Who are we?
The Experiment in International Living trading as EIL Intercultural Learning and as EIL/AFS is a Company Limited by Guarantee (CLG) not having a share capital, registered in Dublin, Ireland with offices at Classic House, 11 – 13 Washington Street, Cork T12 NHP1. The registered company number is 136044 and The Experiment in International Living is a recognised charity (Charity Reg. No 20107390).
The Experiment in International Living is in membership of the following international federations: http://federationeil.org/ AFS International https://afs.org/ For the purpose of this statement when we refer to EIL/AFS we mean Experiment in International Living CLG.
- EIL/AFS collects and uses personally identifiable information (PII) that you submit;
- EIL/AFS collects and uses this PII for the purpose of providing EIL/AFS services, including in person and online educational programmes, for marketing and communication in relation to these services, and for performing research;
- For the purpose of providing its services, EIL/AFS may transfer this PII to EIL and AFS organizations and other parties involved in the provision of EIL/AFS services in your home country and in other countries;
- EIL/AFS transfers this PII across international borders to securely store this information in other countries. Currently those locations are in the USA, Belgium and Singapore.
- You have the right to access and update your PII at any time;
- In some circumstances you have the right to request the erasure of your PII;
- EIL/AFS may use (third party) cookies and other similar techniques to obtain information from you when using the EIL/AFS website(s) in order to facilitate your use of these websites;
- If you are a minor and your parent’s/legal guardian’s consent is required for you to provide PII, ask for your parent’s/legal guardians for permission.
PII includes amongst other things, your name, your home and e-mail address, your date of birth, your mobile telephone number, schools and university attended, highest grade/qualification received, year of graduation, area of study, social media links, an image, photo or video of you, specific EIL/AFS programme information (type, year, etc.), travel details, a personal statement, your CV or resumé, certain medical history and medical disclosures, as well as answers to specific questions that we may ask depending on the type of program you apply for or services that you request.
GOALS AND PURPOSE
EIL/AFS is dedicated to protecting your privacy and safeguarding your personally identifiable information. EIL/AFS works hard to create an online experience that is detailed, efficient and productive by using the information you entrust us responsibly. EIL/AFS is committed to respecting your privacy and adhering to the principles of applicable data protection and privacy laws throughout the world.
EIL/AFS operates a website located at the following domain https://www.eilireland.org/
This website may ask for and/or collect personally identifiable information, for example when you inquire or apply for an EIL/AFS in-person or online programme, in order to provide you with the information and services you seek or to improve your experience, as detailed further below. Our website (or certain areas within a particular website) are for the general public, while areas within the site are only for organizations that are part of the AFS and EIL worldwide networks of exchange organizations (and their authorized representatives) or for specifically designated and authorized third-parties that work closely with EIL/AFS to operate intercultural exchange programs and to provide online and real-world services
Similarly, some areas within the website are only for registered users (e.g., individuals who are prospective, current or former participants in the services and programmes offered by EIL/AFS.
TYPES OF INFORMATION WE COLLECT
EIL/AFS collects information from visitors and users of our websites, and attendees of our events, including Participants, and from third-parties that work with EIL/AFS to deliver EIL/AFS’s services so that we can provide an experience (online and offline) that strives to meet our Participants’ and other users’ needs and interests. Information may be collected as part of: (i) providing EIL/AFS programme services, (ii) fulfilling information requests, (iii) requesting or offering services, (iv) applying or registering for EIL/AFS programme participation or EIL/AFS events, (v) submitting an application or program opportunity, (vi) responding to communications from us (e.g., surveys, requests for additional information or reviews or application or registration confirmations), (vii) accommodating your personal preferences, (viii) fulfilling requests for services, e.g., subscribing to newsletters or participating in promotions, grants or awards or sweepstakes, (ix) working with third-party sources, including collecting information available from certain social networking and other websites to better assist us with understanding your interests and to serve you better, (x) updating your information including your contact information, (xi) keeping you informed about and involved with EIL/AFS activities, or (xii) conducting fundraising campaigns.
The types of personally identifiable information (sometimes referred to as“PII”) that we ask for and/or collect depend on your level of access and participation within our websites (and the types of services, information and participation you are seeking, such as applying for or participating on an EIL/AFS intercultural exchange program or activity or activity or applying for an EIL/AFS online programme or other type of course or event). Such information depends on the type of programme or activity, and based on the type of programme you apply for, as indicated in the respective application.
For our in-person exchange programmes we require very detailed information to operate the programme, including finding a host family and hosting school, and offering travel medical insurance. In this case the requested information it may include your name, a password, home address, work address and e-mail address, telephone number, mobile telephone number, geo-location information, date of birth, gender, schools and university attended, highest grade/qualification received, year of graduation, area of study, social media links to Facebook, Twitter, Instagram, and/or LinkedIn, an image, photo or video of you, your citizenship, passport information, visa status, insurance status, specific EIL/AFS programme information (type, year, etc.), travel details, a personal statement, your CV or resume, what languages you speak, your current occupation and other relevant skills, certain medical history and medical disclosures, dietary restrictions, certain usage data, such as test results, assessments, scores, progress, answers to specific questions, and lifestyle information such as leisure activities, and other information necessary to fulfill special requests (e.g., health conditions that may require special accommodation or consideration in connection with an EIL/AFS intercultural exchange programme or activity).
For applying and participating on online programs, we may request your name, address and email address, phone number, geo-location information, date of birth, gender, schools and university attended, highest grade/qualification received, year of graduation, area of study, social media links to Facebook, Twitter, Instagram, and/or LinkedIn, an image, photo or video of you, your citizenship, travel details, a personal statement, your CV or resume, what languages you speak, your current occupation and other relevant skills.
EIL/AFS may also collect other non-personally identifiable information about you, such as your use of our websites, communication preferences, aggregated data relative to your use of our services, and anonymized responses to questions and surveys.
Please note, to better safeguard your information, please do not include any credit card information in your electronic communication unless we specifically require it as part of the transaction fulfillment process on the EIL/AFS website.
PURPOSE FOR COLLECTION, PROCESSING, AND DISCLOSURE
Collection & Use
EIL/AFS is committed to providing you with information about the collection and use of PII furnished by, or collected from, visitors while using our websites, products and services. It is our practice not to ask you for information unless we need it or intend to use it. Some of the primary purposes for requesting and collecting your PII are as follows:
- providing our services (online and in the real world), such as addressing an inquiry or processing an application (e.g. when Participants are filling out an application, fulfilling a request for information, or completing a request for services), arranging program placement (e.g. select host families and schools), facilitating and managing a Participant’s involvement in a programme, administering scholarships, administering travel medical insurance, and working with partner organisations, sponsors, and service providers toward that end.
- marketing and communications with you in relation to the services offered by EIL/AFS, and by other trusted third parties.
- conducting fundraising campaigns.
- performing research via surveys, questionnaires and reviews to better serve your needs, improve the effectiveness of our websites, your experience, our various types of communications, campaigns, and/or promotional activities.
- alumni engagement and other outreach activities, to keep you informed about and involved with EIL/AFS activities, (such as campaigns, conferences, publications, recruitment of host families and volunteers, new programs and services).
We retain your PII for periods reasonably necessary to provide our services and outreaching activities. We ask your consent to send you marketing communications. You may opt out of our emails, newsletters, and EIL/AFS surveys and reviews at any time by clicking on the link included in such communications, or by contacting us directly to opt out. You will always be offered the choice not to submit your PII or to decide what communications you want to receive from us. However, doing so may cause certain transactions to become affected. For example, not providing required information such as a name will prevent the processing of an application.
Processing and Disclosure
As a general practice, EIL/AFS does not sell, rent, or give physical possession of your PII to unaffiliated third parties other than relevant and applicable partner Network Organizations and service providers (including third party organizations that EIL/AFS cooperates with for the delivery of its programmes) who need to know in order to carry-out services and requests initiated by you or by EIL/AFS to provide you the EIL/AFS services. As an example, we may provide access (through the EIL/AFS website) or transfer PII to certain, relevant partner Network Organizations that need to receive such information in connection with a placement with a family and a school for an EIL/AFS programme. We work hard to help ensure that such third parties will only share this information with other organizations or individuals that are working with them to operate EIL/AFS-related programs or deliver other EIL/AFS services. It may be in the course of your obtaining EIL/AFS-related services that you end up submitting personal information directly to a partner Network Organization or third party organization, such as online platforms used to deliver the content of online programs, in which case you should read and agree with their privacy policies as requested by those entities before submitting your personal information.
For in-person program participants, EIL/AFS will also access and use medical records shared as part of the programme application or produced during programme participation for the following purposes:
(a) To administer the travel medical insurance purchased as part of the programme services. EIL/AFS, the insurer and the other parties involved in providing the medical plan services will use medical data to the extent necessary to administer the plan and process medical claims.
(b) To assess if a programme participant is and remains fit for the program. This is necessary for EIL/AFS to determine if a medical condition, at the time of the application, or arising during programme participation, is compatible with safely starting and continuing the exchange programme in the hosting country, or if repatriation of a participant is required to return participant to the care of the parents/legal guardians to properly handle the relevant medical issues. Medical records will only be accessed to personnel of the hosting and sending organizations on a need to know basis.
In addition, other situations in which EIL/AFS may disclose your information to affiliated organizations, service providers include:
- when we have received your consent to do so
- in situations where sharing or disclosing your information is required in order to offer you services you desire (e.g., a volunteer or program opportunity, a sweepstakes or promotion)
- when companies or service providers that perform business activities on behalf of EIL/AFS require such information (e.g., credit card processing, customer support services, market research administration or database management services)
- in the event EIL/AFS is merged with or acquired by another company
- to comply with legal or regulatory requirements or obligations in accordance with applicable law, a court order or a subpoena
- In case of emergency such as to safeguard the life, health, or property of an individual
If information is shared as mentioned above, we seek to limit recipients and the scope of information that is furnished to only the amount necessary for the performance of the specific function. Unless otherwise precluded by legal process, we require third parties to protect your PII and abide by applicable privacy laws and regulations.
We sometimes use and share non-personally identifiable information that we collect to maintain the services we offer online, improve the design and content of our sites, to enable us to personalize your experience, analyze trends, gather broad demographic information, conduct research, administer the sites, and strengthen our marketing and branding efforts.
If you are a minor and parent’s/legal guardian’s consent is also required, ask your parents/legal guardians for permission before sharing your PII with us. In this case EIL/AFS can also contact (for example via email) your parents or legal guardians to confirm their consent.
EIL/AFS can also process your PII without consent as legal basis, such as when necessary to fulfill certain transactions and services that you request.
DATA TRANSFERS ACROSS INTERNATIONAL BORDERS
AFS as a global organization, endeavors to provide our services wherever you are. To achieve this goal we use cloud services provided by Google and Amazon Web Services, using data centers located in the U.S, and Singapore. Those databases have a restrictive access and can only be accessed by EIL/AFS employees, consultants, service providers, and volunteers all of whom will use the information exclusively for EIL/AFS activities and the management of the EIL/AFS programme operations. The nature of our business and our operations requires us to process and transfer your information, including PII, to partner Network Organizations, third party organizations and data centers or service providers that may be located in countries outside of Ireland. We may process and transfer the PII we collect about you in and to countries other than the country in which the information was originally collected, including the country of a Network Organization that could place you in an EIL/AFS programme, and by submitting your PII to EIL/AFS in seeking such services or information, you consent to such transfer and processing. Although the data protection and other laws of these various countries may not be as comprehensive as those
ACCESS TO PERSONALLY IDENTIFIABLE INFORMATION
AND OTHER DATA SUBJECT RIGHTS
The European Union’s General Data Protection Regulation and other countries’ privacy laws provide certain rights for data subjects.
If you wish to confirm that we are processing your PII, or to have access to the PII we may have about you, please contact us. You may also request access to your PII or information about: the purpose of the processing; the categories of data concerned; who else outside EIL/AFS might have received the data from EIL/AFS; what the source of the information was (if you didn’t provide it directly to EIL/AFS); and how long it will be stored. You have a right to correct (rectify) the record of your PII maintained by EIL/AFS if it is inaccurate. You may request that EIL/AFS erase that data or cease processing it, subject to certain exceptions. You may also request that EIL/AFS cease using your data for direct marketing purposes. In many countries, you have a right to lodge a complaint with the appropriate data protection authority if you have concerns about how EIL/AFS processes your personal data. For more specific information on your rights in Ireland please visit https://www.dataprotection.ie/en/individuals
To ensure that your PII is accurate and up to date, we encourage you to regularly review and update your information as appropriate. You can review and update your information by contacting us. We may also reach out to you to ask to update your information. Please note that in an effort to prevent the unauthorized disclosure of your PII, you may be asked to provide proof of identity (or other authentication materials). Access to PII cannot be provided by telephone. If, upon review, you wish to deactivate or erase a profile or application, or update your PII, we will endeavor to do so without undue delay. Occasionally, information that you request to be erased will be retained in certain files for a period of time in the framework of our legal retention. In addition, some types of information may be stored longer or indefinitely on “back up” systems or within log files due to technical constraints, or financial or legal requirements. Therefore, you should not always expect that all of your PII will be immediately removed from our databases in response to your request.
Please refer to the appropriate contact information below to contact us if you have any questions about our privacy practices or if you want to submit a request.
EIL/AFS recognizes the importance of information security, and is constantly reviewing and enhancing our technical, physical, and logistical security rules and procedures. All EIL/AFS-owned websites and servers have security measures in place to help protect your PII against accidental, loss, misuse, unlawful or unauthorized access, disclosure, or alteration while under our control. Although “guaranteed security” does not exist either on or off the Internet, we safeguard your information using appropriate administrative, procedural and technical safeguards, including password controls, and the use of up to 256- bit encryption (or more sophisticated encryption as per current industry standards) based on a certificate issued by Digicert Inc. This allows for the use of Secure Sockets Layer (SSL), an encryption method used to help protect your data from interception and hacking while in transit. We implement
firewalls, intrusion detection system, and antivirus software with constant updates and monitoring on irregularities. Cloud servers are protected with logging, monitoring, threat detection, and analytics with identity and access control. ICT personnel utilize encryption, where possible, to prevent direct access to data stored in databases. Access to data stored in the systems is subject to authentication with unique username and password. Users are only allowed to access information that belongs to their responsible area. Online confidentiality agreements are in place, for example as click-through consents, to be accepted at first log-in and then annually, to ensure that certain users that have access to select data are bound by appropriate confidentiality obligations.
ON-LINE TECHNOLOGIES AND COOKIES POLICY
THIRD-PARTY WEBSITES AND NETWORK WEBSITES
In order to anticipate your needs, EIL/AFS may provide links to non-EIL/AFS websites for your convenience and information. EIL/AFS is not responsible or liable for any content presented by or contained on any independent website, including, but not limited to, any advertising claims or marketing practices.
Please note that while EIL/AFS will protect your information on EIL/AFS-owned and operated websites, we cannot control and will not be responsible for the privacy policies of third-party websites, including websites owned or controlled by independent third parties. Third-party websites that are accessed through links on our websites have separate privacy and data collection practices, and security measures. We have no responsibility or liability for the practices, policies and security measures implemented by third parties on their websites. We encourage you to contact them to ask questions about their privacy practices, policies and security measures before disclosing any PII. We recommend that you review the privacy statements and policies of linked websites to understand how those websites collect, use and store information.
Organizations directly if you have any questions.
MINORS & CHILDREN UNDER 13
EIL/AFS does not seek to obtain nor does it wish to receive PII directly from any children under age 13; and we cannot always determine the age of persons who access and use our websites. If we find that we have done so inadvertently, we shall immediately delete such information. In addition, if we find that a minor (as defined by applicable law) provides us with his/her data without parental or guardian consent when required, we will have this information removed unless the parents/guardians approve the provision of such information.
If you have any questions about this policy or our privacy practices, or if you want to submit a request, you can contact us as follows: by email at: [email protected] or by writing to us at: Classic House, 11-13 Washington Street, Cork T12 NHP1.
To follow shortly.