The Personal Data that ICEO collects depends on the context of your interactions with us, on ICEO’s website – www.iceoinc.org and portal – iceoinc.hanovercrm.com (the “Site”) and the services you choose that are provided by ICEO (the “Services”).
The Personal Data ICEO Collects
The Personal Data ICEO collects and or process takes different forms – it may be factual, images or other recorded information that identifies or relates to you (whether in paper or electronic form). “Personal Data” may include any information relating to you such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity.
Examples of Personal Data that ICEO collects:
- Contact information or directory information such as, given name(s) and surname, email address, physical address, phone numbers, and other location information
- Government or other official Identification Numbers
- Personal documents in support of visa or program applications
- Photographs, audio and video recordings
- Health and safety information
- Social identification (e.g. citizenship, nationality, racial/ethnic origin)
- Personal information arising out of health, safety, or wellbeing incidents while on ICEO programs. (e.g. police reports, hospital reports)
- Any other information that you voluntarily choose to provide to ICEO that would help ICEO improve its services
- Financial payment information to process applications. (e.g. visas, application fees, SEVIS fees)
- Usage data about how you use the Site, products and Services, your IP address and location.
- Profile data such as your username and password, purchases made by you, preferences, feedback and survey responses.
- Marketing and communications data detailing your preferences in receiving marketing communications from us and third parties and your communication preferences.
Sensitive Personal Information
ICEO recognizes that certain jurisdictions have enacted laws requiring a higher protection of certain sensitive personal information. “Sensitive personal information” includes categories of Personal Data identified by European, California and other data privacy laws as requiring special treatment. This may include personal identity numbers; racial or ethnic origin; political opinions; religious, philosophical, or other similar beliefs; membership of a trade union or profession or trade association; physical or mental health; biometric or genetic data; sexual life; or criminal record (including suspected criminal activities).
As a rule, ICEO does not require such sensitive personal information from you. In the limited cases where ICEO seeks to collect such information, ICEO will try to do so in accordance with applicable data privacy laws. If you choose to provide ICEO with unsolicited sensitive personal information, you consent to ICEO using the information, subject to applicable law.
How We Collect Personal Data
ICEO receives Personal Data from multiple sources, including the following:
Information you provide directly to ICEO. ICEO gathers information about you when you provide it to ICEO, or interact with ICEO directly, for instance engaging with ICEO or registering for ICEO programs, and when you submit a contact form, create an account on the Site, or complete forms or reports , apply or enroll into or participate in ICEO programs, apply for jobs through one of the ICEO programs, request information or services from ICEO, complete ICEO surveys, submit payments, and contact or communicate with ICEO (including through the Site, by email or otherwise). ICEO also collects Personal Data from you when we administer or improve the Site, to prevent and detect fraud, and to protect and enforce its legal rights.
Agents and Other Third Parties: ICEO works with several third-party service providers who promote ICEO programs to you or who provide services to ICEO. When you submit your Personal Data to them for the purpose of enrolling or receiving information about ICEO programs, they will forward your Personal Data to ICEO. You should check with these third parties for additional information on their privacy practices. ICEO will handle your Personal Data pursuant to this Policy but ICEO is not responsible for third party privacy practices.
Automated technologies or interactions: ICEO collects information while monitoring the Site and when you provide it to ICEO, such as when you use the Site or otherwise communicate with ICEO (such as by email or via a form on our Site). ICEO may collect certain information automatically when you use the Site, such as the IP addresses and domain names of visitors, browser type, history of pages viewed and other usage information about your use of the Site. ICEO collects this information for Site administration purposes, such as to analyze this data for trends and statistics. ICEO may share statistical or aggregated non-Personal Data about our users with business partners, sponsors and other third parties. This data is used to customize our website content and advertising to deliver a better experience to our users. Please see the ICEO Cookie Notice for more information.
HOW WE USE PERSONAL DATA & LAWFUL BASIS FOR COLLECTING AND PROCESSING PERSONAL DATA
ICEO uses Personal Data only as necessary, to provide the Site, Services and programs to you, such as: ICEO Outbound Program, ICEO USA Summer Work / Travel Program, ICEO USA Internship Program, ICEO USA Training Program, and ICEO New Zealand and Australia 12-Month Student WAT Pilot Program.
ICEO’s lawful basis for collecting and processing your Personal Data includes the following:
- Performance of a Contract: This basis means we use Personal Data for the performance of a contract to which you are a party, or to take steps at your request prior to entering into an agreement or contract. We use Personal Data under this lawful basis: to correspond with you prior to entering into a contractual relationship with ICEO, to answer your questions, to process your application, to enroll you in ICEO programs, to act as an intermediary with partner organizations, to sponsor your visa applications, to keep a record of your program progress, and to provide you with programmatic or health and safety support services while on ICEO programs.
- Legal Obligation: This basis means we use Personal Data as necessary for compliance with obligations required by applicable law. We use Personal Data under this lawful basis: to act as an intermediary with government agencies including to sponsor your visa application(s), to keep a record of your program progress, and to provide you with programmatic or health and safety support services while on ICEO programs.
- Consent: This basis means we use Personal Data when you have given consent for the processing of your Personal Data for one or more specific purposes.
- Legitimate Business Purpose: necessary for the legitimate interests pursued by ICEO or third parties in providing the Site and Services. When we rely on our “legitimate interest,” we mean that we are using Personal Data in the interest of ICEO’s business to conduct and manage our organization to give you the best programs/services and the most secure experience. We make sure we consider and balance any potential impact on you, both positive and negative, and your rights before we process your Personal Data for our legitimate interests. We do not use your Personal Data for activities where our interests are overridden by the impact on you unless we have your consent or are otherwise required or permitted by law. You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting the data privacy manager at the email address provided below. We use Personal Data under this lawful basis: to conduct marketing surveys about your experience on ICEO programs.
In any case, ICEO will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract. We may process your Personal Data for more than one lawful ground depending on the specific purposes for which we are using your Personal Data.
WHEN AND HOW WE SHARE PERSONAL DATA WITH OTHERS
ICEO may disclose or share Personal Data with its local and foreign service providers for various purposes, as permitted by law. For example, ICEO may share your Personal Data with local and foreign government officials, agencies, consulate or embassies to process and facilitate your visa, host families, accommodation or transportation providers to arrange for program stay and logistics, universities to enroll you in programs, or recruiters and potential local or foreign employers to facilitate internships or jobs.
PROTECTION OF PERSONAL DATA
ICEO uses commercially reasonable security measures, in compliance with applicable law, to protect Personal Data from unauthorized access or use. Unfortunately, the transmission of information via the internet is not completely secure. Although ICEO takes measures to protect your Personal Data, ICEO cannot guarantee its security. Any transmission of Personal Data while using any of ICEO online applications or forms is at your own risk. ICEO is not responsible for circumvention of any privacy settings or security measures contained online. The safety and security of information also depends on you. If ICEO has provided you with (or you have chosen) a username and password for access to any of ICEO Site, you are responsible for keeping such information confidential. Please do not share your username and password with anyone.
LINKS TO THIRD PARTY WEBSITES
The Site may include links to third party websites and services. When you leave the ICEO Site, we encourage you to read the privacy notices of every website you visit. ICEO does not control these third party websites or services and is not responsible for their privacy practices.
FOR INDIVIDUALS IN CALIFORNIA – DISCLOSURES
The Site does not respond to Do Not Track signals and we do not use automated technologies to collect information about your online activities over time across third-party websites or other online services.
California Civil Code Section § 1798.83 permits users of our Site and Services who are California residents to request certain information regarding our disclosure of Personal Data to third parties for their direct marketing purposes. To make such a request, please e-mail us at the address listed in the Contact Us section below.
FOR INDIVIDUALS IN THE EUROPEAN UNION – GDPR PROVISIONS
GDPR stands for the General Data Protection Regulation, a European Union regulation.
For the purpose of the GDPR provisions of this Policy, the following definitions apply:
- Account means a unique account created for you to access the ICEO Site or Services or parts of our Site or Services.
- Website / the Site refers to ICEO’s www.iceoinc.org and https://iceoinc.hanovercrm.com/
- Service refers to the Site and services provided by ICEO.
- Country refers to: the United States
- Data Controller, means ICEO as the legal entity which alone or jointly with others determines the purposes and means of the processing of Personal Data.
- Service Provider means any natural or legal person or entity who processes the data on behalf of the ICEO to facilitate the Site and Services, to provide the Site/Services on behalf of ICEO, to perform services related to the Services or to assist ICEO in analyzing how the Service is used. For the purpose of the GDPR, Service Providers are considered Data Processors.
YOUR RIGHTS UNDER THE GDPR
If you are located within the European Union, you have certain rights under the GDPR which are summarized below:
- Request Access to Your Personal Data. You have the right to be informed of the Personal Data we hold about you and why and how we have it. Whenever made possible, you can access your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact ICEO to assist you. This also enables you to receive a copy of the Personal Data ICEO holds about you.
- Request Correction of the Personal Data that ICEO Holds About You. You have the right to have any incomplete or inaccurate information ICEO holds about you corrected. We will need to verify the accuracy of the new data you provide to us. And, we may not be able to accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
- Object to or Restrict the Processing of your Personal Data. This right exists where ICEO is relying on a legitimate interest as the legal basis for ICEO’s processing and there is something about your particular situation, which makes you want to object to ICEO’s processing of your Personal Data on this ground. You also have the right to object where ICEO is processing your Personal Data for direct marketing purposes. Additionally, you have the right to restrict the processing of your Personal Data if the accuracy of the data is being contested, the processing is unlawful, we no longer need the data for its original purpose but you would like us to hold the data because you need it to establish, exercise or defend legal rights, or you have objected to our use of the data but we need to verify if we have overriding legitimate interests to use it.
- Request Erasure of your Personal Data. You have the right to ask ICEO to delete or remove Personal Data when there is no good reason for ICEO to continue processing it. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be provided to you, if applicable, when evaluating your request. By requesting that we delete your Personal Data, we may keep anonymized or de-identified statistical data that is not connected to your identity.
- Request the Transfer of your Personal Data. ICEO will provide to you, or to a third-party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which you initially provided consent for ICEO to use or where ICEO used the information to perform a contract with you.
- Right to Withdraw your Consent. You have the right to withdraw your consent to the processing of your Personal Data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, ICEO may not be able to provide you with access to certain specific functionalities of the Site or Service.
EXERCISING YOUR RIGHTS UNDER THE GDPR
You may exercise your rights of access, rectification, cancellation and opposition by contacting ICEO at the address provided in the Contact Us section below. Please note that ICEO may ask you to verify your identity before responding to such requests. If you make a request, ICEO will try its best to respond to you as soon as possible.
You have the right to complain to a Data Protection Authority about ICEO’s collection and use of your Personal Data, but we would appreciate the chance to deal with your concerns before you approach the supervisory authority. For more information, if you are in the European Economic Area (EEA), please contact your local data protection authority in the EEA.
TRANSFERRING PERSONAL DATA TO THE UNITED STATES
CONSENT TO TRANSFER AND PROCESS PERSONAL DATA
Any Personal Data that is provided to ICEO will be hosted in the United States. By submitting your Personal Data on the Site and registering or participating in any ICEO programs or services, you consent to the transfer to and the processing of your Personal Data in the United States.
YOUR CHOICES ABOUT YOUR PERSONAL DATA
We strive to provide you with choices regarding certain uses of your Personal Data, particularly around marketing communications and advertising.
- Promotional Offers From ICEO. We may use your Personal Data to provide you with marketing communications that we think might be of interest to you, if you have not opted out of receiving those marketing communications. If we send you marketing communications, it will include instructions on how to opt out of receiving such emails in the future. If you elect to opt out of receiving email communications, we may still send you emails about your programs.
- Opting Out. You can direct us or third parties to stop sending you marketing communications at any time by contacting us at the email address provided below.
- Mobile Devices. Your mobile device may give you the ability to opt out of the use of information from the apps you use (e.g., “Opt out of Interest-Based Ads” or “Opt out of Ads Personalization” on Android devices, and “Limit Ad Tracking” on iOS devices). You may also stop the collection of location information from your mobile device by changing the preferences on your mobile device.
- Change of Purpose. We will only use your Personal Data for the purposes for which we collected it, unless we reasonably determine that we need to use it for another reason compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at the e-mail address provided below. If we need to use your Personal Data for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so.
DATA STORAGE AND RETENTION
Your Personal Data is stored by ICEO on its servers, and on the servers of the cloud-based database management services ICEO engages. ICEO keeps your Personal Data for as long as it is necessary for the purpose set out in this Policy, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).
For more information on where and how long Personal Data is stored, and for more information on rights of erasure and portability, please see the Contact Us section below for our contact information.
The programs that we offer are not intended for person under the age of 18, and we do not knowingly collect Personal Data from persons under the age of 18. If you are under the age of 18, do not use or provide any information through the Site. If we learn that we have collected or received Personal Data from a child without verification of parental consent, we will delete that information. If you believe we might have any Personal Data from or about a child under 18, please contact us at the address provided in the Contact Us section below.
NOTIFICATION OF CHANGES
LAST REVISED: September 30, 2020