Last modified: Wednesday, May 23, 2018

1. Introduction and Acceptance of Terms

The Savannah College of Art and Design, Inc. ("SCAD," "we" or "our") a company registered at 342 Bull St, Savannah, GA 31401, USA with the contact email address [email protected] is the data controller for the purposes of state, federal and international data protection regulations to include the EU General Data Protection Regulation ("GDPR").

We respect the privacy of our online visitors and recognize the importance of providing a secure environment for them. We have adopted this company-wide privacy policy ("Privacy Policy") that sets out how we collect, store, use and otherwise process the information you provide us.

2. Scope of Privacy Policy

This Privacy Policy applies to your use of the scad.edu website, and any other website owned or operated by SCAD, including any related sub-site, service or feature thereto and all content and software associated therewith (each a "Site" and collectively the "Sites"), SCAD's related mobile device application (the "App"), and related content, software, applications, widgets, materials and/or services (together with the Site and the App, the "Service"). The terms "you" and "your" refer to you, as a user of the Service.

If you do not agree to abide by this or any future Privacy Policy, do not use or access the Service.

This Privacy Policy covers the treatment of personal information gathered when you are using or accessing the Service. This Privacy Policy also covers our treatment of any personal information that our business partners share with us or that we share with our business partners.

3. Information We Collect and How We Collect It

When you use the Service, you provide us with three types of information: (i) information you submit via the Service; (ii) information regarding your use of the Service collected by us as you interact with the Service; and (iii) information from Third-Party Websites and services. The information we gather enables us to personalize content and features, improve and continue to operate the Service and to provide you with the services and information you request. In connection with certain aspects of the Service, we will request, collect and/or display your personal information.

We collect several types of information from and about you, including:

• Information you give us that identifies you, which includes, your email address, legal name, physical or postal address, date of birth, gender and photographs identifying you or other depictions of your likeness and related information like demographic information such as the industry in which you work; and
• Technical information about your use of our Service, which includes, for example, internet connection, your computer or mobile device and operating system, browser and other software you use to access our Service, as well as your Internet Protocol ("IP") address or other device identifiers.

Below, we detail the specific types of information we collect from our users.

Educational Services or Service Information

When you provide information for processing on the Service, you will provide information that could be personal information. You acknowledge that this information is personal to you, and by using the Service and providing personal information to us, you allow others, including us, to identify you, and therefore, you will not be anonymous.

We will use your contact information to send you information about our Service or to send marketing emails. You can with withdraw your consent at any time by clicking on the opt-out button which is found in our marketing emails. If you opt out, we will still send you non-marketing emails. Non-marketing emails include emails about educational services and our business dealings with you. We also reserve the right to contact you when we believe it is necessary.

IP Address Information and Other Information Collected Automatically

We automatically receive and record information from your web browser when you interact with the Service, including your IP address and cookie information. Generally, the Service automatically collects usage information, such as the number and frequency of visitors to the Service. We will use this data in aggregate form, that is, as a statistical measure, but not in a manner that would identify you personally. This type of aggregate data enables us and third parties authorized by us to figure out how often individuals use parts of the Service so that we can analyze and improve them.

Information Collected Using Cookies and Web Beacons

"Cookies" are small data files that are sent to your web browser when you access a website, and the files are stored on your device's hard drive. We use "session" cookies to keep you logged in while you use our Service, to track your preferences and to track trends and monitor usage and web traffic information on our Service. These are erased when you close your browser. We use "persistent" cookies to relate your use of our Service to other information about you and store information about your preferences to make your user experience consistent and customized. For example, we will create a persistent cookie that includes basic information about you, like your favorite website locations and whether customer support responded to your inquiry. These cookies stay on your hard drive until you erase them or they expire and associate your information with your account even if you are logged out.

Most browsers automatically accept cookies, but you can change your settings on the browser settings to refuse cookies or prompt you before accepting cookies. You can also use your browser settings or other tools to delete cookies you already have. However, if you disable or refuse cookies, then certain features of our Service will be inaccessible or not function properly.

Our cookies do not, by themselves, contain personal information, and we do not combine the general information collected through cookies with other personal information to tell us who you are, except to provide customized information tailored to specific interests and/or information you provide SCAD. As noted, however, we do use cookies to identify that your web browser has accessed aspects of the Service and will associate that information with your Account if you have one.

This Privacy Policy covers our use of cookies only and does not cover the use of cookies by third parties. We do not control when or how third parties place cookies on your computer. For example, third-party websites to which links point may set cookies on your computer.

We use web analytics tools that help us understand how users engage with the Service. Like many services, we use first-party cookies to track user interactions, as in our case, where they are used to collect information about how users use the Sites. This information is used to compile reports and to help us improve our Service. The reports disclose website trends without identifying individual visitors.

Clear GIFs and Pixel Tags

We use "clear GIFs" (also known as "web beacons" or "pixel tags") or similar technologies, on our Service or in our communications with you to enable us to know whether you have visited a part of our Service or received a message. A clear GIF is typically a one-pixel, transparent image (although it can be a visible image as well), located on a website or in an email or other type of message, which is retrieved from a remote website on the internet enabling the verification of an individual's viewing or receipt of a website or message.

We do not automatically collect personal information unless directly provided by you in order to receive communications from us, but we will tie personal information with the automatically collected information using the above tools or information collected from other sources.

We also log information using digital images called web beacons on our Service or in our emails. We use web beacons to manage cookies, count visits, and to learn what marketing works and what does not. We also use web beacons to tell if you open or act on our emails.

The Service does not respond to internet browsers' Do Not Track ("DNT") signals.

Information Related to Advertising

To support and enhance the Service, we serve advertisements, and also allow third-party advertisements, through the Service. These advertisements are sometimes targeted and served to particular users and will come from third-party companies called "ad networks." Ad networks include third-party ad servers, ad agencies, ad technology vendors and research firms.

Advertisements served through the Service will be targeted to users who fit a certain general profile category and will be based on (i) anonymized information inferred from information provided to us by a user, including personal information, (ii) Service usage patterns of particular users, or (iii) your activity on a third-party website. We do not provide personal information to any ad networks for use outside of the Service.

4. Minors and Children Under Age 13

We do not knowingly collect or solicit personal information from anyone under the age of 13 or knowingly allow such persons to register for our Service. If you are under 13, please do not attempt to use or register for our Service or send any personal information about yourself to us, including your name, physical address, telephone number, or email address. No one under age 13 will provide any personal information to SCAD or on the Service. In the event that we learn that we have collected personal information from a child under age 13, we will delete that information where reasonably possible. If you believe that we have any information from or about a child under 13, please send a detailed message to [email protected].

5. Our Use of Your Information

As it is in our legitimate interests to process your data to provide effective services and useful content to you, we will use information that we collect about you or that you provide to us, including any personal information, to:

• Provide educational services as requested upon submission of information;
• Communicate with you about the services, content, features or products you use or request;
• Customize and optimize the content or advertisements you receive when you use the Service, and otherwise improve your experience on our Service;
• Analyze and improve our services, which will include tracking traffic, usage, and navigation patterns related to your activities on the Service and the links we provide to third-party websites or advertisements;
• Secure your account and prevent fraud;
• Carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
• Protect our own or third-party rights or interests; and
• In any other way, we will describe when you provide the information.

With your consent, we will process your personal information to notify you of new products, services, features, enhancements, upgrades, contests, promotions, or special offers.

6. Sharing Information with Third Parties

We share information that is not personal information and that does not identify you personally about your interests, your use of the Service, and the links and ads that you follow, with third-party content providers or advertisers located in the United States and which store your personal information in the United States; if we do so, we will not provide them with your name or contact information (including phone numbers) without your prior consent.

We share personal information with our business partners located in the United States and which store your personal information in the United States, in order to provide you a service you use or request, subject to commitments by such parties to use your information only for that purpose and to protect it from disclosure.

We will share personal information with a buyer or other successor located in the United States and which stores your personal information in the United States in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of SCAD's assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by SCAD about our Service users is among the assets transferred.

Additionally, in the following circumstances, we will disclose your personal information without your consent:

• If we believe there is a serious and imminent threat to the life, health or safety of yourself or another person (for example, if we learn that a person is suffering abuse or has made statements of an intent to commit self-harm or harm another);
• To investigate or report on activity which we believe on reasonable grounds to be unlawful;
• If disclosure is required, permitted or authorized by law (for example, in response to a subpoena or where a regulatory authority has the power to request the provision of certain records or information);
• If disclosure is reasonably necessary to enable an enforcement body to perform its functions (for example, the prevention, detection, investigation, prosecution or punishment of criminal offenses, or the preparation for, or conduct of, proceedings before any court or tribunal, or implementation of the orders of a court or tribunal); or
• If we deem it necessary in our sole discretion to protect our legal and legitimate business interests.

We reserve the right to disclose your personal information as required by law or in special cases when we have reason to believe that disclosing such information is necessary to identify, contact, or bring legal action against you if you are violating the Terms of Use for a SCAD website or service. We also reserve the right to disclose your personal information if we have a good faith belief that it is necessary to prevent fraud or other illegal activities.

7. Storing Your Information

The information that we collect from you will be stored at/processed in the United States. Your personal information is also processed by staff operating within the United States who work for us or for one of our business partners. Such staff are engaged in, among other things the processing of your information for educational services, the provision of support services, fulfilment of orders or requests, and the processing of your payment details. We will take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this policy.

8. Securing Your Information

Unfortunately, the transmission of information via the internet or email is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted through the Site or over email; any transmission is at your own risk. Once we have received your personal information, we will take appropriate technical and organizational measures to safeguard your personal information against loss, theft and unauthorized use, access or modification.

We will, from time to time, host links to and from the websites of our affiliates or third parties. If you follow a link to any of these websites, these websites will have their own privacy policies, and we do not accept any responsibility or liability for these policies. Please check these policies before you submit any information to those websites.

9. Data Retention

We will retain your personal information pertaining to your transactions with SCAD, educational services provided by SCAD, or third-party services provided on behalf of SCAD and Services provided through our Sites for such period in which you or us can bring a claim of breach of contract. This period differs based on state, federal, and international data protection regulations.

After you have terminated your use of the Services and our Sites, we will store your information in an aggregated and anonymized format.

10. Members of the European Union (EU)

SCAD adheres to the framework and guidance provided through the General Data Protection Regulation (GDPR) and as such ensures all data rights afforded under GDPR to EU members.

Your Rights

You have rights in relation to the personal information we hold about you. Some of these only apply in certain circumstances. We have described these situations below, as well as how you can exercise your rights. To exercise any of your rights, please contact us at [email protected].

You have the following rights in relation to your personal information:

• Access: to inquire and access personal information held by SCAD and details about how we use it and who we share it with;
• Portability: to receive or ask us to provide your personal information (subject to any applicable law) to a third party in a structured, commonly used and machine-readable format in instances where we process personal information provided by you based on contract or consent;
• Correction: to correct any personal information held about you that is inaccurate and have incomplete data completed (including by the provision of a supplementary statement). Where you request correction, please explain in detail why you believe the personal information we hold about you to be inaccurate or incomplete so that we can assess whether a correction is required. Please note that while we assess whether the personal information we hold about you is inaccurate or incomplete, you may exercise your right to restrict our processing of the applicable data as described below;
• Erasure: that we erase your personal information in certain circumstances;
• Restriction of Processing to Storage Only: to require us to stop processing the personal information we hold about you other than for storage purposes in certain circumstances; and
• Objection: in certain circumstances, to restrict or object to our processing of your personal information. (For example, where you request correction or erasure, you also have a right to restrict processing of your applicable data while your request is considered.)

Withdrawal of Consent

Where you have provided your consent for us to process your personal information, you can withdraw your consent at any time by contacting us directly at [email protected].

Objection to Marketing

At any time, you have the right to object to our processing of data about you, to which you have consented for the purposes of keeping you updated with the latest news about SCAD events, exhibitions, opportunities and exclusive content, and we will stop processing the data for that purpose.

Complaints

IN THE EVENT THAT YOU WISH TO MAKE A COMPLAINT ABOUT HOW WE PROCESS YOUR PERSONAL INFORMATION, PLEASE CONTACT US IN THE FIRST INSTANCE AT [email protected], AND WE WILL ENDEAVOR TO ADDRESS YOUR REQUEST AS SOON AS POSSIBLE. THIS IS WITHOUT PREJUDICE TO YOUR RIGHT TO LAUNCH A CLAIM WITH THE DATA PROTECTION SUPERVISORY AUTHORITY IN THE EU COUNTRY IN WHICH YOU LIVE, WORK, OR THINK WE HAVE INFRINGED DATA PROTECTION LAWS.

11. California Residents

California residents may choose to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes or choose to opt out of such disclosure. Our policy is not to disclose personal information collected online to any third party for direct marketing without your approval. To make a request or to opt out at any time, please contact us at [email protected]. Please indicate what publications or services you no longer wish to receive.

12. Changes to Privacy Policy

This Privacy Policy is effective as of the date stated at the top of this Privacy Policy. It may be necessary from time to time for us to modify this Privacy Policy to reflect changes in the way we collect and use information or changes in privacy-related laws, regulations, and industry standards. Accordingly, we reserve the right to change this Privacy Policy at any time by posting the revised policy on the Service and updating the "last modified" date at the top of this page. We encourage you to refer to this Privacy Policy on an ongoing basis so that you understand our current privacy policy. If revisions to the Privacy Policy are unacceptable to you, you must cease using the Service.

13. Contact Us

If you have any questions or suggestions regarding our Privacy Policy, please contact us at [email protected].