Academic Year in America Privacy Policy

Academic Year in America is a program of the American Institute for Foreign Study Foundation, Inc (“AYA”).  Our contact details are at the end of this Policy (see HOW TO CONTACT AYA below).

AYA takes 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, c) our AYA Student Agreement or our Host Family Agreement (each as described in OTHER TERMS WHICH MAY APPLY TO YOU below), applies to personal information that we and/or third party Partners acting on our behalf (“our Partners”) collect about you.

Where we refer to the “Academic Year in America Website” in this Policy, we mean the website which can be accessed at https://www.academicyear.org website operated by us (including any updates or supplements to them), and where we refer to the “Program”, we mean the Academic Year in America program.

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

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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
• KEEPING YOUR INFORMATION SECURE
• UPDATING AND ACCESSING YOUR INFORMATION
• YOUR RIGHTS
• MARKETING
• OTHER WEBSITES
• CHANGES TO THIS POLICY
• HOW TO CONTACT AYA

 

WHO THIS POLICY APPLIES TO

This Policy applies to:

• “AYA Students”, i.e. someone who applies to the Program to become an AYA Student and/or who takes part in the Program as an AYA Student;
• “Parents of AYA Students”, i.e. a parent of an AYA Student;
• “Host Family Contacts”, i.e. someone who registers for or applies to the Program (on behalf of their family) to become a host family and/or who takes part in the Program as part of a host family;
• “Other host family members”, i.e. someone who is a family member living at the home where the AYA Student is intended to live; and
• “Visitors” to the Academic Year in America Website, i.e. someone who visits and/or uses the Academic Year in America Website but who does not register for or apply to the Program.

Unless we say otherwise, the terms of this Policy apply to all AYA Students, Parents of AYA Students, Host Family Contacts, other host family members and Visitors.

 

OTHER TERMS WHICH MAY APPLY TO YOU

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

WEBSITE TERMS OF USE
Our “Website Terms of Use” govern your use of the Academic Year in America Website.

COOKIE POLICY
Our “Cookie Policy” sets out information about the cookies we use on the Academic Year in America Website.

AYA STUDENT AGREEMENT
If you are an AYA Student, as part of your application to the Program, we will ask you to read, acknowledge and sign our terms and conditions for AYA Students (the “AYA Student Agreement”).

CONSENT / INFORMATION FORM If you are a AYA Student or a Parent of AYA Student: as part of the AYA Student’s application to the Program, you will need to read and agree to certain terms on how we handle your personal data in this form: AYA GDPR Terms. This covers how we use special data including health, dietary and religious data, as well as photos and videos of you, and why we need to share these with potential host families, your Host Family Contacts and/or your US school.

HOST FAMILY AGREEMENT
If you are a Host Family Contact, as part of your application to the Program, we will ask you to read, acknowledge and sign our terms and conditions for host families (the “Host Family Agreement”).

 

INFORMATION WE COLLECT (INCLUDING WHEN AND HOW WE COLLECT IT)

We collect the following personal information from and about you:

1. Information you give us
2. Information we collect when you visit the Academic Year in America Website 
3. Information provided by third parties

 Information you give us. You may give us information about you:

• when you register your interest in or apply to take part in the Program (whether as an AYA Student or a Host Family Contact);
• as part of the placement and matching process (for example, in any interviews or assessments you undertake);
• when you take part in the Program;
• when you use the Academic Year in America Website, for example, if you upload any documents or files that contain personal information;
• if you complete a survey or provide feedback on the Academic Year in America Website;
• when you report a problem with the Academic Year in America Website; and
• if you contact or correspond with us (for example, by phone, e-mail or otherwise) for any other reason.

Information we collect when you visit the Academic Year in America Website. Each time you visit the Academic Year in America 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 Academic Year in America 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 Academic Year in America Website, including the full Uniform Resource Locators (URL), clickstream to, through and from the Academic Year in America 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 Academic Year in America Website uses).

Information provided by third parties.

If you are an AYA Student:

when applying to take part in the Program and/or as part of the placement process:

• we will obtain information about you from our Partners, for example, in any interviews you undertake with those Partners;
• we may obtain details of your English language proficiency from the Partner that you worked with;

when taking part or after taking part in the Program:

• we may obtain feedback, comments, photos, or complaints about you from your host family, our Local Coordinators and/or others taking part in the Program.

If you are a Host Family Contact:

when taking part or after taking part in the Program:

• we may obtain feedback, comments or complaints about you or other host family members from AYA Students(s) and/or others taking part in the Program.

 

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, with our Partners and with the Academic Year in America Website, and your involvement 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 if this is the case, we may not be able to consider you for the Program (where that information is necessary for us to do so).

Most commonly, we will use your personal data in the following circumstances:

• To take steps prior to entering into our contract with you, or to perform our contract with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal obligation.

We set out in the table below a description of how we plan to use your personal data, and which of the lawful bases we rely on to do so.

Where more than one basis has been set out in the table below, please contact us if you need details about the specific legal basis, we are relying on to process your personal data.

Please also see our Consent/Information Form: AYA GDPR Terms, for information about how and why we use special data including health, dietary and religious data, as well as photos and videos of you.

 

 

More about the information we use and why

This Policy, together with the Consent/Information Form, 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 you provide us with emergency contact information relating to other individuals or you are a Host Family Contact and you give us details about other host family members, 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 AYA).

 

SHARING YOUR INFORMATION

We may share your personal information with your consent or as is necessary with selected third-party service providers, and other companies within our group that support us in the performance of the activities set out in the table above.

We require all our third-party service providers and all other companies within our group to take appropriate and stringent 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.

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 order to consider you for the Program or place you with a host family, 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 AYA Students, Host Family Contacts, or other host family members, or to operate and maintain the security of our computer systems.) 

We may share your health and medical information with medical professionals in case of a medical emergency while you are on the program.

Who will you share my personal information with?

We will share - and, in some cases, you will provide - certain information about you with and to the following third parties for purposes specified:

• we use Google Analytics to track your usage of the Academic Year in America website. We do so to improve our users’ experience of the Academic Year in America website and analyse website traffic.

In addition, if you are an AYA Student or Parent of AYA Student: :

• we will share certain non-identifiable information about you (including your first name, age, nationality, hobbies and interests) with Host Family Contacts when they agree to our privacy statement. We do so to enable Host Family Contacts to consider potential AYA Students for their family.
• we will share some of the information that we collect as part of your application to the Program with Host Family Contacts when they are fully vetted by our program and sign our Host Family Agreement.
• we will share your health information with Host Family Contacts and the high school that you are matched with, at the point the match is made. We do so to enable Host Family Contacts to assess any medical and/or health issues which are relevant to your role as an AYA Student and for high schools to enroll you in their school.
• we may share information that we collect as part of your application with our Partners and Local Coordinators. We do so to enable our Partners to assist us in interviewing, placing and matching you with a host family and supporting you throughout the program.
• we may share or ask you to share certain information (including your name, address, passport and/or visa details) with third party suppliers such as travel and accommodation providers (including airlines and hotels); insurance providers; embassies; and border control agencies, who will process that information. We do so to facilitate your travel to and from the U.S. and your stay in the U.S. as part of your participation in the Program.
• we may share or ask you to share certain information (including your name, address, passport and/or visa details) with embassies and government departments (including the Student Exchange Visitor Information Service (SEVIS) – US Department of State); who will process that information. We do so to progress your visa application and to comply with visa regulations as part of your participation in the Program.

In addition, if you are a Host Family Contact:

• we will share information about you and your family with any AYA Student that you have selected to host (and who has signed the AYA Student Agreement), in order that any such AYA Student can contact you.  Our Partner organization overseas will also receive the information contained in your host family application and other related documents.

 

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 determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorised use or disclosure of your information, the purposes for which we process your information and whether we can achieve those purposes through other means, and the applicable legal requirements.

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 an AYA Student, Parent of an AYA Student or a Host Family Contact and you:

• register your interest in or apply to take part in the Program but do not take part in the Program, we may retain some of your personal information (including your name and contact information you provided) for a period of 7 years following the date when you first complete your registration and/or application; for legal reasons; or
• take part in the Program, we will process your personal information while you take part in the Program, and may retain some of your information for a period of 7 years thereafter, for example, to keep in touch with you and/or for legal reasons. We will only retain information as necessary.

If you are a Visitor and you do not use the Academic Year in America Website for 1 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 keeping in touch about our services or for our promotional purposes (such as part of a blog post on the Academic Year in America Website or photos of you in our brochures, on our Website and on our social media posts).

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

 

TRANSFERRING YOUR INFORMATION OVERSEAS

This section is only relevant to AYA Students, Parents of AYA Students  and Visitors based in the European Economic Area (“EEA”).

If you are an AYA Student  based in the EEA, we will transfer, process, and store the information we collect from you to AYA and other relevant third parties (such as host families) based in the U.S. i.e., outside of the EEA. We do so as it is necessary for us and any host family to consider you for the Program, and so that you can take part in the Program.

If you are a Visitor based in the EEA, we will transfer, process, and store the information we collect from you to AYA and other relevant third parties based in the U.S. We do so as it is necessary for us to understand how the Academic Year in America Website is used and so that we can improve the Academic Year in America Website.

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.

 

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, Partners, contractors and other third parties who have a business need to know. We will require them only to process your information on our instructions and they are subject to a duty of confidentiality.

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 Academic Year in America Website; 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.

We have also put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

 

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 you would like us to stop using your personal information, please contact our data protection officer (see HOW TO CONTACT AYA).

Alternatively, if you are an AYA Student, Parent of an AYA Student or a Host Family Contact and you have completed an application to take part in the Program, you can access and amend most of your personal information by signing in to your account on the Academic Year in America Portal.  However, once we have shared your personal information as described in  SHARING YOUR INFORMATION above, you will be unable to amend that information by signing in to your account. If you would like to amend any of your personal information but you are unable to do so by signing in to your account on the Academic Year in America Website, please contact our data protection officer (see HOW TO CONTACT AYA).

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

Once you are enrolled as a participant in the program, AYA and your Partner organization must be able to remain in contact with you for the duration of the program until your departure from the U.S.

 

YOUR RIGHTS (EEA and UK residents only)

By law you 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 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 (or that of a third party) 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 your personal information 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 to consider you for the Program or for you to participate in the Program, we may not be able to do so. 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 AYA).

No fee usually required

You will not 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 help us confirm your identity and ensure 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.

Where you have provided your consent 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 AYA). 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

If you are an AYA Student or a Host Family Contact, 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 apply to take part in the Program. 

You have the right at any time to stop us from contacting you for marketing purposes or giving your information to other members of our group. 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 AYA).

We will not provide your personal information to any other third-party businesses for marketing purposes.

 

OTHER WEBSITES

The Academic Year in America Website contains links to other websites, including Facebook, Twitter and Instagram. This Policy only applies to the Academic Year in America 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 May 2023

 

HOW TO CONTACT AYA

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

We have appointed Gene Maillet as our USA Data Protection officer and Richard Howell as our UK 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 our data protection officer at dpo@AYA.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@AYA.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/.