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.
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.
This Policy applies to:
Unless we say otherwise, the terms of this Policy apply to all AYA Students, Host Family Contacts, other host family members and Visitors.
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:
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”).
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”).
We collect the following personal information from and about you:
If you are an AYA Student:
when applying to take part in the Program and/or as part of the placement process:
when taking part or after taking part in the Program:
If you are a Host Family Contact:
when taking part or after taking part in the Program:
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 be not be able to consider you for the Program (where that information is necessary for us to do so). We will only process personal information where we have a valid lawful basis to do so.
How we use your information:
If you are an AYA Student:
All of the information that you submit as a part of your AYA student application and any additional documents submitted on the AYA Student Portal, will be shared with AYA staff, AYA Local Coordinators , potential vetted AYA Host Families and potential U.S. High Schools.
If you are an AYA Host Family Contact:
All of the information that you submit as a part of your AYA Host Family application and any additional documents submitted on the AYA Host Family Portal will be shared with the AYA staff, the AYA Student that you select to host and the student’s Overseas Partner.
If you are a Visitor to the AYA Website:
Anonymous information to analyse traffic to the Academic Year in America Website.
More about the information we use and why
Where we have a legal basis to use your personal information without consent (as we have described above), this Policy 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 consent is required for our use of your personal information, we will ask you to positively opt-in by ticking the appropriate consent box or otherwise communicating your consent. For example, if you are an AYA Student, we will only share your full applications and medical or health details with host families if you consent when we first collect this information from you as part of your application to the Program, and you may withdraw this consent at any time prior to your enrollment in the program. Once you are an active participant in the program, you must remain in contact with AYA so we can administer the program for you.
Where you provide us with personal information relating to other individuals (for example, if you are an AYA Student and you give us your emergency contact’s name and telephone number, 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).
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 tables 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:
In addition, if you are an AYA Student:
In addition, if you are a Host Family Contact:
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 or a Host Family Contact and you:
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).
Please contact our data protection officer if you would like further details on how long we retain your information (see HOW TO CONTACT AYA).
This section is only relevant to AYA Students or 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.
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.
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 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.
By law you have the right to:
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.
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.
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.
We keep this Policy under regular review and will post any updates on this webpage. This Policy was last updated in May 2018.
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.
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/.
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