In addition to Processing the types of Personal Information listed above, the School necessarily Processes a wide variety of Personal Information about Individuals that is of a sensitive nature (“Sensitive Personal Information”), which includes, but is not necessarily limited to, the following: (i) Students who are children as well as family members of Students, other Individuals associated with Students, and other members of the School community who are children; (ii) Social Security number and other governmental identification number; (iii) credit card, debit card, and bank and other financial account number; (iv) date of birth; (v) race, ethnic origin, national origin, citizenship, immigration status, religious and political belief and affiliation, and sexual orientation and identity; (vi) health information; (vii) biometric information; and (viii) geolocation information. For purposes of this Policy, Sensitive Personal Information is considered to be a special category of Personal Information.
The School Processes Personal Information in order to fulfill our statutory, contractual, common law, and other commercial and legal relationships and duties, including to provide Services to Students. The School also obtains consent from Individuals for the Processing of Personal Information, including obtaining consent from Individuals to Process your Sensitive Personal Information, and obtaining consent from the parents or legal guardians of Students for the Processing of Personal Information and Sensitive Personal Information about Students.
If and to the extent necessary and not prohibited by Data Privacy Laws, the School also may Process Personal Information and Sensitive Personal Information for one or more of the following reasons: (i) comply with local, state, federal, or foreign laws, rules, or regulations; (ii) comply with a civil, criminal, judicial, executive, legislative, agency, or other regulatory inquiry, investigation, subpoena, summons, or other legal process; (iii) cooperate with a law enforcement agency or authority concerning conduct or activities that the School in good faith believes may violate a local, state, federal, or foreign law, rule, or regulation; (iv) investigate, establish, exercise, prepare for, or defend any allegation or claim concerning conduct that the School in good faith believes may violate a School rule or policy or a local, state, federal, or foreign law, rule, or regulation; (v) protect an interest that is essential for the life or physical safety of the Individual or another person; (vi) detect, respond to, prevent or protect against illegal or unlawful activity, fraud, harassment, malicious or deceptive activities, identity theft, or other any other security incident; (vii) create, evaluate, develop, improve, enhance, and otherwise manage the Services; and (viii) engage in other educational, academic, non-academic, curricular, extra-curricular, business, operational, financial, technological, and other activities that are or should be reasonably aligned with the expectations of Individuals, reasonably anticipated based on your relationship with the School, or otherwise compatible with the Processing of Personal Information and Sensitive Personal Information in furtherance of providing the Services.
No Sale of Personal Information/Disclosure of Personal Information
The School will not sell any of your Personal Information to any third party. The School also will not disclose your Personal Information to any third party, or otherwise share your Personal Information with any third party, except as set forth in this Policy.
If and to the extent necessary to perform one or more of the legal bases for Processing Personal Information identified in this Policy, the School may disclose your Personal Information as follows: (i) to the Individual about who the Personal Information pertains, the parents or legal guardians of the Student about who the Personal Information pertains, and that Individual’s or Student’s legal representatives; (ii) pursuant to civil, criminal, judicial, executive, legislative, agency, regulatory, or law enforcement inquiry, investigation, subpoena, summons, or other legal process (iii) child safety and public health agencies, authorities, and officials; (iv) to professional service providers, including attorneys, accountants, tax professionals, financial advisers, public relations and media advisers, and consultants, if doing so is necessary or appropriate to obtain professional services from them; (v) to organizations that provide marketing and advertising services, and to other suppliers and vendors, if doing so is necessary to obtain good or services from them, provided that the School will secure an appropriate data processing agreement with such organizations, suppliers and vendors prior to disclosing Personal Information to them; and (vi) in connection with a sale, merger, consolidation, change in control, transfer of substantial assets, reorganization, or liquidation of the School.
Depending on the Personal Information that the School has about an Individual, depending on the Services we provide related to that Individual, and depending on the manner in which we Process an Individual’s Personal Information, you may have the following privacy rights related to our Processing of your Personal Information, and parents and legal guardians of Students may have the following privacy rights related to our processing Personal Information of Students.
Confirm whether the School Processes Personal Information
Be informed about how Personal Information is Processed, the categories of Personal Information Processed, and the categories of sources from which Personal Information was collected
Access or receive a copy of Personal Information, and portability of Personal Information in a commonly used format to the extent technologically feasible
Rectify, update and correct inaccurate or incomplete Personal Information, taking into account the nature of and purpose for Processing of Personal Information
Limit, object to, and opt-out of Processing of Personal Information
Withdraw consent to Processing of Personal Information to the extent such Processing is based on consent, provided that such withdrawal will not affect the lawfulness of Processing of Personal Information before such withdrawal
- Deletion of Personal Information
Be informed about whether and how Personal Information is being sold, shared, traded, exchanged or brokered with unaffiliated third parties, and, if so, which categories of your Personal Information are being sold, shared, traded, exchanged or brokered with unaffiliated third parties
- Opt-out of the sale, sharing, trading, exchange, and brokering of Personal Information with unaffiliated third parties
- Non-discrimination for exercising your privacy rights
To make a privacy rights request, please complete and submit the Privacy Rights Request Form
on the School’s website, or contact our Data Privacy Officer. The School will confirm receipt of all such a privacy rights request within 10 days of our receipt of it. The School will substantively respond to all such privacy rights requests within 45 days, subject to any lawful extension of that period. Additionally, there may be a delay in processing a privacy rights request while we verify that the request is valid and originates from you as opposed to an unauthorized person.
Please be aware there may be valid reasons for the School to decline to comply with a privacy rights request, either in whole or in part. For example, the School may be required to retain and Process certain Personal Information under local, state, federal and foreign laws, rules, and regulations. Similarly, to provide Services to you or your Student, the School may be unable to comply with a privacy rights request in whole or in part, or compliance with a privacy rights request may limit or prevent the School from providing Services to you or your Student. In those situations, the School will notify you in writing within 45 days. You may also contact our Data Privacy Officer for help with those situations. Finally, the School’s ability or duty to comply with privacy rights requests may be limited by Data Privacy Laws.
If you disagree with any response, position, or other decision that the School has taken or made with respect to your privacy rights request, you may appeal by completing and submitting the appeal field in the Privacy Rights Request Form
on the School’s website, or by contacting our Data Privacy Officer and requesting such an appeal. The School will confirm receipt of such an appeal within 10 days of our receipt of it. The School will substantively respond to all such appeals in writing within 60 days, subject to any lawful extension of that period.
The School will not discriminate against you if you exercise any of the foregoing rights or any other rights under Data Privacy Laws, including, by not denying Services to you or your Student, not providing a different level or quality of goods or Services to you or your Student, and not suggesting that you or your Student will receive a different level or quality of Services.
Automated Decision Making
The School does not use automated decision making or profiling in the Processing of Personal Information, and does not make decisions that affect you based on automated decision making or profiling using Personal Information.
When you visit the School’s website, we may place a cookie (a text file containing a randomly assigned number) on your device so that we have the ability to customize the look and feel of the website for you. Cookies remember information about you, your preferences, and your device for a better user experience when visiting the website. Using cookies, the School may also collect a variety of other information regarding your usage of the website, including your Internet protocol address, username, session identification, browser, web pages viewed, referring web pages, when you access the website, and general online behavior for performance and marketing purposes.
Changes to Policy
The School reserves the right to change or amend this Policy at any time and for any reasons, including to remain in compliance with Data Privacy Laws.
Questions or Concerns
If you have any questions or concerns about this Policy or about the School’s Processing of Personal Information, please contact our Data Privacy Officer as follows:
Name: Andreka Johnson
Physical address: 3433 Rose Lane, Falls Church, VA 22042
Phone number: 703-992-0255
Email address: firstname.lastname@example.org
Last Updated: July 28, 2023