Last updated: February 28, 2020
This website is not intended for children and we do not knowingly collect data relating to children. If you are below the age of 16 then you must have your parent’s or legal guardian’s consent to submit any personal information at all. We will promptly delete any personal information relating to minors where we are informed that parental or guardian consent has not been granted. Should you be a concerned parent or guardian of a minor who has submitted their personal information without your consent please write to our Data Protection Officer for assistance.
The Data Protection Officer
GVI World Limited
1 Emperor Way, Exeter Business Park, Exeter, EX1 3QS
Email address: firstname.lastname@example.org
THE DATA WE COLLECT ABOUT YOU
Personal information means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal information about you. Some of the data may constitute personal information only when combined with personal identifiers. We have grouped the data for your reference as follows:
- Identity Data may include first name, maiden name, last name, username or similar identifier, title, date of birth, gender and social security number where applicable.
- Contact Data may include email address, phone numbers, addresses (physical, postal or billing).
- Transaction Data may include details about payments to and from you and other details of products and services you have purchased from us.
- Technical Data may include internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this site and the Service.
- Education record data: This refers to data such as your name, address, email, phone number, date of birth, race, gender, previous salary information, industry of employment, information on your enrollment, specific Program-work taken, attendance, grades, assessments, evaluations, portfolio/projects, communications history with Instructors. This data may be received from or shared with The extension school.
- Usage Data may include information about how you use our website, products and services.
- Marketing and Communications Data may include your preferences in receiving marketing from us and our third parties and your communication preferences.
- Special categories of personal information may include health data relevant to your program, criminal history as relevant to any travel component of the Program or Programs.
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.
IF YOU FAIL TO PROVIDE PERSONAL INFORMATION
Where we need to collect personal information by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have entered into or are trying to enter into with you. In this case, we may have to cease provision of the Services and terminate your contract with us. We will notify you of this in advance should it ever arise.
HOW IS YOUR INFORMATION COLLECTED?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your identity and contact details by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal information you provide when you: apply for our Programs or register on the site or the Service; request marketing to be sent to you; provide any other personal information to us directly by post, phone, email or in person; respond to a survey or enter into our promotions and competitions; engage with us via social media; use the Message Board features of the Service and include personal information directly or indirectly (eg. via a display name).
- Third parties or publicly available sources. We may receive personal information about you from various third parties (and public sources) as set out below:
– Technical Data from the following parties:
(a) analytics providers such as Google Analytics
(b) advertising networks such as Google Adwords, Facebook and Bing
HOW WE USE YOUR PERSONAL INFORMATION
We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
- Where you have provided consent for a stated purpose
- Where we need to perform the contract we are about to enter into or have entered into 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 or regulatory obligation.
We rely on consent as a legal basis for processing your personal information in relation to sending direct marketing communications to you via email or electronic communications methods. You have the right to withdraw consent to marketing at any time by Contacting us.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL INFORMATION
We will only collect and process personal information about you where we have one or more lawful bases. Lawful bases include consent (where you have given consent), contract (where processing is necessary for the performance of a contract with you), vital interests and where relevant “legitimate interests”.
We strive to provide you with choices regarding certain personal information uses, particularly around marketing and advertising.
PROMOTIONAL OFFERS FROM US
You will receive marketing communications from us if you have opted to do so while requesting other information from us or when applying for, registering for and or using the Service.
We will get your express opt-in consent before we share your personal information with any company outside the GVI family of companies or Case Western Reserve University for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by using the unsubscribe link included in the footer of all marketing messages. Where you opt out of receiving these marketing messages, this will not apply to personal information provided to us as a result of registering on the site or Service or enrolling in a Program.
CHANGE OF PURPOSE
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please Contact us.
If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
DISCLOSURES OF YOUR PERSONAL INFORMATION
We may have to share your personal information with the parties set out below for the purposes of providing services to you or performing our contract with you.
- Suppliers: such as web hosting services, flight partners, insurance providers, and other entities we work with in order to fulfill our contract with you.
- Third-party vendors: who provide services or functions on our behalf, such as credit card processing, business analytics, support and fraud prevention. Such vendors are not permitted to share or use the information for any other purpose other than performing the specific functions they provide.
- GVI-controlled entities: are the various operating entities that provide on-the-ground support at our various global program locations.
We require all third parties to respect the security of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.
- Where required by law: there may be circumstances where disclosure is required by law. In such instances we may process and disclose your personal information to comply with the legal request received.
- Social Media and similar websites: in some instances the site may allow you to post information to social media sites. Please familiarize yourself with the privacy policies of these social media sites. We do not control their use of data shared with them.
- Where your express consent is given: we may disclose your information with your consent. Such consent may be withdrawn by you by contacting us.
- Please note that we will share your personal information with the Case Western Reserve University where required to fulfill our contract with you, such as for the issuance of records related to your enrollment in or completion of a program.
NOTICE FOR CALIFORNIA RESIDENTS
NOTICE FOR CALIFORNIA RESIDENTS
Categories of Personal Information that We Collect
Below are the categories of personal information about California consumers that we collect and disclose for a business purpose. We do not sell personal information.
We collect and disclose for a business purpose the following categories of personal information:
- Contact Information and Identifiers, including real name, alias, postal address, unique personal identifier, online identifier, IP address, email address, phone number, account name, or other similar identifiers.
- Customer Records, including paper and electronic customer records containing personal information, such as name, signature, address, telephone number, education, employment, employment history, financial information relevant to your payments, or medical information relevant to your participation in the Case Western Reserve University Impact Academy.
- Usage Data, including internet or other electronic network activity information, such as browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement.
- Employment History, including professional or employment-related information.
- Education Information, including information about education history or background.
- Protected Classifications, including characteristics of protected classifications under California or federal law such as race, color, sex, age, religion, national origin, disability, and citizenship status.
Categories of Sources of Personal Information
The categories of sources of personal information we collect are described in the section How Is Your Personal Information Collected above.
Purposes for Collecting Personal Information
We collect the personal information identified above to communicate with you, for advertising and marketing purposes, to provide and improve our services, and other purposes set forth in How We Use Your Personal Information above.
Categories of Third Parties with Which Personal Information is Shared
We share personal information identified above with the following categories of third parties:
- Our educational partners,
- Third-party providers that serve business, professional or technical support functions,
- Potential employers (as directed by you), or
- Third parties for legal matters or safety purposes.
California Consumer Rights
California law gives California consumers the right to make the following requests:
- The right to opt-out of sale of your personal information. We do not sell personal information.
- The right to request a copy of the personal information that we have collected about you in the prior 12 months.
- The right to request deletion of the personal information that we have collected from you, subject to certain exemptions (for example, where the information is used by us to detect security incidents, debugging or to comply with a legal obligation).
- The right to request more details about the personal information we collect and how and why we use and share it, including the categories of personal information we have collected about you, the categories of sources for personal information we collect, the business or commercial purposes for collecting personal information, and the categories of third parties with which we share personal information.
You can submit a copy, deletion, or right-to-know request online by emailing email@example.com or by contacting us at 1-888-653-6028.
The CCPA prohibits discrimination against California consumers for exercising their rights under the CCPA and imposes requirements on any financial incentives offered to California consumers related to their personal information, unless the different prices, rates, or quality of goods or services are reasonably related to the value of the consumer’s data. Please note that third parties may, however, collect personal information about your online activities over time and across different websites when you visit our Site or use the Service.
Please note that third parties may, however, collect personal information about your online activities over time and across different websites when you visit our Site or use the Service.
NOTICE FOR EU RESIDENT NATIONALS
Users based in the European Union are advised as follows:
GVI has operations in various locations across the world including all the international locations where the fieldwork component of the Case Western Reserve University Impact Academy are offered. As part of the process of performing our contract with you, your personal information may be transferred outside the European Economic Area (EEA). This could include places whose laws may provide for a lesser standard of protection for your personal information than that provided under European Law. In order to meet the data protection standards of European Law we will only transfer your data using one of the safeguards listed below.
Whenever we transfer your personal information out of the EEA, we ensure a similar degree of protection is afforded to it via at least one of the following safeguards:
- We will only transfer your personal information to countries that have been deemed to provide an adequate level of protection for personal information by the European Commission. For further details, see European Commission: Adequacy of the protection of personal information in non-EU countries.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal information the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal information to third countries.
- Where we use service providers based in the US (such as Amazon Web Services), we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal information shared between the European Union and the US. For further details, see European Commission: EU-US Privacy Shield.
- We ensure your personal information is protected by requiring our entire family of companies to follow the same rules when processing your personal information. Transfers to suppliers and partners based outside the EEA may also be required such as when GVI assists with visa applications and renewals. Certain licences, permissions and authorizations required in order to participate in our programs and or enter certain controlled areas (such as national parks, partner schools and dive locations) will require a transfer of your personal information to relevant external suppliers and partners. Suppliers and partners are required to adhere to the same standards as GVI when dealing with personal information.
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
DATA RETENTION AND INFORMATION SECURITY
HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
We will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
Depending on the laws applicable to you in your region, in some circumstances you can ask us to delete your data.
In some circumstances we may anonymize your personal information (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Though we do our best to protect your information, transmission of information via the internet is not completely secure, and we cannot guarantee our security measures. We are not responsible for any unauthorized access to or acquisition of your information.
YOUR LEGAL RIGHTS
Users based in the European Union are advised as follows:
Under certain circumstances, you have rights under data protection laws in relation to your personal information.
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.
Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal information. This enables you to ask us to suspend the processing of your personal information in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal information to you or to a third party. We will provide to you, or a third party you have chosen, your personal information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time
where we are relying on consent to process your personal information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please Contact us.
FERPA RIGHTS FOR US RESIDENTS
Education Records: You may have specific rights relating to the disclosure of any personal information that you provide to us and/or education records that we may create about you under the Family Education Rights & Privacy Act (“FERPA”), or other relevant law or regulation. You also may have specific rights under FERPA related to accessing and/or updating your personal information. If you would like to inspect and review your education records, you may submit a request by emailing us. Requests for access under FERPA will receive a response within 45 days, although certain records may be excluded from education records made available for inspection (within the bounds of the law and our confidentiality agreement with third parties). You may also request amendment of records that you believe are inaccurate, misleading or in violation of your rights.
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 is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these 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 your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal information for our legitimate interests. We do not use your personal information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by Contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal information where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
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