AFS Intercultural Programs – Global Online Privacy Policy

Updated April 4, 2018

SUMMARY

  • AFS collects and uses personally identifiable information (PII) that you submit;
  • AFS collects and uses this PII for the purpose of providing AFS services, for marketing and communication in relation to these services, and for performing research;
  • For the purpose of providing its services, AFS may transfer this PII to AFS organizations and other parties involved in the provision of AFS services in your home country and in other countries;
  • AFS transfers this PII across international borders to securely store this information in other countries. Currently those locations are in the US, Germany and Thailand;
  • You have the right to access and update your PII at any time;
  • In some circumstances you have the right to request the erasure of your PII;
  • AFS may use (third party) cookies and other similar techniques to obtain information from you when using the AFS websites in order to facilitate your use of these websites;
  • If you are a minor and your parent’s/legal guardian’s consent is required for you to provide PII, ask for your parent’s/legal guardians for permission.

PII includes amongst other things, your name, your home and e-mail address, your date of birth, your (mobile) telephone number, schools and university attended, highest grade/qualification received, year of graduation, area of study, social media links, an image, photo or video of you, specific AFS program information (type, year, etc.), travel details, a personal statement, your CV or resumé, certain medical history and medical disclosures, as well as answers to specific questions.

Please note that this is only a summary of the entire Privacy Policy enabling the reader to have a quick understanding of the content of this Privacy Policy. This summary does not replace the Privacy Policy.

GOALS AND PURPOSE

AFS Intercultural Programs, Inc. (together with its Network Organizations and its Subsidiary, as those terms are defined below, collectively referred to herein as “AFS”) is dedicated to protecting your privacy and safeguarding your personally identifiable information. AFS works hard to create an online experience that is detailed, efficient and productive by using the information you entrust us responsibly. AFS is committed to respecting your privacy and adhering to the principles of applicable data protection and privacy laws throughout the world.

We have provided this Privacy Policy as an explanation of the information we collect, how we use it, how the use of this information can benefit your experience on our websites and during your relationship with us, with whom and for what purposes we may share the information, and the choices you can make about our use of the information. We also describe the measures we take to protect the security of the information and how you can contact us about our privacy practices. Our privacy practices may vary among the countries in which we operate to reflect local practices and legal requirements. We wish to help you make informed decisions, so please read the sections below.

 

 

AFS ONLINE

AFS Intercultural Programs operates many websites, either directly or through its Network Organizations (such as AFS-USA Inc.), its subsidiary (Sentio, Inc.) or through certain third-party service providers. These include, but are not limited to those located at the following domains:

Any one of these websites may ask for and/or collect personally identifiable information in order to provide you with the information and services you seek or to improve your experience, as detailed further below. Some of our websites (or certain areas within a particular website) are for the general public, while some websites or areas within such sites are only for organizations that are part of the AFS worldwide network of exchange organizations (and their authorized representatives) or for specifically designated and authorized third-parties that work closely with AFS to operate intercultural exchange programs and to provide online and real-world services to individuals (“Network Organizations”), e.g., AFS-USA, located at afsusa.org. Similarly, some websites (or certain areas within a particular website) are only for registered users (e.g., individuals who are prospective, current or former participants in the services and programs offered by AFS and its Subsidiary and Network Organizations (“Participants”)).

For purposes of this Privacy Policy, “Subsidiary” means Sentio, Inc., a not-for-profit organization established by AFS Intercultural Programs, Inc. and dedicated to mobility programs for adult participants. It should be noted that Network Organizations are separate legal entities that are part of the international network of AFS organizations operating AFS intercultural programs and activities worldwide under the standards policies and procedures established by AFS Intercultural Programs, Inc., including matching Participants in various locations throughout the world in order to fulfill the requests of Participants and provide the AFS intercultural programs and services. For more information, see THIRD-PARTY WEBSITES AND NETWORK WEBSITES

TYPES OF INFORMATION WE COLLECT

AFS collects information from visitors and users of our websites, including Participants, and from third-parties that work with AFS to deliver AFS’s services so that we can provide an experience (online and offline) that strives to meet our Participants’ and other users’ needs and interests. Information may be collected as part of: (i) providing AFS program services, (ii) fulfilling information requests, (iii) requesting or offering services, (iv) applying or registering for AFS program participation, (v) submitting an application or program opportunity, (vi) responding to communications from us (e.g., surveys, requests for additional information or reviews or application or registration confirmations), (vii) accommodating your personal preferences, (viii) fulfilling requests for services, e.g., subscribing to newsletters or participating in promotions or sweepstakes, (ix) working with third-party sources, including collecting information available from certain social networking and other websites to better assist us with understanding your interests and to serve you better, (x) updating your information including your contact information, (xi) keeping you informed about and involved with AFS activities, or (xii) conducting fundraising campaigns.

The types of personally identifiable information (sometimes referred to as “PII”) that we ask for and/or collect depend on your level of access and participation within our websites (and the types of services, information and participation you are seeking, such as applying for or participating on an AFS intercultural exchange program or activity). Such information may include your name, a password, home address, work address and e-mail address, telephone number, mobile telephone number and fax number, geo-location information, date of birth, gender, schools and university attended, highest grade/qualification received, year of graduation, area of study, social media links to Facebook, Twitter, Instagram, and/or LinkedIn, an image, photo or video of you, your citizenship, passport information, visa status, insurance status, specific AFS program information (type, year, etc.), travel details, a personal statement, your CV or resume, what languages you speak, your current occupation and other relevant skills, certain medical history and medical disclosures, dietary restrictions, certain usage data, such as test results, assessments, scores, progress, answers to specific questions, and lifestyle information such as leisure activities, and other information necessary to fulfill special requests (e.g., health conditions that may require special accommodation or consideration in connection with an AFS intercultural exchange program or activity).

AFS may also collect other non-personally identifiable information about you, such as your use of our websites, communication preferences, aggregated data relative to your use of our services, and anonymized responses to questions and surveys.

Please note, to better safeguard your information, please do not include any credit card information in your electronic communication unless we specifically require it as part of the transaction fulfillment process on an AFS website.

PURPOSE FOR COLLECTION, PROCESSING, AND DISCLOSURE

Collection & Use

AFS is committed to providing you with information about the collection and use of PII furnished by, or collected from, visitors while using our websites, products and services. It is our practice not to ask you for information unless we need it or intend to use it. Some of the primary purposes for requesting and collecting your PII are as follows:

  • providing our services (online and in the real world), such as addressing an inquiry or processing an application(e.g., when Participants are filling out an application, fulfilling a request for information, or completing a request for services), arranging program placement (e.g. select host families and schools), facilitating and managing a Participant’s involvement in a program, administering scholarships, and working with Network Organizations, sponsors, and service providers toward that end
  • marketing and communications with you in relation to the services offered by AFS, and by other trusted third parties
  • conducting fundraising campaigns
  • performing research via surveys, questionnaires and reviews to better serve your needs, improve the effectiveness of our websites, your experience, our various types of communications, campaigns, and/or promotional activities
  • alumni engagement and other outreach activities, to keep you informed about and involved with AFS activities, (such as campaigns, conferences, publications, recruitment of host families and volunteers, new programs and services).

We retain your PII for periods reasonably necessary to provide our services and outreaching activities. You may opt out of our emails, newsletters, and AFS surveys and reviews at any time by clicking on the link included in such communications, or by contacting us directly to opt out. You will always be offered the choice not to submit your PII or to decide what communications you want to receive from us. However, doing so may cause certain transactions to become affected. For example, not providing required information such as a name will prevent the processing of an application.

Processing and Disclosure

In most cases, the information you provide is added to a local or global database of AFS. In the course of processing your information, it may be necessary to transfer your PII to AFS’s Subsidiary, Network Organizations or other third party service providers located in the United States and throughout the world for the purposes outlined within this Privacy Policy. Unless otherwise precluded or governed by legal requirements and/or process, AFS or third-parties that may receive your information are required to comply to applicable regulations and Network Organizations and Sentio are also required to abide by the same privacy requirements relating to your PII as this Privacy Policy. As a general practice, AFS does not sell, rent, or give physical possession of your PII to unaffiliated third parties other than relevant and applicable Network Organizations and service providers (including third party organizations that AFS cooperates with for the delivery of its programs) who need to know in order to carry-out services and requests initiated by you or by AFS to provide you the AFS services. As an example, we may provide access (through an AFS website) or transfer PII to certain, relevant Network Organizations that you have explicitly requested (or authorized) to receive such information in connection with a placement for an AFS program. We work hard to help ensure that such third parties will only share this information with other organizations or individuals that are working with them to operate AFS-related programs or deliver other AFS services. It may be in the course of your obtaining AFS-related services that you end up submitting personal information directly to a Network Organization or third party organization, in which case you should read and agree with their privacy policies as well before submitting your personal information.

In addition, other situations in which AFS may disclose your information to others include:

  • when we have received your consent to do so
  • in situations where sharing or disclosing your information is required in order to offer you services you desire (e.g., a volunteer or program opportunity, a sweepstakes or promotion)
  • when companies or service providers that perform business activities on behalf of AFS require such information (e.g., credit card processing, customer support services, market research administration or database management services)
  • in the event AFS is merged with or acquired by another company
  • to comply with legal or regulatory requirements or obligations in accordance with applicable law, a court order or a subpoena
  • in case of emergency such as to safeguard the life, health, or property of an individual

If information is shared as mentioned above, we seek to limit recipients and the scope of information that is furnished to only the amount necessary for the performance of the specific function. Unless otherwise precluded by legal process, we require third parties to protect your PII and abide by applicable privacy laws and regulations.

We sometimes use and share non-personally identifiable information that we collect to maintain the services we offer online, improve the design and content of our sites, to enable us to personalize your experience, analyze trends, gather broad demographic information, conduct research, administer the sites, and strengthen our marketing and branding efforts.

AFS World Café & Find an AFSer

The AFS World Café [woca.afs.org] (and the Find an AFSer function therein) are intended to help members of the AFS community find each other, connect, and collaborate beyond borders on topics of common interest, and thus engage together in promoting the AFS mission. The AFS World Café is built on the Telligent Community ® platform, which contains social community functionality, such as blogs, forums, blogs, ideation, friending, media gallery, status updates, and more.

We ask that you use good judgment and discretion when sending messages to other members of the community. Please do not use information found here for the purpose of commercial promotion of any kind. AFS does not bear any responsibility for any actions or policies of third parties. However, when you voluntarily disclose PII in such forums (such as your first and last name, e-mail address etc.) within the World Café, Find an AFSer or the AFS Mail Lists, that information can be collected and used by others and may result in unsolicited messages from other users. AFS is not responsible for who may contact you by using this information. All registrations in the AFS World Café are voluntary. The only individuals listed in Find an AFSer are those who have registered themselves in the AFS World Café. AFS does not add individuals to the database, therefore if you do not find your AFS friends it is because they have not registered themselves. By uploading information to the AFS World Café (images, videos, text), you agree that AFS may use the content to promote its mission and activities, including improving the experience of AFS World Café users. By accessing the AFS World Café you agree to comply with its Community Guidelines.

CONSENT

CONSENT

By your access, use or continued use of our websites you consent and agree to the terms of this Privacy Policy as it may be amended from time to time. We may also ask you to acknowledge your consent and agreement to the terms of this Privacy Policy and our collection, use and sharing of certain information in ways other than simply by your use and continued use of our websites, for example, by requiring you to sign a separate agreement, by clicking “agree” or taking some other affirmative action prior to your ability to use or access certain websites or certain parts of our websites.  In addition, as part of our commitment to keep you informed, we may mail, e-mail, telephone, or contact you by other means to notify you of AFS services, or upcoming AFS opportunities, events, enhancements, or other relevant information that may be of interest to you.  You may also receive mailings or other communications from Network Organizations or Sentio that are relevant to your requests for services or information, and you may also receive communications from third-party service providers that provide services to AFS, which will be subject to such third-parties’ privacy policies.  We offer you the option to not request such services or information, or to decline any or all of these future communications by following the directions included in our e-mails or other communications, or such third parties’ communications, or by contacting AFS directly. If you are a minor and parent’s/legal guardian’s consent is also required, ask your parents/legal guardians for permission before sharing your PII with us.  In this case AFS can also contact (for example via email) your parents or legal guardians to confirm their consent.

If you reside outside of the United States, certain data privacy regulations may require us to obtain your permission before we send you information that you have not requested from us.  In some cases your permission will be implied from the nature of the service or information requested or transaction undertaken or when you volunteer information in connection with a request or action.  In addition, your permission will be deemed given for communications from us that are necessary to fulfill transactions and services that you request.   By accepting the terms of this privacy policy you also explicitly agree with the collection of information that is regarded under certain data privacy regulations to be sensitive in nature (e.g., information revealing racial or ethnic origin, political opinions, or health conditions).  You may object to AFS disclosing your PII to third parties except when: (i) service providers are engaged to perform services or provide information you have requested, either in conjunction with AFS, or on behalf of AFS; (ii) disclosure is required by law; (iii) disclosure concerns national, legal or public interest grounds; (iv) disclosure is necessary to protect the vital interests of a person; (v) information has been collected from publicly accessible sources; (vi) disclosure concerns the retrospective processing of the information for historical, statistical or enhancement of user experiences; or (vii)  disclosure is authorized by a supervisory authority in an applicable jurisdiction.

DATA TRANSFERS ACROSS INTERNATIONAL BORDERS

By your access, use or continued use of our websites you consent and agree to the terms of this Privacy Policy as it may be amended from time to time. We may also ask you to acknowledge your consent and agreement to the terms of this Privacy Policy and our collection, use and sharing of certain information in ways other than simply by your use and continued use of our websites, for example, by requiring you to sign a separate agreement, by clicking “agree” or taking some other affirmative action prior to your ability to use or access certain websites or certain parts of our websites. In addition, as part of our commitment to keep you informed, we may mail, e-mail, telephone, or contact you by other means to notify you of AFS services, or upcoming AFS opportunities, events, enhancements, or other relevant information that may be of interest to you. You may also receive mailings or other communications from Network Organizations or Sentio that are relevant to your requests for services or information, and you may also receive communications from third-party service providers that provide services to AFS, which will be subject to such third-parties’ privacy policies. We offer you the option to not request such services or information, or to decline any or all of these future communications by following the directions included in our e-mails or other communications, or such third parties’ communications, or by contacting AFS directly. If you are a minor and parent’s/legal guardian’s consent is also required, ask your parents/legal guardians for permission before sharing your PII with us. In this case AFS can also contact (for example via email) your parents or legal guardians to confirm their consent.

If you reside outside of the United States, certain data privacy regulations may require us to obtain your permission before we send you information that you have not requested from us. In some cases your permission will be implied from the nature of the service or information requested or transaction undertaken or when you volunteer information in connection with a request or action. In addition, your permission will be deemed given for communications from us that are necessary to fulfill transactions and services that you request.   By accepting the terms of this privacy policy you also explicitly agree with the collection of information that is regarded under certain data privacy regulations to be sensitive in nature (e.g., information revealing racial or ethnic origin, political opinions, or health conditions). You may object to AFS disclosing your PII to third parties except when: (i) service providers are engaged to perform services or provide information you have requested, either in conjunction with AFS, or on behalf of AFS; (ii) disclosure is required by law; (iii) disclosure concerns national, legal or public interest grounds; (iv) disclosure is necessary to protect the vital interests of a person; (v) information has been collected from publicly accessible sources; (vi) disclosure concerns the retrospective processing of the information for historical, statistical or enhancement of user experiences; or (vii) disclosure is authorized by a supervisory authority in an applicable jurisdiction.

ACCESS TO PERSONALLY IDENTIFIABLE INFORMATION AND OTHER DATA SUBJECT RIGHTS

The European Union’s General Data Protection Regulation and other countries’ privacy laws provide certain rights for data subjects.

If you wish to confirm that we are processing your PII, or to have access to the PII we may have about you, please contact us. You may also request access to your PII or information about: the purpose of the processing; the categories of data concerned; who else outside AFS might have received the data from AFS; what the source of the information was (if you didn’t provide it directly to AFS); and how long it will be stored. You have a right to correct (rectify) the record of your PII maintained by AFS if it is inaccurate. You may request that AFS erase that data or cease processing it, subject to certain exceptions. You may also request that AFS cease using your data for direct marketing purposes. In many countries, you have a right to lodge a complaint with the appropriate data protection authority if you have concerns about how AFS processes your personal data.

To ensure that your PII is accurate and up to date, we encourage you to regularly review and update your information as appropriate. You can review and update your information online or by contacting us. We may also reach out to you to ask to update your information. Please note that in an effort to prevent the unauthorized disclosure of your PII, you may be asked to provide proof of identity (or other authentication materials). Access to PII cannot be provided by telephone. If, upon review, you wish to deactivate or erase a profile or application, or update your PII, we will endeavor to do so without undue delay. Occasionally, information that you request to be erased will be retained in certain files for a period of time in the framework of our legal retention. In addition, some types of information may be stored longer or indefinitely on “back up” systems or within log files due to technical constraints, or financial or legal requirements. Therefore, you should not always expect that all of your PII will be immediately removed from our databases in response to your request.

Please refer to the appropriate contact information below to contact us if you have any questions about our privacy practices or if you want to submit a request.

SECURITY SAFEGUARDS

AFS recognizes the importance of information security, and is constantly reviewing and enhancing our technical, physical, and logistical security rules and procedures. All AFS-owned websites and servers have security measures in place to help protect your PII against accidental, loss, misuse, unlawful or unauthorized access, disclosure, or alteration while under our control. Although “guaranteed security” does not exist either on or off the Internet, we safeguard your information using appropriate administrative, procedural and technical safeguards, including password controls, and the use of up to 256-bit encryption (or more sophisticated encryption as per current industry standards) based on a certificate issued by Digicert Inc. This allows for the use of Secure Sockets Layer (SSL), an encryption method used to help protect your data from interception and hacking while in transit. We implement firewalls, intrusion detection system, and antivirus software with constant updates and monitoring on irregularities. Physical servers are securely protected by 24×7 monitoring at all locations, with redundant electricity, air-conditioning and fire suppression systems. IT personnel utilize encryption, where possible, to prevent direct access to data stored in databases. Access to data stored in the systems is subject to authentication with unique username and password. Users are only allowed to access information that belongs to their responsible area. Online confidentiality agreements are in place, for example as click-through consents, to be accepted at first log-in and then annually, to ensure that certain users that have access to select data are bound by appropriate confidentiality obligations.

ON-LINE TECHNOLOGIES AND COOKIES POLICY:

AFS and its third-party partners may use cookies, invisible pixels, and web beacons to obtain information about you while visiting our websites. A cookie is a very small text file that is sent to your browser from a web server and stored on your computer’s hard drive. AFS cookies assign your computer with a unique identifier, which in turn, becomes your identification card whenever you return to a AFS website.

Cookies are designed to save you time because they help us to provide you with a customized experience without you having to remind us of your preferences each time you return to our web pages. AFS cookies are not designed to damage your files, nor can they read information from other files on your computer hard drive.

Cookies can also help us provide you with a personalized on-line experience in the following ways:

  • they remember your user name and password for future visits so log-in is easier and faster.
  • they ensure you are provided with the appropriate frames and content.
  • they ensure you obtain all requested information.
  • they help us deliver communications that are relevant and responsive to your interests and location.

AFS cookies are limited to our websites only, and are not designed to follow you when traveling on the Internet after leaving AFS-owned websites. We track the usage of our websites in order to better meet your needs and to help make it easier for you to find information in the future. Please note that in addition to AFS cookies, various third parties may also place cookies on your computer’s hard drive. AFS is not responsible for the presence or absence of third-party cookies, or for the technological capabilities or practices employed by third parties in connection with third-party cookies.

Third party cookies might also be used, depending on the content displayed. Examples are: Google Analytics, Salesforce, Pardot, WordPress, Addthis, Mailchimp, Hotjar, Telligent Analytics, Ustream, Vimeo, YouTube, Facebook, Instagram, Twitter, Squarespace, Bridge, etc. As is true of most websites, we gather certain information automatically and store it in log files. This information includes Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information, which does not identify individual users, to analyze trends, to administer our websites, to track users’ movements around the various sites and to gather demographic information about our user base as a whole.

In some of our email messages we use a “click-through URL” linked to content on one of the AFS websites. When a customer clicks one of these URLs, they pass through our web server before arriving at the destination web page. We track this click-through data to help us determine interest in particular topics and measure the effectiveness of our customer communications. If you prefer not to be tracked simply avoid clicking text or graphic links in your email. In addition we may use pixel tags — tiny graphic images — to tell us what parts of our websites users have visited or to measure the effectiveness of searches users perform on our sites. Pixel tags also enable us to send messages in a format our users can read. And they tell us whether emails have been opened to assure that we are only sending messages that are of interest to our customers.

If you would prefer not to have the benefits of cookies, your Internet browser can be adjusted to treat cookies in different ways. Depending upon the type of browser you are using, you may be able to configure your browser so that: (i) you are prompted to accept or reject cookies on an individual basis or (ii) you may be able to prevent your browser from accepting any cookies at all. You should refer to the supplier or manufacturer of your web browser for specific details about cookie security. You should also understand that rejecting cookies might affect your ability to perform certain transactions on our websites and our ability to recognize your browser from one visit to the next.

AFS also uses invisible pixels, sometimes called web beacons, to count how many people visit certain web pages. Information collected from invisible pixels is used and reported in the aggregate and does not contain PII. AFS may use this information to improve programs and content.

THIRD-PARTY WEBSITES AND NETWORK WEBSITES

THIRD-PARTY WEBSITES AND NETWORK WEBSITES

In order to anticipate your needs, AFS may provide links to non-AFS websites for your convenience and information. AFS is not responsible or liable for any content presented by or contained on any independent website, including, but not limited to, any advertising claims or marketing practices.

Please note that while AFS will protect your information on AFS-owned and operated websites, we cannot control and will not be responsible for the privacy policies of third-party websites, including websites owned or controlled by independent third parties. Third-party websites that are accessed through links on our websites have separate privacy and data collection practices, and security measures. We have no responsibility or liability for the practices, policies and security measures implemented by third parties on their websites. We encourage you to contact them to ask questions about their privacy practices, policies and security measures before disclosing any PII.  We recommend that you review the privacy statements and policies of linked websites to understand how those websites collect, use and store information.

Network Organizations are directly responsible for the content presented by or contained on their respective national AFS websites (for example in the US AFS-USA Inc. is responsible for the content of the afsusa.org website). While this Privacy Policy informs you about how we collect, use, share and store your information in connection to all AFS-sites, privacy practices may vary among the countries in which AFS operates to reflect local practices and legal requirements. Accordingly, Network Organizations’ national websites may display additional privacy policies applicable to those websites. When accessing Network Organizations’ websites, carefully review any additional privacy statements and policies of those sites and contact those Network Organizations directly if you have any questions.

MINORS & CHILDREN UNDER 13

AFS does not seek to obtain nor does it wish to receive PII directly from any children under age 13; and we cannot always determine the age of persons who access and use our websites. If we find that we have done so inadvertently, we shall immediately delete such information. In addition, if we find that a minor (as defined by applicable law) provides us with his/her data without parental or guardian consent when required, we will have this information removed unless the parents/guardians approve the provision of such information.

CONTACT US

If you have any questions about this policy or our privacy practices, or if you want to submit a request, you can contact us as follows:

by e-mail at: [email protected]

or by writing to us at:

AFS Intercultural Programs, Inc.

71 West 23rd Street, 6th Floor

New York, NY 10010

Attention: AFS Legal Department

Also, AFS Intercultural Programs, Inc. data protection officer’s name and contact information are as follows:

Maria Grazia Brizi

71 West 23rd Street, 6th Floor

New York, NY 10010 USA

Tel: +1.212.209.0922

E-mail: [email protected]

For requests that relate to country-specific sites operated by AFS Network Organizations (such as afsusa.org, for the United States), please refer to the country-specific contact information available in such site.

UPDATES TO THE PRIVACY POLICY:

AFS may amend this Privacy Policy from time to time in order to meet changes in the regulatory environment, business needs, or to satisfy the needs of our visitors, Participants, Network Organizations, Affiliates, strategic partners, and service providers. Updated versions will be posted to our websites and date stamped so that you are always aware when the Privacy Policy was last updated.