Stetson Academy Online Privacy Policy

Stetson Academy (“Stetson”) provides the following information relating to your privacy when using stetsonacademy.com.

Online Privacy Notice

This Online Privacy Notice applies to the information that we collect when you visit Stetson’s main website stetsonacademy.com and other websites that we own or control and link or refer to this Privacy Notice (together, the “Sites”). This Notice describes what information is collected and how this information is processed.

Unless otherwise indicated on a specific Sites, Stetson is the data controller for all information collected under this Notice. Should you have any questions or concerns regarding this notice or the collection of information through the Sites, contact information for Stetson is listed at the end of this Notice.

This Notice does not apply to information collected from or about current or former employees, contractors, volunteers, and other workers of Stetson as part of their employment or working relationship with Stetson.

Personal Information we collect and process:

When you access or use the Sites, we may collect and process the following types of information from you:

“Personal Information” is any information that we can reasonably use to identify you. Examples include your name, address, and contact details such as phone numbers or email addresses.

“Sensitive Personal Information” includes special categories of Personal Information (e.g., racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data, data concerning health, and data concerning a natural person’s sex life or sexual orientation) for which applicable law provides enhanced protections.

The table below describes the Personal Information and Sensitive Personal Information that we collect, why we collect it, and our legal basis for processing it.

Purpose of Processing	Categories of Personal Information	Legal Basis
As part of our admissions process, we collect applicant Personal Information to evaluate applications. We also may obtain Personal Information from third parties, such as other schools, references, family members, and education partners.	Name, address, contact details, race/ethnicity, demographic information, educational history, and other relevant information as part of the application package.	Legitimate Interest: Personal Information collected through the student application process is necessary to evaluate candidates for admissions and for our internal statistical and analytics purposes. Consent: Processing of Sensitive Personal Information for purposes stated above
To support course registration	Name, Stetson Student ID, contact information	Legitimate Interest: Personal Information collected for matriculated students, staff, and faculty to register for services.
To process tuition and service payments	Name, contact information, payment information	Legitimate Interest: To facility payments for annual tuition costs and service programs
To provide online/hybrid training, online/hybrid academic courses, and other online/hybrid educational programs	Name, Stetson Student ID, contact information, platform usage and interaction, student-provided data and content	Legitimate Interest: To facilitate provision, administration, instruction, and quality improvement of platform use, courses, learning, and teaching/instruction to matriculated students, staff, and faculty as appropriate for the service.
To receive brochures or other information	Name, contact information	Legitimate Interest: To send brochures or other requested information
To provide for student wellness and safety	Name, emergency contact information, health information (such as disclosed allergies)	Legitimate Interest: To provide a safe and healthy environment for students while under school supervision and ensure their health in cases of emergency
For event registration	Name, Stetson Student ID, contact information	Legitimate Interest: To process registration for sports, cultural, educational and other university events
To purchase parking passes and permits	Name, Stetson Student ID, contact information	Contract: To facilitate payments for parking passes and permits
To submit requests for services (e.g., IT, help desk, help line, CAPS, etc.)	Name, Stetson Student ID, contact information	Legitimate Interest: To process service requests from students, staff and faculty Contract: If there is a contract that governs your use of such services, Personal Information is processed pursuant to that contract
Website account registration	Name, contact information	Legitimate Interest: For websites that require registration for access, to facilitate the registration
To receive donations	Name, contact information, payment information	Legitimate Interest: To collect and process donations/gifts and donor information
To issue account credits	Name, student name(s), partially redacted email. This information is shared with selected officers of the Stetson Academy PTO, so they may administer the Credit Compensation Program.	Legitimate Interest: To issue and process account credits as part of our Credit Compensation Program.

Cookie Policy

This Cookie Policy applies to the cookies we use when you visit Stetson’s main website stetsonacademy.com and other websites that we own or control and link or refer to

this Cookie Policy (together, the “Sites”).

This cookie policy provides you with more information about cookies, what types of cookies we use and how we use them. Our Sites uses cookies with the intention of providing you with a user experience that best suits your needs, while concurrently allowing us to improve the design and functionality of our Sites. Cookies can be adjusted or disabled, and this policy provides you with instructions to do so.

Cookies

A cookie is a file designed to contain a small amount of user and website information stored on a user’s computer. The file interacts with the user and the website to provide a webpage tailored to the user through its awareness of information held within the file. Cookies also have the ability to carry all or parts of the information stored within the file to other websites that the user may visit or to third parties.

Types of Cookies

A third-party cookie is placed by a domain other than that of the website the user is visiting.

A session cookie is temporary, linking the actions of a user during the any given browser session. When the browser is closed, the cookie is deleted.

A permanent cookie, also known as a persistent cookie, is stored for a specific period of time and activates each time the user visits the website that created the cookie.

Our Use of Cookies

We use third-party, session and persistent cookies and similar technology to collect aggregate (non-personal) information about Sites usage by all of our visitors and to help us remember you and your preferences when you revisit the Sites. These cookies may stay on your browser into the future until they expire or you delete them. We also use technology to remember you the next time you log in. Some of these cookies are erased when you close your browser window and some persist for a period of time.

Further general information about cookies and how they work is available at www.allaboutcookies.org

We may allow selected third parties to place cookies through the Sites to provide us with better insights into the use of the Sites or user demographics or to provide relevant advertising to you. These third parties may collect information about a user’s online activities over time and across different websites when he or she uses our Sites.

Adjusting Cookie Settings

You can change your cookie settings by reviewing your internet browser’s cookie

options. The links below to popular browsers may help you understand your cookie

options better. Typically, such information can be found under the browser’s ‘Help’, ‘Preferences’ or ‘Options’ menus.

• Cookie settings in Chrome

• Cookie settings in Firefox

• Cookie settings in Internet Explorer

• Cookie settings in Safari – iOS

• Cookie settings in Safari – macOS

Interest-Based Advertisements

Stetson does not use your Personal Information or aggregated non-personally identifiable information to create interest-based ads or direct marketing campaigns, also sometimes referred to as personalized or targeted ads. Additionally, Stetson does not sell or share information with any third parties to use for these same advertising purposes.

To learn more about interest-based ads or to opt-out of receiving third-party interest based ads, please visit www.optout.aboutads.info www.youronlinechoices.eu. Please note that if you opt out of interest-based advertising, you will still see advertisements – they will just not be tailored to your interests. Also note that deleting browser cookies can remove the cookie preferences you have made, so you may need to opt-out again in the future.

Blocking Cookies

Should you choose to decline or block cookies by adjusting your browser settings, including cookies essential to the Sites, please note that all or parts of our Sites may not be functional or accessible to you. Additionally, be advised that our Sites will issue cookies as soon you visit the Sites, unless your browser cookie settings are adjusted to prevent such an occurrence.

Google Analytics

We use Google Analytics to help operate our Sites more efficiently, to gather demographic information, and to monitor the level of activity of our Sites. For information on how Google uses data from Sites that share information with Google, see www.google.com/policies/privacy/partners (Google may provide updates or changes to this notice from time to time). You can prevent the use of Google Analytics relating to your use of our Sites by downloading and installing a browser plugin provided by Google. If you do not want to be tracked by Google Analytics you may opt- out using Google’s official opt out browser plugin, available here.

Sharing your Personal Information

We share your information internally at Stetson to facilitate and manage the purposes listed above. This includes third parties whom Stetson engages to process your Personal Information on our behalf for the purposes stated above, such as vendors who help Stetson with our marketing, payment processing, and web hosting. Stetson may also share your personal data with government and law enforcement agencies or regulators to 1) comply with a legal process, subpoena, order or other legal or regulatory requirement applicable to us; 2) enforce our terms of use or other policies; or 3) pursue available legal remedies or defend against legal claims. Stetson does not sell your Personal Information to third parties for their use in direct marketing, advertising, or promotion of their products or services.

Non-personally identifiable information we collect and process

Standard, non-personally identifiable internet log information such as browser type and navigation to various parts of the Sites, in an aggregated form, is collected for analytical purposes to improve the browsing experience of our Sites, update relevant content and improve the overall design.

Information Security

Stetson takes the security of your Personal Information seriously. When you submit sensitive information via the website, your information is protected both online and offline.

Wherever we collect sensitive information that information is encrypted and transmitted to us in a secure way. For example, we do not store your credit card information directly. Instead, it is passed through to a third-party credit card processing merchant using 128- bit SSL encryption. We retain only your credit card's brand, last 4 digits and expiration date to assist with any billing related issues.

While we use encryption to protect sensitive information transmitted online, we also protect your information offline. Only employees who require access to your information to perform a specific job (for example, billing or customer service) are granted access to personally identifiable information. The computers and servers in which we store personally identifiable information are kept in a secure environment.

Marketing

Personal Information you submit through our Sites, such as your name, address and other contact information, may be collected by Stetson for internal marketing and development purposes as well as to respond to your inquiries, complete a transaction for you, or fulfill other forms of customer service. You can choose not to receive

marketing from us by “unsubscribing” using the instructions in any marketing email you receive from us.

Document Retention

We keep your Personal Information for as long as needed to fulfill the particular purpose for which it was collected. We may also retain your records if legally required or to fulfill a legitimate interest.

COPPA Compliance

In compliance with the Children’s Online Privacy Protection Act, children under the age of 13 are not permitted to use the Stetson Sites without parental supervision and we do not intentionally collect or maintain personal information from those who are under 13 years old. Protecting the privacy of children is very important to us. Thus, if we obtain actual knowledge that a user is under 13, we will take steps to remove that user’s personal information from our databases. We recommend that children between the ages of 13 and 18 obtain their parent’s permission before submitting information over the Internet. By using the Stetson Sites, you are representing that you are at least 18 years old, or that you are at least 13 years old and have your parents’ permission to use the website and any Services offered by us.

Limitation of Liability

YOU UNDERSTAND AND AGREE THAT ANY DISPUTE OVER THE PRIVACY OF YOUR INFORMATION IS SUBJECT TO THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY AND THE NICHE USER AGREEMENT (INCLUDING ANY INDEMNIFICATION AND LIMITATIONS ON DAMAGES CONTAINED IN THAT AGREEMENT).

Updates to Privacy Policy

Stetson reserves the right to modify this Privacy Notice at any time, so you should check it periodically. If we make changes that are material, we will provide you with appropriate notice before such changes take effect. Your continued use of the Sites after any change in this Privacy Policy will constitute your acceptance of such change.

Contact Information

For more information on how we collect and process your Personal Information, or if you have any complaints please contact us via telephone at 707-471-5101 or by email at [email protected].

Effective Date

The effective date of this policy is effective April 28, 2023.