This Policy applies when you interact with School Group, including when you make a donation, register for an event, sign up for a newsletter, or otherwise provide School Group with information via the School Group website located at www.schoolgroup.org, or any other domain name owned or controlled by School Group. The Policy also applies to personal data you may provide to School Group via telephone, email, regular mail, social media, text messaging, mobile applications, at a special event, in response to a solicitation, or face-to-face.
Minors: School Group shall not knowingly solicit any personally identifiable information from children under the age of 13. Children under 13 are not authorized to make a donation, sign up for an event or program, or otherwise provide any personally identifiable information without consent from a parent or legal guardian.
II. What information do we collect?
Information you provide us
We may collect different information from or about you depending on how you interact with School Group. For example, we collect your personal data when you voluntarily provide it to us including your email address, country of residence, and your contact information.
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 also obtain your personal data directly when you make a donation, sign up for one of our events, or when you communicate with us directly in some other way.
It is always your choice whether to provide this personal data. However, some personal data must be provided to participate in certain programs, activities, or events (such as to sign up for a newsletter, apply for a position, or register to participate in one of our events), so the decision not to provide information might limit or eliminate certain functions of our sites or your ability to participate.
Data we receive from third parties and other sources
a. When you give it to another School Group organizationfroma different country (“Global Affiliate”)
We may obtain your personal information indirectly when you sign up for an event sponsored by a Global Affiliate, such as a campaign or pilot program. In such cases, the Global Affiliate 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.
Each Global Affiliate or School Group Global Chapter is responsible for its own compliance with local data protection laws and regulations.
b. When you give it to School Group indirectly
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.
c. 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.
d. 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.
III. How will we use your data?
We use, hold, and process your 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 School Group website’s terms of service.
- Perform other functions as described at the time School Group collects information.
If you make a donation 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 to provide information about upcoming programs.
Unless we are informed that we do not have 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 may 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 School Group your consent to send marketing information, School Group 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 School Group 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 donation, for example, monthly.
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 School Group 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 donation to School Group or a Global Affiliate. 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 Global Affiliate.
Use of personal data for School Group operations:
School Group will use your personal data for the following purposes:
a. 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 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 implement any instructions, you give us to with regard to withdrawing consent to send marketing information; and
- to use IP addresses to identify the location of users, to block disruptive use and to establish the number of visits from different countries.
b. For marketing and fundraising
Personal data may be used for marketing and fundraising purposes under the circumstances described in section III above.
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.
IV. When do we share your data?
Sharing of information within the School Group network
We may share your data with a Global Affiliate, 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 in receiving updates about the Global Affiliate programs and campaigns. Before we will share your personal data, School Group requires that the Global Affiliate receiving the data (the “Receiving Organization”) to 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 Global Affiliate 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 Global Affiliate that hosts the event (the “Hosting Organization”) 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.
Sharing of 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).
V. 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 (i.e. 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 for our organization. School Group may keep provided data 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.
VI. How to control what we send you and update or control your personal information
The accuracy of your information is important to School Group. 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 or update your information, email us at [email protected] , or write to us:
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 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.
European Union (General Data Protection Regulation): 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. 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.
School Group would like to make sure you are fully aware of all of your data protection rights. You are entitled to the following:
- The right to access – You have the right to request copies of your personal data held by School Group.
- The right to rectification – You have the right to request corrections to any personal data you believe is inaccurate. You also have the right to request for us to complete personal information you believe is incomplete.
- The right to erasure – You have the right to request that we erase your personal data, under certain conditions.
- The right to restrict processing – You have the right to request that we restrict the processing of your personal data, under certain conditions.
- The right to object to processing – You have the right to object to us processing your personal data, under certain conditions.
- The right to data portability – You have the right to request that we transfer the data we have collected to another organization, or directly to you, under certain conditions.
Please address rights requests, or questions or complaints about this Policy, to the Data Privacy Manager: 1700 Atlas RD, Cedar Park, TX USA 78613, or at [email protected].org.
Canada (Personal Information Protection and Electronic Documents Act): This Policy complies with the Personal Information Protection and Electronic Documents Act. If you want to review, verify or correct your personal information, please contact our Data Privacy Manager (contact details above). Please note that any such communication must be in writing.
When requesting access to your personal information, please note that we may request specific information from you to enable us to confirm your identity and right to access, as well as to search for and provide you with the personal information that we hold about you.
Your right to access the personal information that we hold about you is not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal information that we hold about you. In addition, the personal information may have been destroyed, erased or made anonymous in accordance with our record retention obligations and practices. In the event that we cannot provide you with access to your personal information, we will endeavor to inform you of the reasons why, subject to any legal or regulatory restrictions.
VII. 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 password–protected and/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 School Group, 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 Global Affiliate, the Global Affiliate 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.
This Policy may be updated from time to time, so you may wish to check it each time you submit personal information to School Group. The date of the most recent revisions will appear on this page. If you do not agree to these changes, please do not continue to use the School Group website to submit personal information to School Group. If material changes are made to the Policy, we will notify you by placing a prominent notice on the website.