Effective:  August 27, 2018

Welcome to the Higher Learning Advocates website (the “Site”) provided and owned by Higher Learning Advocates (“our” or “we” or “us”). This Privacy Policy describes the types of information we collect from our Site or that you provide to us through other means, how we may use that information, to whom and under what circumstances we may disclose it, and how we protect it.  We also tell you how to update your information or contact us with questions about our privacy practices. This Privacy Policy also extends to any and all Sites owned and operated by the Higher Learning Advocates. By using this Site or voluntarily providing personal information to us, you consent to the terms of this Privacy Policy. If you do not agree to the policy, please do not use the Site

1. Collection of Personal Information from Site Users.

Information Collected Automatically

Each time you visit the Site, we may automatically collect certain types of information. Some examples of automatic information we may collect are as follows:

• Your IP address, MAC address, browser type, operating system, device-identifying information, type of computer, and type of Web browser software, the specific webpages visited during your connection and the domain name from which you accessed the Site.
• Information about your browsing behavior, such as the date and time you visit the Site, the areas or pages of the Site that you visit, the amount of time you spend viewing the Site, the number of times you return to the Sites and other clickstream data.
• We may use “cookies” of different types to recognize your computer.  A cookie is a small text file that a website, online application, or e-mail may save to your internet browser and/or your computer’s hard drive for use in subsequent visits to the Site or other sites.
• We may use web beacons, match scripts, pixel tags or similar technologies that allow us to know if a particular web page was visited, an e-mail opened, or links in the email utilized.  In some instances, these technologies may allow us to match activities with particular users.

Information You Give to Us

We may collect any information, such as your first and last name, email address, postal address, and telephone number that you provide when you interact with us.  Some examples are when you:

• Correspond with us.
• Register for a meeting or event.
• Complete an online form, or surveys.
• Make a donation.

In some jurisdictions, individuals may have the right to provide opt-in consent or withdraw consent for certain uses. If you reside in such jurisdictions, you may have additional rights which are detailed below, “Access, Correction and Deletion.”

2. Use of Personal Data Collected. Higher Learning Advocates may use personal data it collects for editorial and feedback purposes, for marketing and promotional purposes, for a statistical analysis of users’ behavior, for product development, for content improvement, to customize the content and layout of the Site, or to notify you about updates to the Site.

If you make a donation we will request personally identifiable information about you, such as your name, address, phone number, email address and debit/credit card information. We seek such information primarily to facilitate donations and to communicate with you about them.

3. Sharing or Disclosure of Your Personal Data.  Unless otherwise agreed, Higher Learning Advocates will not sell or disclose to third parties any individually identifying information, such as names, postal and e-mail addresses, telephone numbers, and other personal information which users voluntarily provide to the Higher Learning Advocates, except as follows:

• We may use outside service providers to facilitate the Site and overall operation, and to perform functions on our behalf, such as sending postal mail and email, removing repetitive information from donor lists, analyzing data, processing credit card payments and providing customer service. These third parties may have access to your personal information as needed to perform their functions, but they may not use it for any other purpose.
• To the extent necessary to comply with applicable laws or valid legal processes, such as in response to subpoenas or court orders.
• To protect the rights and intellectual property of Higher Learning Advocates.
• To investigate, prevent or take action regarding illegal activities, suspected fraud, violations of our policies, or as otherwise required by law.
• In urgent circumstances to protect Higher Learning Advocates or the personal safety of any individual.
• We may transfer information about you to successors to the relevant portion of the Higher Learning Advocates’s business.
• We may also disclosure your personal information with your express consent.

4. Cookies Policy.  To enhance the Internet experience, Higher Learning Advocates may also use Internet technologies such as “cookies” and “JavaScript.”  Higher Learning Advocates may identify users through these technologies solely to customize and enhance the Internet experience of the individual users. For example, Internet cookies save data about individual users, such as the user’s name, password, user-name, screen preferences, the pages of a site viewed by the user, and the advertisements viewed or clicked by the user. When the user revisits the Site, Higher Learning Advocates may recognize the visitor by the Internet cookie and customize the user’s experience accordingly. Users may decline Internet cookies, if any, by using the appropriate feature of their Web client software, if available. If cookies are disabled, however, all features of our Site may not operate as intended. We believe these technologies add value to the user experience, and the information resulting from these technologies is not sold or otherwise made available to third parties, unless otherwise agreed. This information may include which URL you just came from, which URL you next go to, what browser you are using, what features you click on and read (in whole or in part), and your IP address. We use such data only in the aggregate. This collective data helps us to determine how much our visitors use parts of the website, and to do internal research on our users’ demographics, interests, and behavior, so as to better understand and serve you.

We or our partners may also use Flash cookies (also known as Local Stored Objects) or other similar technologies. A Flash cookie is a small data file placed on a computer using Adobe Flash or similar technology that may be built into your computer or downloaded or installed by you to your computer. We use these technologies to personalize and enhance your online experience, facilitate processes, and personalize and store your settings. Flash cookies may help our website visitors to, for example, set volume preference associated with a video experience, play games and perform surveys. They help us improve our Site by measuring which areas are of greatest interest to customers. They may be recognized by other sites or by our marketing or business partners. Flash cookies are different from browser cookies and the cookie management tools provided by your browser may not remove Flash cookies. Click here to learn how to manage privacy and storage settings for Flash cookies. If you disable Flash cookies or other similar technologies, please be aware that you may not have access to certain features and services that make your online experience more efficient and enjoyable.

We may also use web beacons, which are electronic images that may be used on our websites or in our emails. We use web beacons to deliver cookies, count visits, understand usage and campaign effectiveness and to tell if an email has been opened and acted upon.

5. Access, Correction & Deletion.  Higher Learning Advocates respects your right to access and correct your personal information. Upon request via e-mail Higher Learning Advocates will provide to users a summary of any personally identifiable information retained by Higher Learning Advocates regarding the user.  Users may modify, correct, change or update personally identifiable information that Higher Learning Advocates has collected by the Site. You may also exercise your rights, subject to applicable laws, to request that we delete or restrict access to your personal data. We may need to retain it for legally permitted purposes and this will be explained to you if necessary.

If you need assistance correcting or updating your personal information, or would like to request that we delete your personal information, please contact us using the contact information detailed in the “Contact Us” section below

6. Retention of Personal Information.  Personal information that we collect, access or process will be retained only as long as necessary for the fulfilment of the purposes for which it was collected, unless otherwise provided in agreements between you and Higher Learning Advocates or as required or authorized by law. Personal information that is no longer required to fulfil the identified purposes will be destroyed, erased or made de-identified.

7. Collection of Personal Data from Children. The Site is not directed to children, nor do we knowingly collect any personal information from, children under the age of thirteen without verifiable parental consent. If you believe that a child has provided personal information to us, please contact us promptly as described below, and we will endeavor to investigate and delete such information from our systems.

8. Links to Other Sites. The Site may contain links to other websites, such as social media sites like Facebook and Twitter, which may have privacy policies that differ from our own.  We are not responsible for the activities and practices that take place on these websites. Accordingly, we recommend that you review the privacy policy posted on any external site before disclosing any personal information. Please contact those websites directly if you have any questions about their privacy policies.

9. Security. We maintain reasonable and appropriate measures designed to maintain information we collect in a secure manner. We have taken certain physical, electronic, and administrative steps to safeguard and secure the information we collect from Site visitors. Even though we follow reasonable procedures to try to protect the information in our possession, no security system is perfect and we cannot promise, and you should not expect, that your information will be secure in all circumstances.

10. Do Not Track.  Do Not Track (DNT) is a privacy preference that users can set in some web browsers, allowing users to opt out of tracking by websites and online services. At the present time, the World Wide Web Consortium (W3C) has not yet established universal standards for recognizable DNT signals and therefore, Higher Learning Advocates and the Site do not recognize DNT.

11. Changes to Privacy Policy. We may change this privacy policy from time to time, including as required to keep current with rules and regulations, new technologies and security standards. When we do, we will post the change(s) on our website. If we change the policy in a material and retroactive manner, we will provide appropriate notice to you.

12. Your California Privacy Rights.  This Privacy Policy describes how we may share your information for marketing purposes, as described above.  California residents are entitled to request and obtain from us once per calendar year information about any of your personal information shared with third parties for their own direct marketing purposes, including the categories of information and the names and addresses of those businesses with which we have shared such information.  To request this information and for any other questions about our privacy practices and compliance with California law, please contact us as set forth below.

13. Visitors from Outside the United States—Cross-Border Transfer

The Site is hosted in the United States. If you are visiting the Site from outside the United States, your information may be transferred to, stored and processed in the United States or other countries in accordance with this Privacy Policy.  The data protection and other applicable laws of the United States or other countries may not be as comprehensive as those laws or regulations in your country or may otherwise differ from the data protection or consumer protection laws in your country. Your information may be available to government authorities under lawful orders and law applicable in such jurisdictions. By using the Site and/or providing personal information to us, you consent to transfer of your information to our facilities as described in this Privacy Policy.

14. Right to Lodge Complaints

We are transparent about the ways in which we collect and use personal information, and welcome your questions and concerns. If you have any concern or complaint about the way we handle your personal information, please contact us as described below. To the extent you believe we have not addressed your concerns or otherwise choose to do so, you have the right to lodge a complaint with a supervisory authority in the country where you reside and/or the United States. You may contact the US Federal Trade Commission regarding your concerns. For more information, please see https://www.ftc.gov/faq/consumer-protection/submit-consumer-complaint-ftc.  Within the United Kingdom, you may obtain more information about how to protect your rights and lodge a complaint by contacting the UK Information Commissioner’s Office, see https://www.gov.uk/data-protection/make-a-complaint.

15. Contact Us. Questions or concerns regarding Higher Learning Advocates data protections practices should be addressed to:

E-mail: info@higherlearningadvocates.org

Mail: 1001 Connecticut Ave, NW, Suite 710, Washington, DC 20036

Telephone: (202) 470-6432