsored physical event or a Global Village build—and then only to the extent such data is required to ensure that we provide appropriate facilities or support to enable you to participate in the event.
Should you support School Group in a substantial way, we may provide an account manager to help tailor your relationship to us and the information you receive from us to suit your interests. If this is the case, we may collect sensitive personal data where relevant to our relationship, such as your political or religious views. If you provide us with information about your health or your family, this may also be recorded so we can communicate with you in a considerate and appropriate manner.
All sensitive personal data is stored on a password-protected system to which only a limited number of relevant staff have access. It is deleted when no longer needed by us, is never shared with third parties, and is available to you at any point should you wish to see it.
VII. How will School Group use your personal data?
School Group will use your personal information for the following purposes:
For administrative reasons, including:
“service administration”, which means that School Group may contact you for reasons related to administering any donations you have made, the completion of commercial or other transactions you have entered into with us, or the activity or online content you have signed up for;
to confirm receipt of donations (unless you have asked us not to do this), and to say thank you and provide details of how your donation might be used;
in relation to correspondence you have entered into with us whether by letter, email, text, social media, message board or any other means, and to contact you about any content you provide;
for internal record keeping so as to keep a record of your relationship with us;
to complete sales transactions you have entered into with us, for example at The School Group Store;
to implement any instructions, you give us to with regard to withdrawing consent to send marketing information;
to use IP addresses to identify the location of users, to block disruptive use and to establish the number of visits from different countries.
For marketing and fundraising
Sections III and IV above describe what data may be used for marketing and fundraising purposes and under what circumstances.
To analyze and improve the activities and content offered by the School Group website to provide you with the most user-friendly navigation experience. We may also use and disclose personal information in aggregate (so that no individuals are identified) for marketing and strategic development purposes.
VIII. Will we share your information outside the School Group network?
If you reside in the U.S. or Canada, and unless you instruct us otherwise, School Group may share your personal data with organizations with which School Group partners, as well as other companies whose products and services may be of interest to you. In these cases, we may also provide you with information about services from third parties, unless you inform us that you do not want to receive this information.
School Group’s suppliers: We may need to share your information with service providers who help deliver our projects and fundraising activities. These “data processors” will only act under our instruction and are subject to contractual obligations containing strict data protection clauses. We do not allow these organizations to use your data for their own purposes or disclose it to other third parties without our consent, and we will take all reasonable care to ensure that they keep your data secure.
Facebook and other Social Media Sites: We may also use your email address and phone number to match to your Facebook or other social media account in order to show you School Group content while you use those services. We only do this where you have consented to receiving marketing emails, either by opting in (where you reside in the European Economic Area) or by not opting out (where you reside in the United States and Canada). In addition, we may also use your email address and phone number to link to Facebook or other social media sites in order to identify other users of these sites whom we believe would be interested in School Group.
There are two ways to prevent this use of your data. You can either update your consent preferences directly with us at School Group (see below, “How to control what we send you or update your personal information”) or via the social media sites.
Updating your preferences with School Group will not guarantee that you never see School Group content on social media, since the social media site may select you based on other criteria.
Where legally required: We will also comply with legal requests where disclosure is required or permitted by law (for example to government bodies for tax purposes or law enforcement agencies for the prevention and detection of crime, subject to such bodies providing us with a relevant request in writing).
How long will School Group keep your personal information?
We will hold your personal information on our systems only for as long as you continue to provide your consent, which consent will be presumed to expire after 24 months. Beyond that, we will hold your information only for as long as necessary to comply with our legal and regulatory obligations—such as, for example, to provide documentation on funding sources in connection with a review or audit of our compliance with U.S.C. Sec. 501(c)(3).
If you request that we stop sending you marketing materials, we will keep a record of your contact details and appropriate information to enable us to comply with your request not to be contacted by us.
Legacy income is vital to the running of the charity. We may keep data you provide to us indefinitely, to carry out legacy administration and communicate effectively with the families of people leaving us legacies. This also enables us to identify and analyze the source of legacy income we receive.
How to control what we send you and update your personal information
The accuracy of your information is important to us. We want to ensure that we are able to communicate with you in ways that you are happy with, and to provide you with information that is of interest.
If you wish to change how we communicate with you, or update the information we hold, then please contact us:
To amend your contact preferences for any type of communication, email us at [email protected] , or write to us at: Data Privacy Manager; 1700 Atlas RD
Cedar Park, TX USA 78613 (to amend your preferences for any communication channel);
To amend your contact preferences for newsletters, reply to the newsletter via the email account from which the communication was received.
Additionally, you can opt out of marketing emails at any time by clicking the unsubscribe link in any marketing email from School Group.
Timing of implementation. In responding to requests to not receive marketing information, we will make take all reasonable efforts to meet the following service levels:
Email: 48 hours from receipt of email
SMS: 48 hours from receipt of SMS
Mail: 28 days from receipt of ‘do not mail’ request. This period is longer than for other channels due to the production times for mailing campaigns, and in most cases, we would expect the change to be effective much more quickly.
If you are a resident of the European Economic Area and your country has adopted the provisions of the General Data Protection Regulation, you have the right to request a copy of the personal information we hold about you, to have any inaccuracies corrected, and to have any personal information deleted from our systems (a “Subject Access Request” or “SAR”). In line with standard guidelines for these requests, we will require you to prove your identity with two pieces of approved identification. We will respond to such requests within 30 days of receipt.
How School Group keeps your data safe
We ensure that there are appropriate technical controls in place to protect your personal details. For example, our online forms that ask for personal information are stored on networks that are password-protected and routinely monitored. Laptops are not used to store sensitive personal information unless they are both password protected or encrypted. All sensitive personal data is stored on a secure database, to which only a limited number of relevant staff have access. It is deleted when no longer needed by us, is never shared with third parties, and is available to you at any point should you wish to see it.
Within School Group, we undertake regular reviews of who has access to information that we hold to ensure that your information is only accessible by appropriately trained staff, volunteers and contractors. Where we share your personal data with a School Group School Group Global Organization, the School Group Global Organization is required to take comparable steps to assure that your information is securely stored and accessed only by appropriately trained personnel.
We use external companies to collect or process personal data on our behalf. We do comprehensive checks on these companies before we work with them, and in our legal agreements, we clearly set out our requirements regarding how they manage the personal data to which they have access. We have a robust partner-monitoring framework to ensure these contractual obligations are met.
School Group Cookies Policy
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measuring how many people are using each page of the website and for how long so that we can try to improve the quality of our website;
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If you reside in the United States or Canada, cookies may also be used for “re-targeting” in advertising campaigns so that third-party vendors can display advertising to you about School Group or other related entities as you use the internet.
How to manage and delete cookies. If you wish to restrict or block the cookies set by the School Group website, you can do this through your computer or device’s browser settings. The Help function within your browser should tell you how.
Alternatively, you may wish to visit www.aboutcookies.org, which contains comprehensive information on how to do this on a wide variety of browsers. You will also find details on how to delete cookies from your computer as well as more general information about cookies.
Please be aware that restricting cookies may affect the functionality of the School Group website.
If you visit our website as an anonymous visitor (e.g. you switch off cookies), School Group may still collect certain information from your browser, such as the IP address (which uniquely identifies a computer or other internet device).