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PRIVACY POLICY

Solebury School 
Privacy Policy

Last updated: June 20, 2024

Solebury School (“Solebury,” “we” or “us”) is committed to protecting your privacy.  This privacy policy (“Policy”) describes how we collect, use, disclose, and otherwise process your personal information.

Please read this Policy carefully. It is your choice whether or not to provide personal information to us. If you choose to do so, you are giving us your express consent to use, process, and disclose your personal information as set forth in this Policy. If you choose not to provide your personal information to us, you may not be able to use the full extent of our Website.

1. Scope of this Policy

This Policy is intended to describe how we process personal information relating to:

  • the use of our websites that link to this Policy, including https://www.solebury.org/ (“Website”), 
  • information that we collect from and about students, applicants, families of students and applicants, alumni, volunteers, donors, and potential donors, whether through our Website or through other means, and
  • when you communicate with us electronically, including via email, messaging, and social media platforms. 

This Policy does not apply to information that:

  • is collected by any third party, including through any application or content that may link to or be accessible from or on the Website, and
  • personal information relating to our employee and non-employee workers, job applicants, job candidates, or independent contractors.  

In this Policy, “personal information” means information relating to an identified or identifiable natural person. An identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identified such as a name, an identification number, location data, and online identified or to one or more factors specific to his/her physical, physiological, genetic, mental, economic, cultural, or social identity. Personal information does not include aggregate information or de-identified information, meaning that the information can no longer be attributed to an identifiable natural person without the use of additional information.

Personal information is required for us to be able to provide certain features of our Website or services to you. In addition, some of the services we provide require that we disclose your personal information to third parties, such as to service providers that help us to provide those services. If you are not willing to provide your personal information and have it disclosed to third parties in accordance with this Policy, you will not be able to use certain features of our Website or services.

Our Website may contain links that enable you to share content on social media, links to other websites, and link to third-party apps that do not operate under this Policy. These third-party services, websites, and apps may independently solicit and collect personal information from you. We encourage you to review the privacy statements of all third-party websites you visit to understand their privacy practices.

While we strongly support the protection of privacy on the Internet, we do not have control over, and cannot be responsible for, the actions of third parties. We encourage you to review each such third party’s privacy statement and otherwise understand its privacy practices, before providing personal information directly to it.

2. Personal Information We Collect and How We Collect It

We collect personal information from and about users of our Website, students, applicants, alumni, donors, and potential donors.  You provide some of this information directly, such as when you complete an online form or contact us. We also may collect some of your information, such as your IP address, automatically when you visit and use our Website.

We collect the following information:

  • Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.
  • Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, social security number, date of birth, gender, marital status, physical characteristics or description, address, telephone number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, background check information, criminal history information, beneficiary/dependents information, or any other financial information, medical information, or health insurance information.
  • Audio, video, and photographic images.
  • Visa and I20 information from our international students and applicants.
  • Internet or other electronic network activity information.
  • Professional or employment-related information.
  • Education information.

We may use various technologies to automatically collect information from your computer or device and about your activities on our Website.  

The technologies we may use for automatic information collection include:

  • Google Analytics.  We may use Google Analytics provided by Google Inc. Google Analytics uses cookies to collect the information identified above, for example, information about the operating system and the browser that you use, your IP address, the website you previously accessed (referrer URL) and the date and time of your visit to the Website.  On subsequent repeated visits to the Website, frequently used information is automatically displayed for you.  We are able to track your usage patterns with the help of the cookies. The information generated by cookies about the use of the Website is transmitted to a Google server, which may be located within or outside of the United States, and stored there. Google will use this information to evaluate your use of the Website.  Google may transfer these rights to third parties insofar as it is required to do so by law or in order that data may be processed on Google’s behalf. By accepting this policy, you consent to the processing of your data by Google.  You can learn about how Google Analytics collects and processes data here. 
  • Cookies. When you visit our Website, we may assign your device one or more cookies to facilitate access to our site and to personalize your online experience. Through the use of a cookie, we also may automatically collect information about your online activity on our site, such as the web pages you visit, the links you click, and the searches you conduct on our site. Most browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies. If you choose to decline cookies please note that you may not be able to sign in or use some of the interactive features offered on our Website. A cookie is a small text file that is stored on a user’s computer for record keeping purposes. Cookies can be either session cookies or persistent cookies. A session cookie expires when you close your browser and is used to make it easier for you to navigate our website. A persistent cookie remains on your hard drive for an extended period of time. We may allow our authorized service providers to serve cookies from our website to allow them to assist us in various activities, such as doing analysis and research on the effectiveness of our site, content and advertising. You may delete or decline cookies by changing your browser settings (click “Help” in the toolbar of most browsers for instructions). If you do so, some of the features and services of our Website may not function properly.

3. How We Use Personal Information

While the purposes for which we may process personal data will vary depending upon the circumstances, in general we use personal information for the purposes set forth below.

We may use information that we collect about you to:

  • deliver the services or information that you have requested
  • perform research and analysis about your use of, or interest in, our Website
  • manage our business and perform functions as otherwise described to you at the time of collection
  • advertising, marketing and promotional purposes, including sharing content on social media platforms
  • protect against or identify possible fraud
  • help to ensure security and integrity
  • legal compliance purposes

We may de-identify personal information and create anonymous and aggregated data sets and reports in order to assess, improve and develop our business, products and services, and for other research, marketing and analytics purposes.

4. Sharing of Personal Information

As discussed more fully below, we share your personal information as necessary to provide the services you request, including sharing information with service providers; when required by law; to protect rights and safety, and with your consent.

We may share personal information with:

  • Our service providers: We may share your personal information with our authorized service providers that perform certain services on our behalf. These services may include customer relationship management software; website hosting; web forms for questionnaires; email marketing vendors; providing customer service; performing business and operations analysis; conducting surveys; payment processors; educational consultants; and supporting our Website. 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 purposes.

We also may disclose your information:

  • In response to a subpoena or similar investigative demand, a court order, or a request for cooperation from a 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.
  • When we believe disclosure is appropriate 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 our company, our users, our employees, or others; to comply with applicable law or cooperate with law enforcement; or to enforce our terms and conditions or other agreements or policies.
  • In connection with a substantial corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.
  • When you provide us with your consent to share your information with third parties.

Third-Party Privacy Policies: Any third parties to whom we may disclose personal information may have their own privacy policies which describe how they use and disclose personal information. Those policies will govern use, handling and disclosure of your personal information once we have shared it with those third parties as described in this Policy. If you want to learn more about their privacy practices, we encourage you to visit the websites of those third parties. These entities or their servers may be located either inside or outside the United States.

5. Your Privacy Rights and Choices 

A. How You Can Request to Access and Amend, Your Information

You may request to review, update, amend, or otherwise access your personal information that we collected or otherwise maintain subject to certain limitations under applicable laws.  You may submit a request to us by using the contact information provided at the end of this Policy. 

We will respond to your request as soon as practicable for us and in the time frames provided under any applicable laws.  

B. Your Choices About Collection and Use of Your Information

You can choose not to provide us with certain information, but that may result in you being unable to use certain features of our Website.

C. Opt-Out

You may be given a choice as to whether you want to receive marketing or promotional e-mails or newsletters from us. At any time you can choose to no longer receive marketing or promotional emails or newsletters from us by modifying your email preferences by selecting the “Opt-Out” link found in the footer of the communication. You may modify your choice at any time by using the “Opt-Out” link as described above. It may take up to 10 business days for us to process an opt-out request. Please note that opting out of receipt of promotional email communications will only affect future activities or communications from us. If we have already provided your information to a third party before you have changed your preferences or updated your information, you may have to change your preferences directly with that third party.
Even if you opt-out of receiving marketing or promotional communications, you may continue to receive other types of transactional and relationship email communications, such as sending you a survey you have elected to participate in.

6. Data Retention 

We will retain your personal information to fulfill the purposes outlined in this Policy. We may retain personal information where required by our regulatory obligations or professional indemnity obligations, or where we believe it is necessary to establish, defend or protect our legal rights and interests or those of others.

We will also retain usage data for internal analysis, to strengthen the security, or to improve the functionality of our Website.

7. Security

While we are focused on the security of your personal information and follow standards, processes and procedures that are designed to protect your personal information, you must remember that the Internet is a global communications vehicle open to threats, viruses and intrusions from others and so we cannot promise, and you should not expect, that we will be able to protect your personal information at all times and in all circumstances.

You should also take care with how you handle and disclose your personal information and should avoid sending personal information through insecure email. Please refer to the Federal Trade Commission’s website at https://www.ftc.gov for information about how to protect yourself against identity theft.

8. No Rights of Third Parties

This Policy does not create rights enforceable by third parties.

9. Changes to this Policy

We may modify this Policy from time to time and will notify you of any updates to our Policy by posting the revised Policy on our Website. The last updated date set forth at the top indicates the last time we revised this Policy. We encourage you to review the Policy each time you visit our Website to see if this Policy has been updated since your last visit. 

10. Additional Information for Residents of the United Kingdom and the European Union

A. Legal Basis for Processing

If you reside in the United Kingdom of the European Union, our legal basis for processing your personal information will depend on the personal information concerned and the specific context in which we collect it.

When we have collected your personal data to provide you with services that you have requested, our legal basis for the processing of that personal data is that it is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract. If you refuse to provide us with your personal data, you may be unable to obtain the products and services from us that you requested.

We also collect and process personal information about you as necessary to provide our educational services, meet our contractual and legal obligations, and/or fulfill our other legitimate interests (when not overridden by your data protection interests or fundamental rights and freedoms).

If you have any questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided below.

B. Transfer of Personal Data to Countries Outside the United Kingdom and the European Union

Your personal information may be transferred to, stored, and processed within the United States. Additionally, we may transfer your personal information to other countries in certain circumstances, for example because a server or third-party service provider is located there. BY PROVIDING YOUR PERSONAL INFORMATION TO US, YOU ARE CONSENTING TO ANY TRANSFER, STORAGE, AND PROCESSING IN ACCORDANCE WITH THIS POLICY.

There are potential risks to you associated with transferring your information to the United States due to the absence of an adequacy decision and appropriate safeguards. These risks include the risk that you will not be able to exercise your data protection rights under applicable law to protect yourself from unlawful use or disclosure of your information. The data protection and privacy laws of other countries, including the United States, may not afford you the same level of protection as those in your own country.

IF YOU RESIDE IN THE UNITED KINGDOM, THE EUROPEAN UNION, OR OTHER REGIONS WITH LAWS GOVERNING DATA COLLECTION AND USE AND YOU PROVIDE US WITH YOUR PERSONAL INFORMATION, YOU ARE AGREEING TO THE TRANSFER OF YOUR PERSONAL INFORMATION TO THE UNITED STATES AND POSSIBLY OTHER JURISDICTIONS.

C. Your Privacy Rights

If you are an individual located in the United Kingdom or the European Union, you may have additional rights available to you under applicable laws, including:

  • You have the right to request access to your personal data, and the rectification of inaccurate personal data concerning you. 
  • You have the right to obtain the deletion or the restriction of processing of your personal data in certain circumstances, including when the data are no longer necessary in relation to the purposes for which they were collected or otherwise processed, except when we are required by applicable law to maintain or otherwise process your personal data, for the establishment, exercise, or defense of legal claims, or for the protection of the rights or another person. 
  • You may have the right to request that we stop processing your personal information and/or to stop sending you marketing communications. 
  • In certain circumstances, you may have the right to be provided with your personal information in a structured, machine readable and commonly used format and to request that we transfer the personal information to another data controller without hindrance. 
  • Where our processing of your personal information is based on your consent, you have the right to withdraw your consent at any time. This does not affect the lawfulness of the processing based on consent before its withdrawal. 
  • You also have the right to lodge a complaint with a supervisory authority, in particular in the country of your habitual residence, place of work, or place of an alleged infringement of the applicable data protection law.

You may exercise these rights by contacting us using the contact information provided below. To protect your privacy and security, we may take steps to verify your identity before taking action on your request.

11. Contact Us

If you have any questions about this Policy or our privacy practices, please contact us by e-mail or postal mail as follows:

Solebury Privacy Policy

privacy@solebury.org

Solebury School
6832 Phillips Mill Road
New Hope, PA 18938
215.862.5261