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THINK GLOBAL SCHOOL PRIVACY AND INFORMATION SECURITY POLICY

EFFECTIVE DATE: January 3rd, 2012

This website (the “Site”) is brought to you by THINK Global School. This TGS Privacy and Information Security Policy (“Policy”) generally describes collection, processing and other aspects of our dealings with personal information that we obtain from you online at this Site. We also collect personal information in other ways such as if you become a TGS student or employee, in which event this Policy and supplemental terms will constitute the Policy. For ease of reference, we will sometimes call the Policy on this Site the “Master Policy” and we will refer to the additional terms as the “Supplemental Policy(ies).” If you are simply visiting this Site, or using this Site to apply for admission or employment, you are subject to the Master Policy, but not to any supplemental policy.

You may find a link to this Policy on many pages of this Site, as well as at the bottom of the forms that we use to collect your personal information.

BY PROVIDING PERSONAL INFORMATION TO US, BY APPLYING FOR ADMISSION OR EMPLOYMENT, BY REGISTERING AT OR USING THE SITE (other than to read the Policy and Terms of Use), OR BY TAKING OTHER AFFIRMATIVE ACTION TO CONSENT, YOU AGREE TO ALL TERMS AND CONDITIONS OF THIS POLICY FOR YOURSELF AND FOR ANYONE ELSE WHOSE PERSONAL INFORMATION YOU PROVIDE. If you do not want to agree, do not do any of the foregoing.

TGS Website Terms of Use; Definitions

This Policy is part of the THINK Global School Terms of Use (“Terms” or “Terms of Use”). All capitalized terms used but not defined in this Policy shall have the definitions in the Terms of Use (which definitions are incorporated herein by this reference). Additionally:

  • by “you,” we mean an individual who uses our Site, such as potential or actual students or their parents or guardians, potential or actual employees and individuals about whom a Site user supplies personal information. “You” does not include TGS contractors (other
    policies or contracts apply to them) or deceased individuals.
  • by “TGS,” “we,” “us,” or “our” we mean THINK Global School, Inc., an Illinois not-forprofit corporation. Our e-mail address is info@thinkglobalschool.com; and our telephone number is +1 347-281-6855.
  • by “TGS Community” we mean employees, board members, students (and their family members), donors to and supporters of TGS or of schools that host or assist TGS or its students, and the like.
  • by “personal information,” we generally mean information that personally identifies you or another individual. At our option and for purposes of our rights under this Policy (but not our obligations, except as required by law), we also mean information that we collect through technological means such as “cookie” information (see below), even if such is not personal information.
  • by “Disclose” we collectively mean using, accessing (or barring access), processing, fulfilling, disclosing, receiving, displaying, sharing, transferring, storing, selling, leasing, licensing, retaining, combining, investigating, verifying, proving, enforcing and otherwise dealing with, voluntarily or involuntarily, personal information.

Information That You Affirmatively Provide

We collect personal information that you intentionally provide such as when you: (1) register on the Site; (2) submit an application to us; (3) complete a survey; (4) join our mailing list; (5) contact us; or (6) you or others post a comment or otherwise post personal information on the Site or send it to us (e.g., a parent or student might supply personal information about each other or you might post something in a chat room). The personal information we affirmatively seek from you usually includes your name, physical and/or e-mail address, telephone number and other contact information, but also includes more depending upon what you are doing. For example:

  • If you submit an application for admission, TGS typically requires the applicant’s date of birth, gender, education information (including transcripts or report cards), essays, and information about the parents or guardians (including certain financial information).
  • If you submit an application for employment, you may be asked for experience information and the curriculum vitae that you upload might include personal information. Also, you will be asked to provide your name and addresses, work eligibility, visa status, criminal history.
  • If you make an application requiring information about others (e.g., a reference or relatives or guardians) you will need to supply information about the other person. You agree not to supply information about others unless you first obtain their consent to do so and to have it treated under this Policy.
  • If you have a disability and request a special accommodation, such as for submitting an application, we collect information relevant to your request (e.g., disability information).

Unless we expressly ask for sensitive information, you should not supply it (e.g., don’t send us a national identification number simply because it is in your resume or curriculum vitae – remove it before uploading). We do not expect our Third Party Services to request sensitive information and you should check with us before supplying it. Also, remember that in the Terms of Use you promise not to upload to public areas of the Site or for public communications facilitated by the Site, personal information about yourself or others unless you (and they) are willing for everyone in the world to see and potentially Disclose it.

With respect to personal information that we request, you should assume that information expressly requested on our forms is required unless marked as optional – if you have questions, contact us. Subject to applicable law, failure to provide required information will prevent you from obtaining the service you seek. Providing information pertaining to your religion, disability status or physical or cognitive challenges, or medical condition is usually optional, but if you do something that requires or makes it advisable for us to have it or if you are requesting an accommodation from TGS on any such basis, you must provide such information and consent to our processing of it.

We may combine the personal information you provide us with information we receive from or about you from other sources, including but not limited to authentication services. We will use the combined information for the purposes described in this Policy or as allowed by law.

Information That You Do Not Affirmatively Provide

As part of the standard operation of the Site, we may collect information from you that is not necessarily personal information, but which is collected at the Site. This includes but is not limited to typical collections such as your browser type, operating system, IP address, unique device identifiers, and the domain name from which you accessed the Site and the date and time of access. In addition, we may collect information about your browsing behavior, such as the date and time you visit the Site, the areas or pages of the Site that you visit or the things you click on, the amount of time you spend viewing the Site, the number of times you return to the Site, the country from which you view the Site and other clickstream data. We may collect public and non-public information from third parties and combine it with other personal information.

We may use cookies and other tracking mechanisms to collect certain of the information described above. A cookie is a small text file that our Site transfers to the hard drive of your computer for our use when you access the Site (e.g., it can help us recognize you and your preferences and information). We may also use cookies to: (1) provide you with customized content; (2) monitor Site usage or help us prevent fraud; and (3) help us to improve the Site, content and services and to conduct research.

Our cookies or other technologies might personally identify you: they do not expressly do so, but to the extent that combining bits of information can result in identification, then they might. You may be able to disable1 some cookies.

We also allow collection by analytic service provider(s), such as Google Analytics, of Site Clickstream, cookie and similar data to help us track aggregate and individual use of our Site and determine possible interests of users (e.g., if you read about our 11th grade curriculum we might present you with an article about 11th grade issues during a subsequent visit). You may be able to opt-out of some analytic collection – please visit http://www.google.com/analytics/ to learn what options you have with Google Analytics. When you use a Third Party Service, that service may use cookies, or other means of collecting information, too – read its privacy policy to learn more.

Accuracy and Access to Information You Provide to Us; Identity Theft

When you supply personal information to us, you agree to supply accurate information only, and agree that we may assume and rely on that accuracy. You also agree to update the information to keep it accurate (to the extent we allow updates).

We do not maintain all personal information in a form that can be accessed or updated by you and some items may not be changed or may be held (or already used) by third parties that we do not control. For example, you may not change information that we or others relied upon in connection with an application or a payment or that might indicate deception. We will determine what may be accessed in our records and how; we may also keep a record of requests and of changes (including deletions) and Disclose all of that for lawful purposes, including for things such as investigations. You may access or update personal information in our records that we make eligible for updating by making a written request to Our Legal Notice Address (see the Terms of Use).

  • Your request to access or update information must include a clear identification of the personal information at issue and, if relevant, an explanation of the changes you want made to it, as well as proof of your identity and authority to make the request (call or e-mail us at the contact information in the “Who We Are” section of the Terms of Use to obtain a list of the current identification documents you may provide). If applicable law requires us to accept requests by another method such as e-mail, use the same contact information for us to obtain the address to which those e-mails should be sent. However, e-mails are insecure, so if you determine to use e-mail under any such law, you accept the risk of exposure of the information in the e-mail. We reserve the right to charge for handling your request(s) subject to applicable law.
  • Our Response. We will honor qualified requests that comply with this Policy and applicable law and do not interfere with privacy rights of others. Requests to access information will be complied with by supplying you with a copy of the information and/or otherwise providing you access to the same.

We will need a reasonable time to process an access request. Currently, we do not charge for accessing, updating or providing information that we are required to or voluntarily supply to you. However, we reserve the right to do so, subject to applicable law.

If you believe that you are a victim of identity theft, you may be entitled by law to request information from us. You can do this by writing to us at Our Legal Notice Address in the Terms of Use. If we receive a request, we will then explain what information we require in order to respond. Once we have all of the required information, we will supply, without charge, any information that we then have which we are legally required to provide (subject to applicable law, and reserving all rights and defenses).

What We Do With Personal Information (Disclosure)

We use personal information to engage in our business and fulfill our mission. This means that we make (or reserve the right to make) all lawful, worldwide Disclosures of personal information subject to this Policy and applicable law. For example (and in addition to other examples in this Policy), we will Disclose personal information:

  • To process and verify you, your application and requests, including trying to see whether you may travel with us to other countries (e.g., we may try to check with governmental authorities and educational organizations with whom we might deal);
  • To provide you or others with requested information, including our newsletters, when you join our mailing list;
  • To contact you or others when necessary or when we think it is advisable;
  • To Third Party Services, as discussed below;
  • To engage in our everyday educational and business purposes, which includes the international transfer of your personal information, and use of Third Party Services2;
  • To engage in our out-of-the-ordinary educational and business purposes3, including but not limited to transferring data worldwide;
  • To address problems or potential problems with the Site, our school, services, students or employees;
  • To create and keep records (including without limitation), storing personal information in databases and commingling or combining it with other information;
  • To exercise our legal rights under U.S. or foreign laws, including (without limitation and without undertaking any duties to do so) Disclosures to assert, defend and enforce rights or property of us or others or to prevent harm to us or others;
  • To deal with legal process;4
  • To make subsequent uses of personal information such as using it for research, educational, alumni or international community outreach projects, and for meeting subsequent requests made by you (such as to forward student grades to an employer or university well after graduation); and
  • To generate aggregate data5 and Disclose it for statistical studies and research related to our products, services and use of the Site.

In general we do not Disclose personal information of students to third parties for their advertising purposes, but we reserve the right to do so if we believe that such is lawful and appropriate in the circumstances or if you provide your consent.

If you get a job with us or are admitted as a student or otherwise contract or deal with us (such as a parent), we may store personal information that we collected or relied on (as we deem relevant) in post-admission or employment file and we may base post-employment or admission decisions on it (including disciplinary and termination actions).

It is impossible to list every lawful use that we might make of personal information so the above is a general, non-exclusive, description. We reserve the right to prepare translations of or other derivative works from the information collected from you in relation to the above purposes.

Third Party Systems and Services that We Use

In addition to service providers such as mailing houses, TGS uses third party systems and services for more sophisticated and current tools and services (collectively, “Third Party Services”). These third parties may have their own terms of use and privacy policies, which may apply to you. Examples of our third party services include Gmail, which we use for e-mail (including those that you send to us), and for applications and information that you submit through the Site. You can learn more about Gmail’s privacy practices at:
http://www.google.com/intl/en/policies/privacy/.

We also integrate the Site with social media websites, which facilitates the sharing and further distribution of information available on the Site. For example, parts of the Site allow you to share information using Third Party Services like:

Each of the Third Party Services (including the ones listed above) may collect and Disclose personal information about you in ways that we do not control. The Third Party Services that we use change from time to time – please contact us for more information;

Information From Job Applications

In addition to Disclosures of personal information explained above, we make various kinds of Disclosures of personal information that you submit in an application for employment. For example, we:

  • don’t necessarily do this at the application stage, but we might later send it to others who help us authenticate you or review your qualifications and credentials or contact your references, including but not limited to background check providers if we make you a conditional offer of employment;
  • share it with third parties with whom we or you might work if you get the job or from whom permissions may be needed in order to travel to or do your job, such as governmental authorities from who you might need a work permit or authority to teach or an anti-terrorism review, law enforcement and so on; and
  • use it to communicate with you about the job for which you applied or to deliver notices.

YOUR PARTICULAR CONSENTS

We need you to consent to particular Disclosures which we have listed below — they emphasize particular Disclosure practices that the law wants us to emphasize. We will make the Disclosures not only for the personal information you supply through the Site, but also for other personal information that you now or later provide to us. Accordingly, we want to emphasize those practices now. You may avoid the impact of some of your consents by not engaging in an activity making it relevant (e.g., there will be no transfers of your application information if you do not apply). However, if you choose to engage or if you otherwise provide personal information to us, you will be bound by your consent now and later, including after any enrollment or employment.

BY PROVIDING PERSONAL INFORMATION TO US, BY APPLYING FOR ADMISSION OR EMPLOYMENT, BY REGISTERING WITH US, OR BY ACCEPTING ANY ADMISSION OR EMPLOYMENT, YOU: (A) EXPRESSLY CONSENT (OR CONFIRM YOUR CONSENT) TO THE FOLLOWING; AND (B) AGREE THAT YOUR CONSENTS WILL CONTINUE TO APPLY IF YOU ARE ADMITTED AS A STUDENT OR BECOME AN EMPLOYEE AND WILL COVER NOT ONLY THE INFORMATION COVERED BY THIS POLICY BUT ALSO OTHER PERSONAL INFORMATION THAT YOU PROVIDE LATER IN YOUR DEALINGS WITH US:

  1. Processing and Disclosing of Personal Information: This Policy explains that TGS will make Disclosures of personal information about you. You expressly consent to that.
  2. International Transfers of Personal Information: This Policy explains that TGS, its service providers, and Third Party Services will make Disclosures and transfers of personal information into and out of the United States and other countries worldwide. You expressly consent to that.
  3. Subsequent and Secondary Disclosures of Personal Information: This Policy explains that TGS will use information for more than one purpose including subsequent and secondary purposes (e.g., if we initially collect contact information to contact you about your application, if your application is approved we will keep that information and use it later, for different relevant purposes such as to provide job or classroom information or even to contact you about disciplinary matters). You expressly consent to secondary and subsequent uses of personal information.
  4. Sensitive Data; Accommodations for Disabilities: If you request an accommodation for a disability or religious reason, we will process and Disclose to third parties personal information in order to examine your qualification for the accommodation, and to provide you with the accommodation, including information about your:
    • disability status or other physical or cognitive challenges;
    • medical condition;
    • philosophical, political or religious opinions or sexual life; or
    • racial or ethnic origin.
    • If you are admitted or employed, we may request the above and additional sensitive information. For example, TGS is a traveling school and we may need to know more than most schools or employers such as in case there is a health emergency or a schedule for practicing your religion. You expressly consent to that.

  5. Background; Affiliations: This Policy explains that we collect, Disclose and retain certain information if it is included in a larger, more comprehensive document such as student or employment records. Some of that may include information about your:
    • membership in any trade unions; or
    • criminal record, if any.
  6. Storage on Your Computer: This Policy explains that we (and others, e.g., Third Party Services) store cookies or other information on your computer (see “Information That You Do Not Affirmatively Provide”). You consent to that and to our access to it.
  7. Automated Systems: We might, or our service providers might, use automated systems to process personal information and make decisions about you, including adverse decisions (e.g., that you might be an imposter or, if you are admitted, that your grades are below a required level). You consent to our use of automated systems that might adversely affect you.
  8. Recording: We might collect some information by phone or another technology (e.g., VOIP or “live meeting” technologies). If you interact with us or a representative over a medium that can be recorded, you agree that we may record the conversation and Disclose it under this Policy.
  9. Electronic Notice if There is a Security Breach: If we or any of our service providers are required to provide notice of unauthorized access or other invasions of certain security systems, you agree that we may do so voluntarily or when required by posting notice on our Site or sending notice to any e-mail address that we have on file for you, in our good faith discretion.

Retention of Personal Information

We tend to retain personal information for the length of time that we, in our good faith discretion, believe necessary to fulfill the purposes for which we collected it, to comply with applicable laws or contracts, and to operate our business and fulfill our educational mission. For example, we will retain admission information through graduation in case we need to rely on it while a student is enrolled; we will retain student grades for the post-graduation, indefinite period during which we think a student or other school might ask to see them. Often it is not feasible or advisable to actually discard information, so we reserve the right to retain it but treat it as inactive or discarded.

Information Security and Protecting Yourself

TGS believes it has implemented and maintains information security programs or procedures intended to provide reasonable security procedures and practices consistent with its needs and mission. These are intended to protect personal information from unauthorized access, destruction, use, modification, or disclosure when required by law. For example, we collect Social Security Numbers (“SSNs”) from United States registrants during the application and interview process (but not on applications submitted through the Site) and at least one state requires us to take steps to protect the confidentiality of SSNs, prohibit unlawful disclosure and limit access to them. We do that with internal policies, procedures or contracts that we endeavor to obtain from our service providers.

  • You should assume the Site is not encrypted. You should also take steps to sustain Site security, e.g., you should create the most robust password that the Site accommodates and should not submit or store any sensitive information through the Site.
  • Some Third Party Services use standard form contracts that we are not able to customize or clarify, although when we can, we contract for versions made available to educational institutions. We believe, but do not guarantee, that these services provide reasonable security too.

EVEN WITH PRECAUTIONS, SECURITY OR OTHER BREACHES AND MISTAKES AND CRIMINAL ACTS CAN HAPPEN. WE DISCLAIM ANY IMPLIED WARRANTIES, DUTIES OR CONDITIONS REGARDING SECURITY AND WE DO NOT GUARANTEE THE SECURITY OF PERSONAL INFORMATION. If applicable law imposes a non-disclaimable duty on TGS, you agree that the standard used to measure our compliance will be intentional misconduct. If this is not acceptable to you or to anyone whose personal information you supply, you agree not to use the Site.

Minors

Our Terms of Use prohibit use of the Site by users under 13 years of age. Although minors (under 13) may write the essay portions of an admission application, only parents and legal guardians may submit those essays and personal information to us through the Site.

Other Websites

The Site may contain links to websites of others, which may have privacy policies that differ from our own. We are not responsible for the activities and practices that take place on these sites. Accordingly, we recommend that you review the privacy policy posted on any site that you may access through the Site.

Changes to This Policy

We may change this Policy from time to time in the same way that we may amend the Terms of Use or to respond to laws, regulations, technologies and the like. See the “Amendments” section of our Terms of Use for details regarding changes to the terms of this Policy.

Enforcement of This Policy

As noted, this Policy is part of and supplemented by our Terms of Use. If there is a conflict between them and this Policy, the latest version of this Policy will control. As a contract, we and you are bound by this Policy. If you think we are in default, you may contact us by writing to Our Legal Notice Address that is included in our Terms Of Use. There are no third party beneficiaries of this Policy.

Withdrawing Consent to This Policy

In general you may not withdraw your consent to this Policy unless the law expressly allows you to do so despite a contrary contract. This is because typically we will rely on your consent right away (such as to start processing your inquiry) and this Policy is part of our contract with you. When personal information may be withdrawn, you may remove it from the Site using tools that we supply for that purpose whenever you want to do so, but Disclosures or copies already made may remain. If this is not acceptable, do not supply the personal information in the first place — for required information this may mean you will not be able to apply for employment or admission, or to obtain a particular service. If you have a non-variable legal right to withdraw your consent or particular information and exercise that right, we reserve the right to terminate your application and any contracts or obligations we might have to you, including (without limitation) any benefits or services you receive from us, except that you will still be bound by any obligations incurred and consent provided before your withdrawal.

Footnotes

1To learn about disabling cookies consult the instructions for your browser or computer. There are also many other sources of information about cookies. See, for example, the various materials and resources at http://www.epic.org/.

2Routinely, we will Disclose relevant information to service providers, Third Party Services, affiliates, consultants, organizations that we work with, and relevant members of the TGS Community. These would include without limitation: payment processors and verification services; schools and personnel that help us in foreign countries even if they are not our employees; immigration and law enforcement authorities in countries to which TGS and its students reside or will visit; translators; food service and other providers of educational or boarding school services; medical service providers; insurance companies; data processors/managers/storage providers; mailing houses or advertisers (if any); persons with whom any of the foregoing deal (e.g., payment processors deal with banks); and our affiliates, agents, consultants, auditors, creditors and regulators. These service providers and other third parties might sometimes receive a “code” for you instead of personal information directly identifying you, and they should use and otherwise Disclose personal information received for purposes relevant to the job they do for us. We or they may also provide (and reserve the right to provide) personal information to credit reporting agencies and voluntarily to cooperate with law enforcement authorities or other governmental, educational, health or other authorities, including but not limited to searches of persons and property (including but not limited you and your property such as when the acts of one person might endanger another). The companies or individuals to whom we make Disclosures (and to whom they make Disclosures) are located all over the world and that is why we obtain your consent to transferring personal information internationally.

3There is no clear line between everyday business purposes and out-of-the ordinary purposes but here are some examples of what we view as more in the nature of non-every day circumstances: if a claim is made that an imposter posed as you or if you or TGS become the subject of an investigation, we will Disclose personal information as appropriate; or if TGS materially changes form (e.g., if it is acquired or sells its assets or engages in a corporate change such as a merger) or goes into bankruptcy or the like, we will transfer and Disclose personal information in connection with that.

4Legal process includes things like responding to or initiating court orders, legal actions, investigations or requests. Without limitation, we may Disclose personal information when we think (in our sole discretion) that doing so might help prevent or investigate potential crimes, or is not prohibited by law. We reserve the right (without undertaking an obligation) to notify you or others of subpoenas or other legal process, if notice is lawful. If you do not want us to respond to a subpoena, you must seek a valid court order allowing us to delay or forego responding and serve that order on us at least 3 business days before we must respond. Because we will be traveling internationally, we might receive legal process from a variety of countries or purported authorities, although we will not necessarily be bound to respond to it all. Our primary location is in the United States of America and we will at least be subject to its laws and procedures regarding legal process and the laws or rules of the applicable state or judicial body. Third Party Services and other third parties will also receive legal process.

5By “aggregate data,” we mean collective information or blind data that does not contain express personal identifiers like names or addresses (e.g., X% of 20XX admissions were female). We reserve the right to create aggregate data by removing express personal identifiers and undertake no duty to remove data that, theoretically or otherwise, might possibly be associated with a person under various theories of what data or combinations might possibly identify a person. Aggregate data tends to reflect collective information. We use it for a variety of purposes such as for research that we or third parties may now or later do or to improve our services or further our mission.