Privacy Notice
Last Edited on 2019-04-04
We’ve developed this privacy policy to explain how your personal information is being collected and used by Independent School Management, Inc. (“ISM”), FAST, LLC (“FAST”), and other entities under the ISM umbrella (with the exclusion of ISM Insurance, which is governed by a separate Privacy Policy). Please read our privacy policy carefully to get a clear understanding of how we collect, use, protect, and otherwise handle your information.
When you use one of our websites
This Privacy Policy relates to all websites using the following domains, unless explicitly stated otherwise in a separate privacy policy on the website:
What type of information do we collect?
When purchasing a product or service, filling out a form, or registering on our site, as appropriate, you may be asked to enter your name, email address, mailing address, phone number, billing information, or other details to help you with your experience. We also automatically collect your IP address to improve our website.
When do we collect information?
We collect information from you at the time you visit our website, register on our website, order a product or service, or fill out a form.
How do we use your information?
We use the information that you provide on our website to fulfill your requests, process orders, and improve our website.
How do we share your information?
We may share the information collected on our website with vendors who provide services to ISM. For example, as discussed in greater detail below, ISM works with Google to facilitate analytics and advertising. We also may share your information with governmental bodies as necessary for compliance with law, with law enforcement authorities when necessary, and other third parties to enforce our legal rights.
What is our legal basis for processing personal information of EU residents?
With respect to personal information subject to the General Data Privacy Regulation (“GDPR”), our processing is based on our contractual obligations to provide you with the requested services, our legitimate business interests in operating our website, and, when applicable, your consent.
When you access membership services
What type of information do we collect?
We collect information from you including school name, membership administrator name, title, mailing address, and email address.
When do we collect information?
We collect information from you at the time you register for our membership, add a user to your membership, or you fill out a form to make changes to or customize your school’s membership access.
How do we use your information?
We may use the information we collect from you when you register, make a purchase, sign up for our newsletter, respond to a survey or marketing communication, navigate the website, or use certain other site features in the following ways:
- To personalize your experience and to allow us to deliver the type of content and product offerings in which you are most interested.
- To improve our website in order to better serve you.
- To allow us to better service you in responding to your customer service requests.
- To quickly process your transactions.
- To send periodic emails regarding your order or other products and services.
- To follow up with you in response to correspondence (live chat, email or phone inquiries)
How do we share your information?
We may share the information collected on our website with vendors who provide services to ISM and governmental bodies as necessary for compliance with law, with law enforcement authorities when necessary, and other third parties to enforce our legal rights.
What is our legal basis for processing personal information of EU residents?
With respect to personal information subject to the GDPR, our processing is based on our contractual obligations to provide you with the requested services, our legitimate business interests in operating our website, and, when applicable, your consent.
When you complete an ISM survey
What type of information do we collect?
When you complete an ISM survey, we collect all of the information that you provide in response to the survey questions.
When do we collect information?
We collect the survey information from you at the time you enter it on the survey website or in hard copy form.
How do we use your information?
We use the information that you provide in response to surveys to inform our school customers and improve our products and services.
How do we share your information?
We may share the information collected on our website with vendors who provide services to ISM and governmental bodies as necessary for compliance with law, with law enforcement authorities when necessary, and other third parties to enforce our legal rights. We may share anonymized information about your survey submission with schools.
What is our legal basis for processing personal information of EU residents?
With respect to personal information subject to the GDPR, our processing is based on our legitimate business interests in facilitating surveys, and, when applicable, your consent.
When you sign up for an ISM e-mail list or newsletter
What type of information do we collect?
When you sign up for an ISM e-mail list or newsletter, we collect your name and e-mail address.
When do we collect information?
We collect this information only when you provide it to us.
How do we use your information?
We use the information that you provide to send you e-mails and newsletters that we believe will be of interest to you.
How do we share your information?
We may share the information with vendors who provide services to ISM and governmental bodies as necessary for compliance with law, with law enforcement authorities when necessary, and other third parties to enforce our legal rights. We may share anonymized information about your survey submission with schools.
What is our legal basis for processing personal information of EU residents?
With respect to personal information subject to the GDPR, our processing is based on our legitimate business interests in facilitating e-mails and newsletters, and, when applicable, your consent.
When you use FAST®
What type of information do we collect?
FAST®, our cloud-based software collects specific student/family information which is used to determine need for financial aid. We collect information and supporting documentation that you provide in your financial aid submission and financial information, including financial information about your family members. This includes, but is not necessarily limited to names, addresses, ages, dates of birth, Social Security income, trust information, and tax records.
When do we collect information
We collect this information at the time you provide it to us.
How do we use your information?
Your personal information will be used by authorized school administrators at the school to which you are applying expressly for the purpose of determining financial aid eligibility and determining awards. We also may use the information that you provide for research and statistical purposes (in an anonymized fashion), for compliance with legal obligations, to respond to subpoenas, court orders, or other legal process, and to enforce our agreements, to prevent or investigate fraud or other unlawful activity, and to protect the security of FAST’s property, website, and other systems.
We will use school information for our internal marketing purposes or family testimonials when explicitly agreed to by the family via opt-in at the time of data collection.
How do we share your information?
We may share the information with School administrators at the school to which you are applying, vendors who provide services to ISM (including Google and OnBrand Customer Service), and governmental bodies as necessary for compliance with law, with law enforcement authorities when necessary, and other third parties to enforce our legal rights. We will at no time sell any school, student, or family information with or to third parties, or use such information in conjunction with third parties or any other purpose other than as authorized at the time the information is provided.
Only authorized FAST staff members and authorized administrators at the school to which you are applying have access to your information. This access enables the FAST staff to assist you in resolving any issues that may arise. In the case of divorced or separated families, all information is kept separate. Spouses who are separated cannot access one another’s confidential information. Neither FAST nor authorized school administrators will release one spouse’s information to the other spouse. Any FAST staff member who knowingly violates FAST’s confidentiality policies is subject to disciplinary action, including the possibility of termination. FAST does not sell any customer information to third-party marketing companies.
What is our legal basis for processing personal information of EU residents?
With respect to personal information subject to the GDPR, our processing is based on our obligation to provide you services or perform contractual obligations, our legal obligations, our legitimate business interests in facilitating your relationship with the school to which you are applying and, when applicable, with your consent.
Third-party links
We do not include or offer third-party products or services for you on our website. However, third parties providing services to ISM will sometimes need to collect, use and disclose information on our websites to the extent necessary to allow them to perform the services they provide to us and consistent with the terms of the Policy. For example, ISM contracts with third-party payment gateways and other payment transaction processors to facilitate purchase-related transactions.
Where an ISM website contains hyperlinks to websites operated by third parties, these linked websites are not under the control of ISM, and ISM is not responsible for the contents of any linked website. ISM provides these hyperlinks to you for convenience only and the inclusion of any link does not imply any endorsement of the linked website by ISM. You link to any such website entirely at your own risk, and we recommend that you read their privacy policies so you can understand the manner in which your personal information will be handled by these providers.
How secure is our site?
ISM maintains appropriate technical and organizational measures to ensure a level of security appropriate to the risks represented by the processing and the nature of the personal data to be protected. We periodically assess risks to your information and update our policies, procedures and technology accordingly.
If you are applying to a school that has contracted with FAST to handle tax scanning and verification, you will send tax returns and supporting tax documentation to FAST. After processing, all physical tax forms are securely destroyed for your protection.
Retention of Data
ISM retains your personal and financial information only as long as is necessary to complete its legitimate business purposes.
Individual Rights
If you are located in the European Union (“EU”), you may have the following legal rights under applicable law with respect to the personal information processed by ISM:
- To withdraw consent at any time, if we are processing your personal information on the basis of consent
- To access the information that ISM has about you
- To request that ISM rectify or erase your information
- To request that ISM restrict the way it uses your information
- To object to the way ISM uses your information
- To ask ISM to transfer your information to someone else
- To lodge a complaint with a data protection authority in the EU
ISM’s ability or obligation to comply with your requests may be limited by applicable law.
To request to exercise one of these rights, please contact us at info@isminc.com.
Do we use ‘cookies’?
Yes. Cookies are small files that a site or its service provider transfers to your computer’s hard drive through your Web browser (if you allow) that enables the site’s or service provider’s systems to recognize your browser and capture and remember certain information. For instance, we use cookies to help us remember and process the items in your shopping cart. They are also used to help us understand your preferences based on previous or current site activity, which enables us to provide you with improved services. We also use cookies to help us compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future. And we use cookies to facilitate authentication and authorization.
On our websites, you will be notified of the presence of cookies via a pop-up message on your first visit to the site. You also can choose to have your computer warn you each time a cookie is being set, or you can choose to turn off all cookies. You do this through your browser (like Internet Explorer) settings. Each browser is a little different, so look at your browser’s Help menu to learn the correct way to modify your cookies.
Although you have the ability to disable cookies, most of the features on ISM websites will not function because cookies are used for authentication and authorization. Most notably, the FAST software will not be able to operate.
Google’s advertising requirements can be summed up by Google’s Advertising Principles. They are put in place to provide a positive experience for users.
We have implemented the following:
- Remarketing with Google AdSense
- Google Display Network Impression Reporting
We, along with third-party vendors, such as Google use, first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) or other third-party identifiers to compile data regarding user interactions with ad impressions and other ad service functions as they relate to our website.
Users can set preferences for how Google advertises to you using the Google Ad Settings page. Alternatively, you can opt out by visiting the Network Advertising initiative opt out page or permanently using the Google Analytics Opt Out Browser add on.
COPPA (Children Online Privacy Protection Act)
We do not specifically market to children under 13. To the extent any information related to a child under the age of 13 may be provided on any website covered by this Privacy Policy, such information should only be provided by a parent or guardian. Please read our pledge to safeguard student privacy here.
Through in-school, offline surveys, children under the age of 13 may sometimes provide anonymized information to ISM. Any such data is collected anonymously, under the direct supervision of the child’s school, and in a means that prevents ISM from having any direct or indirect line of communication with the child.
California Privacy Rights/Other State Laws
California Civil Code Section 1798.83 entitles California customers and Users to request information concerning whether a business has disclosed Personal Information to any third parties for the third parties’ direct marketing purposes. California customers or Users who wish to request further information about our compliance with this law or have questions or concerns about our privacy practices and policies may contact us through the information provided below.
Questions and Contact Information
If you would like to: access, correct, amend or delete any personal information we have about you, register a complaint, or simply want more information contact:
Independent School Management, Inc.,
2207 Concord Pike, #417
Wilmington, DE 19803
USA
info@isminc.com
302-656-4944
Changes to this Privacy Policy
ISM will not make material changes to this privacy policy without first providing prominent notice to you and allowing you choices before data is used in any manner inconsistent with privacy policy you were initially provided.
