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Privacy Policy

This Privacy Policy (this "Privacy Policy") applies to our website at https://www.chch.org (the "Website" or "Site") operated by Chapel Hill – Chauncy Hall School ("CH-CH," "we," "our" or "us"), as well as to the services and information about our academic programs and scholarships available via the Website (collectively, the "Services") (the Services, together with our Website, are referred to as the "Platform"). This Privacy Policy describes how we collect, use, and disclose information, governs how we treat this information, and lets you know your associated rights.

Our Platform contains links to other websites for your convenience and reference. We are not responsible for the privacy practices or the content of those sites.

1. Navigating this Privacy Policy
To help you navigate our Privacy Policy, we have divided it into numbered sections and provided a set of definitions in Section 18 (Definitions) to allow easy reference to key concepts.

2. Your Consent to this Privacy Policy

2.1 Consent by User. We have structured our Website so that, you are able to come to our Website and review selected information about our Services without providing us with any Personally Identifiable Information. By accessing and using our Platform as a visitor, you are acknowledging that you have read and understood this Privacy Policy and agree to be legally bound by it.

2.2 Consent by User Acting in a Representative Capacity on Behalf of an Organization. If you are agreeing to our Privacy Policy on behalf of a company or other legal entity ("Your Organization"), then (i) you represent and warrant that you have authority to act on behalf of, and to bind Your Organization and (ii) for all purposes in this Privacy Policy, the term "you" means Your Organization on whose behalf you are acting.

2.3 Consent by User Acting in a Representative Capacity of a Current or Prospective Student. If you are agreeing to our Privacy Policy on behalf of a current or prospective student ("Your Student"), then you represent and warrant that you have authority to act on behalf of and to bind Your Student, and the authority to provide us with Personally Identifiable Information and other information about Your Student.

2.4 Right to Withdraw Consent. You have the right to withdraw your consent at any time, in accordance with Section 11 (Your Right to Opt-Out, Object to Processing, and Delete Information).

3. The Information We Collect
To provide our Services, and to otherwise conduct our business via the Platform, we rely on information provided by and collected from our users. This information consists of the following:

3.1 Personally Identifiable Information. We collect certain information that identifies you as an individual (collectively, "Personally Identifiable Information"). The Personally Identifiable Information we collect may include the following:
  • Your name;
  • Your email address;
  • Your payment information;
  • Your relationship with Your Student;
  • Your Student's address;
  • Your Student's phone number;
  • Your Student's birthdate;
  • Your Student's email address;
  • Your Student's phone number;
  • Your Student's school and grade information; and
  • Your Student's other information, including those that relate to academics and extracurricular activities.
  • Device identifiers, such as cookies;
  • Device information, such as hardware and software settings;
  • IP addresses and log information, such as your device's name, the type and version of your web browser, and referrer addresses that can function to identify a user device; and
  • Tracking information that we, or a third party collects.
3.2 Non-Personally Identifiable Information. We also collect technical and device-related information that is not Personally Identifiable Information, but instead identifies or may reasonably be used to identify a particular user device (collectively, "Non-Personally Identifiable Information"). Non-Personally Identifiable Information is typically collected automatically by technical means, and, subject to Section 3.4 (Treatment of Combined Information), for purposes of our Platform consists of the following:

3.3 Anonymous Information. Our Platform also collects, processes, and/or uses information that does not identify you or your devices, including Personally Identifiable Information that has been made anonymous by: (i) removing identifying fields and aggregating the information with other information so that individual subjects of the information cannot be re-identified, or (ii) anonymizing the information with techniques that remove or modify the identifying data so as to prevent re-identification of the anonymized information (collectively, "Anonymous Information"). Information that meets these criteria might include, for example, demographic information, statistical information (e.g. page views and hit counts), and general tracking information.

3.4 Treatment of Combined Information. If we combine Non-Personally Identifiable Information or Anonymous Information with Personally Identifiable Information, we treat the resulting combination as Personally Identifiable Information.

4. How We Collect this Information
We collect the above information through the following means and technologies:

4.1 User-Generated Content. We may give you the ability through the Platform to engage with us and others in public exchanges, and these may include opportunities for you to provide comments, photographs, feedback, responses to polls, news items for the CH-CH Chronicle, our annual publication, and other input via the Platform (collectively, "User-Generated Content"). Please understand that, if you include Personally Identifiable Information in User-Generated Content, others will be able to read, collect, re-publish, and otherwise freely use the Information. We are not responsible for Personally Identifiable Information you decide to include in User-Generated Content, and we will not take down, remove, or edit User-Generated Content, except as required by Applicable Law. If you include in your User-Generated Content any Personally Identifiable Information relating to others, including Your Student, you represent that you have full permission and authority to do so.

4.2 Contacting CH-CH. You can contact us via the Site with questions or comments – for example, you can contact us to learn more about our academic programs and scholarships. In order to communicate with us, you must provide certain Personally Identifiable Information, including Your Student's Personally Identifiable Information.

4.3 Submitting Admission / Scholarships Applications or Pre-Visit Forms. You can submit admission or scholarship applications or pre-visit inquiry forms to us. As part of completing such applications or forms, you must provide certain Personally Identifiable Information, including Your Student's Personally Identifiable Information. Regardless of the method you choose to submit your application or form to us – for example, if you send us a scholarship application by email – we will treat the Personally Identifiable Information you provide to us in such application or form as if you provided such Personally Identifiable Information to us via our Site.

4.4 Submitting Employment Applications. You can submit employment applications to us. As part of completing such applications, you must provide certain Personally Identifiable Information. Regardless of the method you choose to submit your employment application to us – for example, if you send us an employment application by email – we will treat the Personally Identifiable Information you provide to us in such application as if you provided such Personally Identifiable Information to us via our Site.

4.5 Newsletters, Publications, and Bulletins. You can provide us with Personally Identifiable Information so that we can send you newsletters and other publications about CH-CH, our Services, and information about programs or news that we believe may be of interest to you.

4.6 Beacons and Tags. The Platform may use certain data collection technologies that rely on (i) beacons; (ii) pixel tags and object hyperlinking tags, and (iii) other means to link an object to an Internet address, a remote software application, a remote database, or other remote means of receiving or processing information. We may use these technologies to tell us what parts of our Platform have been visited or to measure the effectiveness of searches that users perform on our Platform. These technologies also enable us to send email messages in a format users can efficiently read, to learn whether these email messages have been opened, and to help ensure, for example, that our messages are of interest to our users. These technologies provide us with Anonymous Information, Non-Personally Identifiable Information and, in certain instances, Personally Identifiable Information.

4.7 Device Identifiers; Logs; IP Addresses. To determine whether your device is supported by our Platform, we may collect certain information about your device and network, including your IP address, your operating system and browser, your device model, information about your use of the Platform, as well as the presence of any software that our Platform may require to operate with your device, or other third party software or mobile apps on your device. We automatically receive and record this information in log files, and this is generally Non-Personally Identifiable Information.

4.8 Cookies. A cookie is a small amount of data that is sent to your browser from a website's computers and stored on your computer's hard drive. Cookies can be used to provide you with a tailored user experience and to make it easier for you to use a website upon a future visit. We may include cookies on our Platform and use them to recognize you when you return to our Platform. You may set your browser so that it does not accept cookies; however, you may need to enable cookies on your web browser if you wish to access certain personalized features of our Services. Cookies alone are typically Non-Personally Identifiable Information.

4.9 Click-Throughs. We may send email messages or display links that use a "click-through URL" linked to our Platform or to another resource. When you click one of these URLs, you pass through our web server before arriving at the destination website page or other resource. Click-throughs may use and collect Anonymous Information and Non-Personally Identifiable Information. We may track this click-through data to help determine interest in particular topics and measure the effectiveness of our user communications.

4.10 Other Technologies and Data Sources. We currently do not augment the Personally Identifiable Information that you provide to us with data from other third-party sources, such as privately-held marketing or analytics databases. We do not, for example, link your Personally Identifiable Information with third-party demographic information (such as age, sex, household income, job industry, or job title). If we later choose to use these data sources, or technologies other than those listed above in this Section 4 (How We Collect Your Information), we will treat any information we collect or generate in that manner in full accordance with this Privacy Policy.

5. How We Use this Information
We use the information we collect or process, including Anonymous Information, Non-Personally Identifiable Information, and Personally Identifiable Information, as permitted under Applicable Law, including where the use is based on (i) the consent you provide to us at the point of collection; (ii) to provide you with the Services; (iii) compliance with our legal obligations; and/or (iv) our Legitimate Interests, as well as a third party's Legitimate Interests. More specifically, we use the information we collect for some or all of the following:

Our Use of the Information
Bases for Our Use
To provide you with the Services you request and, specifically, to allow us to send you email with information
Performance and management of our Services provided to you
Your Consent
To allow you to post User-Generated Content
Performance and management of our Services provided to you
Your Consent
To respond to your inquiries
Performance and management of our Services provided to you
To customize your visit to and use of the Platform
Our Legitimate Interests
To consider your or Your Student's admission and/or scholarship application
Our Legitimate Interests
To consider your employment application
Our Legitimate Interests
To organize and manage our events, programs, and other functions
Our Legitimate Interests
To determine which newsletters, publications, events, or programs might interest you
Our Legitimate Interests
Your consent
To inform you of events, programs, and other items that we think (or our marketing partners think) would be appealing to you
Our Legitimate Interests
Your consent
To track access to and use of our Platform, and conduct data and other analyses, including anonymization and aggregation of Personally Identifiable Information
Our Legitimate Interests
To perform internal administration, auditing, operation, and troubleshooting for our Platform
Our Legitimate Interests
To engage in the activities specified in Section 6 (How We Share This Information)
Our Legitimate Interests
Compliance with our legal obligations
Performance and management of our agreement with you
To evaluate and improve our Platform and our communications, and to develop and test new services and content
Our Legitimate Interests
To comply with Applicable Law
Compliance with our legal obligations
 
Note that when determining the bases for our use of your information, we rely on what we consider to be the most appropriate basis, even if there are multiple bases available in connection with our use.

6. How We Share this Information
We value your privacy, and we share the information we collect only in the manner set out below.

6.1 Our Service Providers. We engage third parties to perform functions on our behalf, and these may include maintaining the Platform, collecting information, responding to and sending email or other messages, and other functions useful to our business. In this capacity, we may provide service providers with Personally Identifiable Information, Non-Personally Identifiable Information, and Anonymous Information as applicable. The following are examples:
  • We may use service providers (i) to complete your donation payments, (ii) to provide customer service (where applicable), (iii) to process and distribute email, (iv) to manage marketing and similar activities; and (v) to receive assistance in organizing and hosting our events and programs. These service providers generally require access to your Personally Identifiable Information in order to perform these services.
  • We may use analytics service providers to assist us in understanding and using Non-Personally Identifiable Information and other information that we collect via the Site. A service we use in this regard is Google Analytics, and information concerning how Google uses the information is available at https://policies.google.com/privacy/partners, and opt-out options specific to Google Analytics are available at https://tools.google.com/dlpage/gaoptout.
  • We may use service providers to anonymize and aggregate Personally Identifiable Information in order to generate Anonymous Information.
  • We may engage service providers to analyze the interests and attributes of our users and, using techniques based on Anonymous Information and Non-Personally Identifiable Information, identify others who might share those interests and attributes. 
  • We do not permit our service providers to use the information we give them for any purpose other than providing services to us. 

6.2 Questions of Harm; Legal Process. We may disclose your Personally Identifiable Information and Non-Personally Identifiable Information to third parties, including law enforcement agencies, attorneys, and private investigator organizations, where it is necessary, or where we have a good faith belief that it is necessary:
  • To comply with legal process;
  • To protect and defend our rights and property, including the Platform and associated content;
  • To protect against misuse or unauthorized use of our Services;
  • To protect the personal safety or property of Platform users or the public, including your personal safety or property (it being understood that we assume no duty to provide, or monitor the need for, such protections); and
  • To cooperate with public and government authorities including, where required, authorities outside your jurisdiction
While you are not able to opt out of this use of information, we will take reasonable steps to limit such use, and disclose only the information we reasonably believe is necessary for the above purposes. If we receive legal process calling for the disclosure of your Personally Identifiable Information, we will attempt to notify you within a reasonable amount of time, unless such notification is not permitted.

6.3 Transfer of the Platform. We shall be entitled to transfer information that we collect (including Personally Identifiable Information) to a third party in connection with a reorganization, merger, sale, joint venture, assignment, transfer or other disposition (including a disposition in connection with a bankruptcy or similar proceedings) of all or substantially all assets or stock of the business unit or division responsible for the information under this Privacy Policy; provided the acquiring third party has agreed to safeguard your Personally Identifiable Information with protections that are compatible with those set out in this Privacy Policy.

6.4 Our Affiliates. We may choose to rely on and share the information we collect with our affiliates. By "affiliate" we mean an entity that is closely related to us, such as an entity that controls, is controlled by, or is under common control with CH-CH. Our affiliates will be bound by the terms of this Privacy Policy.

7. How We Safeguard the Information We Collect
We recognize the sensitivity of our users' Personally Identifiable information and we have put in place security systems designed to prevent unauthorized access to or disclosure of this information. Our security systems include physical, technical, and administrative information security controls, and we take commercially reasonable steps to secure and safeguard such Personally Identifiable Information in accordance with Applicable Law.

8. Our Retention of Data
We retain Personally Identifiable Information for the period of time necessary to fulfill the purposes for which we obtained the Personally Identifiable Information and consistent with Applicable Law. We use the following criteria to set our retention periods: (i) the duration of our relationship with you; (ii) the existence of a legal obligation as to the retention period; and (iii) the advisability of retaining the information in light of our legal position (for example, in light of applicable statutes of limitations, litigation, or regulatory investigations).

9. Accuracy and Minimization of Data
We take reasonable steps (i) to maintain the accuracy of the Personally Identifiable Information we process; and (ii) to limit the Personally Identifiable Information that we process to that which is reasonably necessary for the purposes for which we obtained the information.

10. Accessing and Updating Your Information
If you would like to review, correct, or update the Personally Identifiable Information that you have provided to us, or if you would like to request an electronic copy of this Personally Identifiable Information for purposes of transmitting it to another company (to the extent Applicable Law provides you with this right to data portability) you may make such requests by us as provided in Section 17 (Contact Us).

11. Your Right to Opt-Out; Object to Processing; Deleting Information

11.1 Unsubscribing to Email. If you no longer wish to receive email messages from us, you can opt out of this Service by either (1) following the "unsubscribe" instructions located near the bottom of each email message, or (2) contacting us as provided in Section 17 (Contact Us).

11.2 Deleting Information. If you request, we will take reasonable steps to remove your name and email address from our databases, within the time frames (if any) set out in Applicable Law. Please understand, however, that if you request the deletion of your information, you will no longer be able to receive our Services. In addition, it may be impractical (or essentially impossible) to remove the requested information completely, due to requirements promulgated by Applicable Law, and/or data backups and records of deletions. As such, certain Personally Identifiable Information may remain in our databases following the deletion of your account; we will continue to treat the remaining information (if any) in accordance with this Privacy Policy and Applicable Law.

11.3 Objections. If you object to our processing of your Personally Identifiable Information, and a request for us to delete this Information is not, in your view, sufficient, please contact us as provided in Section 17 (Contact Us).

11.4 Anonymous Information. We will not delete Anonymous Information from our database, and nothing in this Privacy Policy restricts our use of Anonymous Information.

11.5 Your "Right to be Forgotten. If you are protected by the GDPR with respect to our use of your information, upon proper request, we will take the steps set out in the GDPR to erase your Personally Identifiable Information, including information that may be publicly available via our Platform, such as, for example, Personally Identifiable Information made publicly available through User-Generated Content.

12. Advisory Regarding Participation by Children and Teens
Under U.S. Federal Law (as reflected in the Children's Online Privacy Protection Act), WE DO NOT COLLECT OR STORE ANY PERSONALLY IDENTIFIABLE INFORMATION FROM INDIVIDUALS THAT WE KNOW ARE UNDER THE AGE OF 13. If you wish further information concerning privacy policies in general, and concerning online social networking and safety, you should visit the following website: http://www.ftc.gov/privacy/index.html.

13. Relationship to Terms of Use; Incorporation of Terms of Use
This Privacy Policy must be read in conjunction with our Terms of Use, and the provisions of our Terms of Use are incorporated herein. To the extent the Terms of Use conflict with the terms of this Privacy Policy, the terms of this Privacy Policy will control.

14. Notice of Privacy Rights to California Residents
California law requires certain businesses to respond to requests from California users who ask about business practices related to disclosing Personally Identifiable Information to third parties for direct marketing purposes. The California "Shine the Light" law further requires us to allow California residents to opt out of certain disclosures of Personally Identifiable Information to third parties for their direct marketing purposes.

15. Complaints
We want your feedback. If you have suggestions on how we can improve our Services or complaints you would like us to address, please contact us at the address set out in Section17 (Contact Us).
If you are protected by the GDPR with respect to our use of your information, you may lodge a complaint with a data protection authority for your country or region. A list of EU data protection authorities is available at http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.

16. Changes to this Privacy Policy
From time to time, we may change this Privacy Policy for our business purposes and to comply with changes in Applicable Law. In the event of any substantive or material changes, we will communicate these changes to you by posting the updated Privacy Policy on the Platform and/or notifying you of the change via the Platform, email, or other methods. Your continued use of the Platform following such notice constitutes your agreement to follow and be bound by the updated Privacy Policy.

17. Contact Us
If you have any questions about this Privacy Policy, the Platform, or your dealings with this Platform, please contact us. You may contact us, for any reason, using the contact information below:
msoule@chch.org

18. Definitions
Below are definitions applicable throughout this Privacy Policy. Additional terms are defined in context.

18.1 "Anonymous Information" has the meaning set out in Section 3.3 (Anonymous Information). If you are protected by the GDPR with respect to our use of your information, the term "Anonymous Information" has the same meaning as information generated by a "pseudonymisation" processes, as that term is defined under the GDPR.

18.2 "Applicable Law" means statutes, regulations, and any other laws that apply to the Website, the Services, or the Platform. For example, if you are protected by the GDPR with respect to our use of your information, the term "Applicable Law" includes the GDPR.

18.3 "GDPR" means the European Union General Data Protection Regulation.

18.4 "Legitimate Interest" means, for purposes of the GDPR, that there is a good reason for the processing your Personally Identifiable Information, and that the processing is carried out in a way that minimizes impacts (if any) on your privacy rights and interests. The term "Legitimate interest" also refers to our use of information in ways that you would reasonably expect, based on your relationship to us. For example, there is a Legitimate Interest in collecting and processing your Personally Identifiable Information: (i) to safeguard our Platform, networks, content, and related information and resources; (ii) to administer and generally conduct our business; and (iii) to prevent fraud.

18.5 "Non-Personally Identifiable Information" has meaning set out in Section 3.2 (Non-Personally Identifiable Information).

18.6 "Personally Identifiable Information" has meaning as set out in Section 3.1 (Personally Identifiable Information). If you are protected by the GDPR with respect to our use of your information, the term "Personally Identifiable Information" has the same meaning as the term "personal data" under the GDPR.
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