May 28, 2019
Personally Identifiable Information
Certain information we may collect could be used to identify you if you provide it, such as your name, date of birth, Social Security number, phone number, email address, physical address, bank account information, credit card information or any combination of information that could be used to identify you (collectively, the "PII").
We Respect Your Privacy
Hotchkiss respects the privacy of every individual who accesses our website. Hotchkiss does not sell, rent, give away or loan your PII to any third parties (other than agents, contractors or service providers of the Hotchkiss School) unless we have your (or your parent's or guardian's) consent or are required by subpoena, court order or legal process to do so. We maintain appropriate security measures to protect against the loss, misuse, and alteration of the PII under our control.
Information We Collect
Through the website we may collect the following types of information:
- Information you provide to us
To communicate effectively with visitors to our website, we may ask you for information that can include PII. Whenever you use the Hotchkiss website to request admissions information, make a gift or donation to Hotchkiss, purchase an item from a school store, register for an event or sign up for a service such as the Alumni directory, information, including PII, may be requested. This information is used to obtain payment and/or to fulfill the visitor's request.
- Information gathered automatically
Unless you take steps to browse the Internet anonymously Hotchkiss can track web browsing patterns of website visitors when you log on to the Hotchkiss website to better understand how our site is being used. The information we collect is based on your Internet Protocol ("IP") address, and is not linked to your specific email address in any of the reports or other material compiled by Hotchkiss. Your IP address is a series of numbers that identifies the location of each computer or network. Because the IP address is machine specific, it is not, in and of itself, PII. The information we gather may include the browser type, the date and time of the request, average time spent on the website, pages viewed and any inquiries that you may have made. We do not associate your IP address and web usage data with any other information held by Hotchkiss that can specifically identify you unless required to do so by law.
How We Use Your Information
Our primary purpose in collecting information is to provide services and information to you. We may use information that you provide about yourself to fulfill requests for products, programs and services and to respond to inquiries about our offerings.
- Website Improvements or Changes
We might use PII and information gathered automatically to improve your experience on the Hotchkiss website, to inform you of changes to the website or to provide you other news and information about our services and school that we believe would be of interest to you.
Disclosure of PII
Hotchkiss may disclose PII to respond to legal requirements and enforce our school rules and policies. Such information will be disclosed in accordance with applicable laws and regulations.
We may also share PII with:
- Agents, contractors and/or service providers for Hotchkiss who assist with our operations (e.g., the service provider that handles fulfillment of credit card purchases made via the Hotchkiss website);
- Law enforcement or other governmental officials, in response to a verified request relating to an investigation or alleged illegal activity;
- Third parties that provide a valid subpoena or court order; or
- Third parties as requested or authorized by you (or your parent or guardian).
Children's Online Privacy Protection Act
Hotchkiss complies with the Children's Online Privacy Protection Act of 1998 ("COPPA"). COPPA requires that website operators never knowingly request PII from anyone under the age of 13 without requesting verifiable parental consent. In accordance with COPPA, we do not knowingly collect any PII from children under the age of 13. In the event that we determine that a user of this site is under the age of 13, we will not maintain or use his or her PII.
Accessing and Updating PII
When you use the Hotchkiss website, we make good faith efforts to provide you with access to your PII and either to correct this data if it is inaccurate or to delete such data at your request if it is not otherwise required to be retained by law or for legitimate business purposes. We ask individual users to identify themselves and the information requested to be accessed, corrected or removed before processing such requests, and we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backup tapes), or for which access is not otherwise required. In any case where we provide information access and correction, we perform this service free of charge, except if doing so would require a disproportionate effort. Because of the way we maintain certain services, after you delete your information, residual copies may take a period of time before they are deleted from our active servers and may remain in our backup systems. If you wish to access or update your information please contact firstname.lastname@example.org.
Changes to Our Policy
In addition to protecting the privacy of information you provide to the School through activity on the website as detailed above, The Hotchkiss School is also committed to protecting the privacy of people who appear in images posted by the School on the Internet.
Hotchkiss respects the privacy of every constituent who accesses our website and social media properties, including but not exclusive to the following URLs:
The School occasionally posts images on the website or on social media sites of constituents – in particular, alumni and current students. We do not identify students by name in images without permission. We do not post, or permit constituents to post, images that might be deemed inappropriate or embarrassing.
We will honor all requests by users who wish to have images of themselves removed from the website or social media sites. To make such a request, please contact email@example.com.